IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF TEXAS
`DALLAS DIVISION
`
`VALTRUS INNOVATIONS LTD.,
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`Plaintiff,
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`v.
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`GOOGLE LLC,
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`Defendant.
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`Civil Action No. 3:22-CV-00066-N
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`DEFENDANT GOOGLE LLC’S FIRST SET OF INTERROGATORIES TO
`PLAINTIFF VALTRUS INNOVATIONS LTD.,
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`Defendant Google LLC (“Google”) hereby requests and demands pursuant to Federal
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`Rules of Civil Procedure 26 and 33 and the applicable Local Rules of the United States District
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`Court for the Northern District of Texas that Plaintiff Valtrus Innovations Ltd., (“Valtrus”) serve
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`written responses to these Interrogatories within thirty days after the service hereof, at the offices
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`of Quinn Emanuel Urquhart & Sullivan, LLP, 50 California Street, 22nd Floor, San Francisco,
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`California, 94111. These Interrogatories are continuing in nature and require supplemental
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`production under the Federal Rules of Civil Procedure.
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`DEFINITIONS
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`1.
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`“Plaintiff,” “You,” and “Your” means Valtrus Innovations Ltd., and its officers,
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`directors, current and former employees, counsel, agents, consultants, representatives, and any
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`other Persons acting on behalf of any of the foregoing, and Plaintiff’s affiliates, parents, divisions,
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`joint ventures, licensees, franchisees, assigns, predecessors and successors in interest, whether
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`1
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`Ex. 1018
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`foreign or domestic, that are owned or controlled by Plaintiff, and all predecessors and successors
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`in interest to such entities.
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`2.
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`3.
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`“Google” means Defendant Google LLC.
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`“This Litigation” means Valtrus Innovations Ltd., v. Google, LLC, Civil Action No.
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`3:22-CV-00066-N.
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`4.
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`“Complaint” means the Complaint, and any amendments to the Complaint, filed in
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`this Litigation.
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`5.
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`6.
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`7.
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`8.
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`9.
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`10.
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`11.
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`“’704 Patent” shall mean United States Patent No. 6,728,704.
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`“’764 Patent” shall mean United States Patent No. 6,738,764.
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`“’809 Patent” shall mean United States Patent No. 6,816,809.
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`“’604 Patent” shall mean United States Patent No. 7,346,604.
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`“’454 Patent” shall mean United States Patent No. 7,525,454.
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`“’005 Patent” shall mean United States Patent No. 7,748,005.
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`“Asserted Patents” shall mean United States Patent Nos. 6,728,704, 6,738,764,
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`6,816,809, 7,346,604, 7,525,454, and 7,748,005, individually and collectively, including all
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`underlying patent application, continuations, continuations-in-part, divisionals, parents, progeny,
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`reexaminations, or reissues thereof and all foreign counterpart applications and patents which
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`claim the same subject matter.
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`12.
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`“Related Patent” means (1) any United States or foreign patent or patent application
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`related to the Asserted Patents by way of subject matter or claimed priority date, (2) any parent,
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`grandparent or earlier, divisional, continuation, continuation-in-part, provisional, reissue,
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`reexamination, and foreign counterpart patents and applications, and/or (3) any patent or patent
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`2
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`application filed by one of more of the same applicant(s) (or his or her assignees) that refers to any
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`of (1) or (2) herein.
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`13.
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`“Accused Products” shall mean Google’s products and/or services that Plaintiff
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`accuses of Infringement as defined and set forth in Plaintiff’s Infringement Contentions.
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`14.
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`“Asserted Claims” refers to each and every claim of the Asserted Patents that
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`Plaintiff contends that Google Infringes as set forth in Plaintiff’s Infringement Contentions. These
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`claims include only those claims identified in Plaintiff’s Infringement Contentions for which it has
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`set forth its element-by-element contentions per Misc. Order #62, 3-1. These claims do not include
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`those claims identified in Plaintiff’s Infringement Contentions for which Plaintiff has not set forth
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`any contentions but has stated it may amend to do so after it reviews Google’s source code per
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`Misc. Order #62, 3-7(a)(1).
