Jason Bartlett
`
`Elizabeth O"Brien; Vincent Ma; Ray Huang
`Tom Dunham
`
`RE: IPR2022-00915 and -00916 - Discovery Requests
`Friday, May 20, 2022 5:54:34 PM
`
`From:
`
`To:
`Cc:
`
`Subject:
`Date:
`
`Hi Elizabeth,
`
`Thanks for your email. It takes a little time to coordinate schedules with Major Data due to the
`timezone difference. We were able to meet with them this morning.
`| expect we will be able to
`offer a discovery proposal by Monday.
`
`Regards,
`
`Jason
`
`From:Elizabeth O'Brien <elizabetho@ruyakcherian.com>
`Sent: Friday, May 20, 2022 8:42 AM
`To: Jason Bartlett <jbartlett@mkwllp.com>; Vincent Ma <VMa@mkwillp.com>; Ray Huang
`<rhuang@mkwillp.com>
`Cc: Tom Dunham <tomd@ruyakcherian.com>
`Subject: [EXT] RE: IPR2022-00915 and -00916 - Discovery Requests
`
`Hi Jason,
`
`Just following up on when we might expect Major Data’s responsesto the discovery requests.
`
`Thank you,
`Elizabeth
`
`Elizabeth O’Brien
`Associate
`
`RuyakCherian LLP
`1901 L Street NW, Suite 700
`Washington, DC 20036
`O: (202) 873-1726
`M: (703) 930-0505
`
`From: Elizabeth O'Brien
`
`Sent: Monday, May 16, 2022 8:50 PM
`To: Jason Bartlett <jbartlett@mkwllp.com>; Vincent Ma <VMa@mkwllp.com>; Ray Huang
`<rhuang@mkwllp.com>
`Cc: Tom Dunham <tomd@ruyakcherian.com>
`
`Subject: RE: IPR2022-00915 and -00916- Discovery Requests
`
`Major Data, UAB v. Bright Data Ltd.
`IPR2022-00915, EX. 2001
`1 of 4
`
`

`

`Hi Jason,
`
`Thankyoufor taking this request up with Major Data.
`
`As you are aware, based on Petitioner’s Mandatory Notices, there are a numberofdistrict court
`proceedingsinvolving Bright Data and one or more of the Tesonet companies referenced in
`Interrogatory No. 4. Mr. Okmanasis a founder/owner of the Tesonet companies. Therefore, the
`discovery requests are targeted to assess whetherthere is any preexisting relationship between Mr.
`Koltan/Major Data and Mr. Okmanas/Tesonet, possibly personal and/or professional.
`
`For some additional context, we understand that Mr. Koltan is also a co-founder of another
`company, netzet, UAB. We have found some employeesof netzet, UAB who have also worked with
`Teso LT, UAB (f/k/a UAB Tesonet). We also found multiple newsarticles about Mr. Koltan and Mr.
`Okmanasbeingtheinitiators of an idea to distribute local aid to fight coronavirus. One sucharticle
`included the hashtag “WeAreTesonet”. We thoughtthis link might suggest somesort of personal
`and/or professional relationship between Mr. Koltan and Mr. Okmanas.
`
`Weappreciate you taking the time to resolve our concerns as wedo not wish to burden the Board
`with this issue.
`
`Elizabeth
`
`Elizabeth O’Brien
`Associate
`
`RuyakCherian LLP
`1901 L Street NW, Suite 700
`Washington, DC 20036
`O: (202) 873-1726
`M: (703) 930-0505
`
`From:Jason Bartlett <jbartlett@mkwllp.com>
`Sent: Monday, May 16, 2022 7:12 PM
`To: Elizabeth O'Brien <elizabetho@ruyakcherian.com>; Vincent Ma <VMa@mkwllp.com>; Ray
`Huang <rhuang@mkwillp.com>
`Cc: Tom Dunham <tomd@ruyakcherian.com>
`Subject: RE: |IPR2022-00915 and -00916- Discovery Requests
`
`Hello Elizabeth.
`
`I’m not familiar with Thomas
`Good to meet you. We'll take this request up with Major Data.
`Okmanasor the Tesonet family. Could you please point me to the public information you are
`referencing so that | can explain the basis for the proposed requests?
`
`Major Data, UAB v. Bright Data Ltd.
`IPR2022-00915, EX. 2001
`20f4
`
`