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`15.
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`“Person” refers to any individual, corporation, proprietorship, association, joint
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`venture, company, partnership or other business or legal entity, Including governmental bodies
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`and agencies.
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`16.
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`“Predecessors-in-Interest” shall mean all Persons or entities other than You that
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`have ever held ownership rights to the Asserted Patents.
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`17.
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`18.
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`“Third Party” or “Third Parties” means any Person other than You.
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`“Document” Includes, without limitation, all written, graphic or otherwise recorded
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`material, Including without limitation, microfilms or other film records or impressions,
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`electronically stored information regardless of the form of storage medium, tape recordings or
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`computer cards, floppy disks or printouts, any and all papers, photographs, films, recordings,
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`things, memoranda, books,
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`records, accounts, Communications,
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`letters,
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`telegrams,
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`correspondence, notes of meetings, notes of conversations, notes of telephone calls, inter-office
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`memoranda or written Communications of any nature, recordings of conversations either in
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`writings or upon any mechanical or electronic recording device, Including email, notes, papers,
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`reports, analyses, invoices, canceled checks or check stubs, receipts, minutes of meetings, time
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`sheets, diaries, desk calendars, ledgers, schedules, licenses, financial statements, telephone bills,
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`logs, and any differing versions of any of the foregoing, whether so denominated, formal, informal
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`or otherwise, as well as copies of the foregoing which differ in any way, Including by the addition
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`of handwritten notations or other written or printed matter of any nature, from the original. The
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`foregoing specifically Includes information stored in a computer database and capable of being
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`generated in documentary form, such as electronic mail.
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`19.
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`“Communication” means, without limitation, any transmission, conveyance or
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`exchange of a word, statement, fact, thing, idea, Document, instruction, information, demand or
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`question by any medium, whether by written, oral or other means, Including but not limited to,
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`electronic communications and electronic mail.
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`20.
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`“Prior Art” shall mean the subject matter described in 35 U.S.C. §§ 102 and 103,
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`Including but not limited to, publications, articles, posters, abstracts, chapters, displays, slides,
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`patents, physical devices, prototypes, systems, uses, sales, and offers for sale, and any Documents
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`evidencing any of the forgoing.
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`21.
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`“Infringe” and “Infringement” mean direct
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`infringement, contributory
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`infringement, infringement by inducement, literal infringement, and infringement under the
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`doctrine of equivalents.
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`22.
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`“Regarding” means relating to, referring to, concerning, mentioning, reflecting,
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`pertaining to, evidencing, involving, describing, discussing, commenting on, embodying,
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`responding to, supporting, contradicting, or constituting (in whole or in part), as the context makes
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`appropriate.
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`23.
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`“Identify” or “Identifying” in relation to a Person means to state his or her full name
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`and: (a) present business address(es), position and business affiliation, and business telephone
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`number; or, if current information is not known, (b) the last known business and home addresses,
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`position and business affiliation, and business telephone numbers. Once any Person has been
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`identified properly, it shall be sufficient thereafter when Identifying that same Person to state the
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`name only.
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`24.
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`“Identify” or “Identifying” in relation to an entity means to state the entity’s: (a)
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`full name; (b) state of incorporation; (c) current or last known business address; and (d) current or
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`last known telephone number. Once an entity has been identified properly, it shall be sufficient
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`thereafter when Identifying that same entity to state the name only.
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`25.
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`“Identify” or “Identifying” in relation to a Document means to state: (a) the date
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`the Document was created; (b) the author of the Document; (c) the recipient of the Document; (d)
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`any Person or entity receiving a copy of the Document by “cc,” “bcc,” or otherwise; (e) a basic
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`description of the nature of the Document, Including, if applicable; (f) the title of the Document;
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`and (g) whether the Document has been or is being produced in This Litigation, the Bates or
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`identifier number affixed to the Document. Documents to be “identified” include Documents in
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`Plaintiff’s possession, custody, or control, Documents known by Plaintiff to have existed but no
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`longer exist, and other Documents of which Plaintiff has knowledge or information.
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`26.
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`Identify” or “Identifying” in relation to a product or service means to state the
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`product or service name, commercial or trade name, manufacturer, producer, or service provider,
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`model or version number, part number, type, description, or any other representative designation.
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`5
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`27.
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`“Identify” or “Identifying” in relation to a Communication means: (a) to state the
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`date of the Communication; (b) to Identify all Documents Regarding such Communications; (c) to
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`describe the content and substance of the Communication; (d) to Identify the Persons who received
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`or were involved in the Communication; and (e) to Identify the Person or Persons most
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`knowledgeable about the Communication.
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`28.
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`29.
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`30.
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`“Include” and “Including” shall mean including without limitation.
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`Use of the singular also Includes the plural and vice-versa.
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`The phrase “Written Description” refers to the requirement that “[t]he specification
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`shall contain a written description of the invention” as set forth in 35 U.S.C. §112 para. 1.
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`31.
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`The phrase “Enabling Disclosure” refers to the requirement that “[t]he specification
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`shall contain a written description of . . . the manner and process of making and using [the
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`invention], in such full, clear, concise, and exact terms as to enable any Person skilled in the art to
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`which it pertains, or with which it is most nearly connected, to make and use the same . . .” as set
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`forth in 35 U.S.C. § 112 para. 1.
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`32.
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`The words “or” and “and” shall be read in the conjunctive and in the disjunctive
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`wherever they appear, and neither of these words shall be interpreted to limit the scope of these
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`Interrogatories.
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`The words “any,” “all,” “every,” and “each” shall each mean and include the other.
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`The use of a verb in any tense shall be construed as the use of the verb in all other
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`33.
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`34.
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`tenses.
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`The following instructions shall apply to each of the Interrogatories herein:
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`INSTRUCTIONS
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`1.
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`In answering the following Interrogatories, furnish all available information,
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`Including information in the possession, custody, or control of You or any of Your attorneys,
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`directors, officers, agents, employees, representatives, associates, investigators or division
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`affiliates, partnerships, parents or subsidiaries, and Persons under Your control, who have the best
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`knowledge, not merely information known to You based on Your own personal knowledge.
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`If You cannot fully respond to the following Interrogatories after exercising due diligence
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`to secure the information requested thereby, so state, and specify the portion of Interrogatories that
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`cannot be responded to fully and completely. In the latter event, state what efforts were made to
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`obtain the requested information and the facts relied upon that support the contention that the
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`Interrogatories cannot be answered fully and completely; and state what knowledge, information
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`or belief You have concerning the unanswered portion of any such Interrogatories.
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`2.
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`If any information requested is claimed to be privileged or otherwise immune from
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`discovery, please provide all information falling within the scope of the Interrogatory which is not
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`privileged, and for each item of information contained in a Document to which a claim of privilege
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`is made, Identify such Document with sufficient particularity for purposes of a motion to compel,
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`such identification to include at least the following:
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`a)
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`b)
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`c)
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`d)
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`e)
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`the basis on which the privilege is claimed;
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`the names and positions of the author of the information;
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`the name and position of each individual or other Person to whom the
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`information, or a copy thereof, was sent or otherwise disclosed;
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`the date of the information;
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`a description of any accompanying material transmitted with or attached to
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`such information;
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`f)
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`g)
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`the number of pages in such document or information; and
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`whether any business or non-legal matter is contained or discussed in such
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`information.
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`3.
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`If Your response to a particular Interrogatory is a statement that You lack the ability
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`to comply with that Interrogatory, You must specify whether the inability to comply is because the
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`particular item or category of information never existed, has been destroyed, has been lost,
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`misplaced, or stolen, or has never been, or is no longer, in Your possession, custody, or control, in
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`which case the name and address of any Person or entity known or believed by You to have
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`possession, custody, or control of that information or category of information must be identified.
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`4.
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`Your obligation to respond to these Interrogatories is continuing and its responses
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`are to be supplemented to Include subsequently acquired information in accordance with the
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`requirements of Rule 26(e) of the Federal Rules of Civil Procedure.