`

`Regards,
`
`Jason
`From: Elizabeth O'Brien <elizabetho@ruyakcherian.com>
`Sent: Monday, May 16, 2022 4:04 PM
`To: Jason Bartlett <jbartlett@mkwllp.com>; Vincent Ma <VMa@mkwllp.com>; Ray Huang
`<rhuang@mkwllp.com>
`Cc: Tom Dunham <tomd@ruyakcherian.com>
`Subject: [EXT] IPR2022-00915 and -00916 - Discovery Requests
`
`Dear Counsel,
`
`We write to express our concern in regard to IPR2022-00915 and IPR2022-00916. The petitions
`identified Major Data UAB as the only real party-in-interest and the POAs identified Gerbert Doronin
`Koltan as the Director of Major Data UAB. However, our own searching has revealed public
`information linking Gerbert Doronin Koltan with Thomas Okmanas and/or the Tesonet family of
`companies.
`
`We believe this issue could affect denial of institution due to the time-bar under 35 U.S.C. § 315(b)
`and also whether joinder to IPR2021-01492 or IPR2021-01493 is appropriate.
`
`In order to address this issue, we prepared six discovery requests that are narrowly tailored and
`reasonable, consistent with the Board’s guidance. See, e.g., PTAB Consolidated Trial Practice Guide
`(November 2019) at 28.
`
`Please let us know as soon as possible if Petitioner agrees to provide discovery responses. If
`Petitioner agrees, please provide such responses before Monday, May 23, 2022.
`
`We hope the Parties can reach agreement on this discovery issue. If no agreement is reached, we
`intend to raise this issue on the conference call with the Board regarding joinder.
`
`--
`
`Interrogatory No. 1: When and how did Petitioner become aware of each of Patent Nos. 10,257,319
`and 10,484,510?
`
`Interrogatory No. 2: When and how did Petitioner become aware of each of IPR2021-01492 and
`IPR2021-01493?
`
`Interrogatory No. 3: Does Gerbert Doronin Koltan have a personal and/or professional relationship
`with Thomas Okmanas?
`
`Interrogatory No. 4: Does either Petitioner or Gerbert Doronin Koltan have any relationship with the
`Tesonet family of companies, including any of Code200, UAB; Teso LT, UAB (f/k/a UAB Tesonet);
`Metacluster LT, UAB; Oxysales, UAB; Coretech LT, UAB; or Tefincom SA d/b/a NordVPN?
`
`Major Data, UAB v. Bright Data Ltd.
`IPR2022-00915, EX. 2001
`3 of 4
`
`

`

`Interrogatory No.5: Identify any communication with any non-party discussing Petitioner's
`preparationorfiling of IPR2022-00915 and/or IPR2022-00916. For any tangible communications,
`please produce the document. For any non-tangible communications, please describe the topic, the
`individuals involved, and the approximate date of the communication.
`
`Interrogatory No.6: Identify the corporate structure of Major Data UAB,including any parent,
`subsidiary, or sister (e.g., under common ownership with Major Data UAB) companies.
`
`Thank you,
`Elizabeth
`
`Elizabeth O’Brien
`Associate
`
`RuyakCherian LLP
`1901 L Street NW,Suite 700
`Washington, DC 20036
`O: (202) 873-1726
`M: (703) 930-0505
`
`Major Data, UAB v. Bright Data Ltd.
`IPR2022-00915, EX. 2001
`4 of4
`
`