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`INTERROGATORIES
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`INTERROGATORY NO. 1.
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`For each claim of each of the Asserted Patents, describe in detail on an element-by-element
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`basis, all facts Regarding its conception and reduction to practice, Including but not limited to
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`Identifying each purported inventor, the date of conception, the date of reduction to practice of its
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`subject matter, all acts You contend represent diligence occurring between the dates of conception
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`and reduction to practice, each Person involved in such conception, diligence and/or reduction to
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`practice and each such person’s specific contributions thereto, where the invention was first
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`conceived and/or reduced to practice, when, where, and to whom the invention was first disclosed,
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`and Identifying each Person, Including Third Parties, who worked on any portion (no matter how
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`trivial) of the subject matter and/or alleged invention(s) described and claimed in each of the
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`Asserted Patents, describing in detail each Person’s role (e.g., producer, developer, tester,
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`technician, researcher, etc.) and the dates and places each such Person assisted, supervised, or was
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`otherwise so involved, and Identifying all Documents Regarding these facts.
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`INTERROGATORY NO. 2.
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`Identify each product, service or software known to You that You contend practices,
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`practiced, embodies, or embodied any Asserted Claim of the Asserted Patents, Including without
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`limitation products, services or software designed, programmed, owned, marketed or sold by any
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`Third Party, and Including, without limitation, products marked pursuant to 35 U.S.C. § 287, and
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`Identify each such claim practiced by each such product, service, or software, Including but not
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`limited to by Identifying for each Asserted Claim any Documents Regarding such claimed
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`embodiments, and any Persons with knowledge of such facts.
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`INTERROGATORY NO. 3.
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`Describe in detail and Identify any and all inspection, testing, evaluation, or analysis,
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`whether performed by You or on Your behalf, or by any Third Party, of any of Google’s products
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`or services that You allege Infringes any claims of any of the Asserted Patents, and state: the
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`particular products inspected, tested, evaluated or analyzed; the nature of the inspection, testing,
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`evaluation or analysis performed; when such inspection, testing, evaluation or analysis was
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`performed; any and all Persons involved in the inspection, testing, evaluation, or analysis; the dates
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`of the inspection, testing, evaluation, or analysis; the results of such inspection, testing, evaluation,
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`or analysis, Including Identifying the Documents Regarding those results; and any conclusion(s)
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`or opinion(s) formed as a result of each inspection, testing, evaluation, or analysis.
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`INTERROGATORY NO. 4.
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`Describe in detail each offer made by Plaintiff, its Predecessors-in-Interest, or any other
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`Person to any Third Party Regarding the licensing or sale of any of the Asserted Patents or any
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`Related Patent, whether individually or in combination with any other patents, by Identifying the
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`name of the entity, the date of each offer, Identification of the Persons involved, the royalty rate
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`offered, the terms or basis on which such proposed royalty rate was calculated, any other proposed
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`or actual consideration or value to be paid or given by such Third Party in exchange for the license
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`or sale; if the Third Party did not take a license or purchase any of the Asserted Patents or any
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`Related Patent, any stated reasons for why it did not do so; Identification of the Documents
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`Regarding the negotiations, Including if the entity did take a license or purchase any of the
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`Asserted Patents or any Related Patent, the Bates number in Your document production of that
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`agreement.
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`INTERROGATORY NO. 5.
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`State in complete detail all financial remedies, Including any claim for damages in the form
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`of lost profits or a reasonable royalty, to which You contend You are entitled in this case, Including
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`without limitation all factual, legal, and evidentiary bases for such contention and a detailed
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`description of how such damages have been calculated, Including without limitation any profits
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`You contend You lost, the form of royalty You contend is appropriate, the date of any hypothetical
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`negotiation You contend is applicable, any royalty rate You contend should apply, and the royalty
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`base You contend it should be applied to, the factors by which You calculated that royalty rate,
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`whether you contend the Entire Market Value Rule should apply and the basis for Your
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`contentions, and Including Your assessment of the factors set forth in Georgia Pacific Corp. v.
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`United States Plywood Corp., 318 F. Supp. 1116 (S.D.N.Y. 1970), the factors by which You
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`determined the royalty base to which the rate should be applied, and the identity of all Documents
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`that contain information Regarding Your damages contentions and Persons with knowledge
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`Regarding Your damages contentions.
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`INTERROGATORY NO. 6.
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`For each and every of Google’s products or services that You allege Infringes any claims
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`of any of the Asserted Patents: Identify each Asserted Claim of each of the Asserted Patents
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`allegedly infringed, Including for each claim the applicable statutory subsections of 35 U.S.C.
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`§271 asserted; each accused apparatus, product, device, service, process, method, act, or other
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`instrumentality of Google by name, if known, Including Identifying all Documents supporting
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`Your allegations; describe the complete factual and legal bases for Your contentions of
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`infringement, Including by Identifying all Documents that contain information Regarding Your
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`Infringement contentions and Persons with knowledge Regarding Your Infringement contentions;
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`provide a chart Identifying specifically where and how each element of each Asserted Claim is
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`found within each apparatus, product, device, service, process, method, act, or other
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`instrumentality; Include for each limitation governed by 35 U.S.C. § 112(6), the identity of the
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`structure(s), act(s), or material(s) in the Accused Instrumentality that performs the claimed
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`function; and Identify whether You contend each element from each Asserted Claim is literally
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`present or present under the doctrine of equivalents for each accused apparatus, product, device,
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`service, process, method, act, or other instrumentality.
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`INTERROGATORY NO. 7.
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`Separately for each claim which is alleged to have been indirectly infringed by Google,
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`describe the complete basis for Your contention that it is indirectly infringed by Google by
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`Identifying the product or service, Identifying which claims in any of the Asserted Patents have
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`allegedly been indirectly Infringed, Identifying the specific act(s) by Google that You contend
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`caused, urged, encouraged or aided the infringing conduct, Identifying any third parties you
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`contend Infringe that claim, describing the complete basis for Your contention that Google knew
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`or was willfully blind that its conduct was infringing, and describing the complete basis for Your
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`contention that Google had specific intent to encourage such Infringement.
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`INTERROGATORY NO. 8.
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`Separately for each claim of the Asserted Patents that You contend has been willfully
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`Infringed by Google, describe the complete basis for Your contention that Google’s Infringement
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`has been or is willful, including without limitation, stating the date and manner in which You
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`contend Google was first notified or became aware that it was allegedly infringing the Asserted
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`Patents, and the allegedly infringing activity.
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`INTERROGATORY NO. 9.
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`Describe in detail and chronologically the complete ownership interests, Including the
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`chain of title, of the Asserted Patents or any Related Patent, Including: an identification of each
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`and every Person or party that has ever had a financial interest in any or all of the Asserted Patents
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`or any Related Patent of any kind; any and all promises, transfers, liens, assignments, and
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`agreements Regarding the ownership of any or all Asserted Patents or any Related Patent, or
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`transfer or assignment thereof; an identification of when and how each and every transfer or
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`assignment of interest occurred from the named inventor through Valtrus’s purported ownership
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`of them; and an identification of each Document Related to ownership interests in the Asserted
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`Patents or any Related Patent.
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`INTERROGATORY NO. 10.
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`State whether Plaintiff contends there are secondary considerations that should be
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`considered by the Court in connection with its determination pursuant to 35 U.S.C. § 103 of the
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`validity of each Asserted Claim of the Asserted Patents, and if the answer is anything other than
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`an unqualified negative for any Asserted Claim, Identify for that claim each such secondary
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`consideration and describe in detail Plaintiff’s contentions as to why each such secondary
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`consideration demonstrates obviousness or non-obviousness and all facts in support thereof,
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`including but not limited to any Documents in support of such facts, testimony from past cases in
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`support of such facts, and any Persons with knowledge of such facts.
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`INTERROGATORY NO. 11.
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`For each limitation of each Asserted Claim of the Asserted Patents, Identify, in claim chart
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`form, all evidence, including portions of the specification, that You contend provide Written
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`Description support and an Enabling Disclosure.
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`INTERROGATORY NO. 12.
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`State Plaintiff’s contentions as to what constitutes the level of skill of a Person of ordinary
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`skill in the art of the subject matter of each Asserted Claim of the Asserted Patents as of its
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`conception date.
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`INTERROGATORY NO. 13.
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`For each Asserted Claim of the Asserted Patent, Identify the priority date to which each
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`Asserted Claim is allegedly entitled, and Your basis for asserting such earlier priority date,
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`Including by Identifying the supporting disclosure in each earlier application upon which You are
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`asserting priority on an element-by-element basis in each Asserted Claim.
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`INTERROGATORY NO. 14.
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`For each Asserted Claim of the Asserted Patents, explain in detail all legal and factual bases
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`for Your contention that the Asserted Claims are not invalid under 35 U.S.C. §§ 101, 102, 103, or
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`112, including without limitation, Your contentions that the Asserted Claims are not invalid for
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`indefiniteness, lack of enablement, or lack of written description.
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`INTERROGATORY NO. 15.
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`For each Asserted Claim of the Asserted Patents, describe in detail any non-infringing
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`alternatives to the Accused Products, including, for each such alternative, the date range on which
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`You contend or believe it was, or could have been, available to Defendant, why You contend each
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`alternative would or would not have been acceptable to Defendant, and Identify all facts in support
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`thereof, Including but not limited to any Documents, testimony, and any Persons with knowledge.
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`INTERROGATORY NO. 16.
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`Describe in detail any valuation of the Plaintiff’s patent portfolio, including any valuation
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`of the Asserted Patents or Related Patents, by Identifying the date of the valuation, the Person or
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`party conducting the valuation, all materials reviewed, considered, or relied upon in connection
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`with the valuation, any Communications Regarding the valuation, and by describing Plaintiff’s
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`reaction to the valuation, including how the valuation was used by Plaintiff, and Identify all facts
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`in support thereof, Including but not limited to any Documents, testimony, and any Persons with
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`knowledge.
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`INTERROGATORY NO. 17.
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`Describe in detail Your relationship with any Person having a financial or pecuniary
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`interest in the outcome of This Litigation, including a description of relationship, any investments
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`or monies You have received from any such Person, the amount or percentage of each Person’s
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`interest in This Litigation, the amount or percentage of each Person’s interested in the Plaintiff, all
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`materials exchanged between Plaintiff or its Predecessors-in-Interest and such Person regarding
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`This Litigation, the Asserted Patents, Defendant, or Asserted Products, and Identify all facts in
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`14
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`support thereof, Including but not limited to any Documents, testimony, and any Persons with
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`knowledge.
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`15
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`DATED: April 21, 2022
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`By: /s/ Deepa Acharya
`
`Deepa Acharya (pro hac vice)
`Patrick Stafford (pro hac vice)
`QUINN EMANUEL URQUHART &
`SULLIVAN, LLP
`1300 I Street, NW
`Washington, DC 20005
`202-538-8107 (Telephone)
`202-538-8100 (Facsimile)
`
`Charles K. Verhoeven (pro hac vice)
`David A. Perlson (pro hac vice forthcoming)
`Michael Trombetta (pro hac vice forthcoming)
`QUINN EMANUEL URQUHART &
`SULLIVAN, LLP
`50 California Street, 22nd Floor
`San Francisco, CA 94111
`415-875-6600 (Telephone)
`415-875-6700 (Facsimile)
`
`Michael K. Hurst
`mhurst@lynnllp.com
`Texas Bar No. 10316310
`Patrick Disbennett
`pdisbennett@lynnllp.com
`Texas Bar No. 24094629
`Barira Munshi
`bmunshi@lynnllp.com
`Texas Bar No. 24095924
`
`LYNN PINKER HURST &
`SCHWEGMANN LLP
`2100 Ross Avenue, Suite 2700
`Dallas, Texas 75201
`(214) 981-3800 (Telephone)
`(214) 981-3839 (Facsimile)
`
`
`ATTORNEYS FOR DEFENDANT
`GOOGLE LLC
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`16
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`CERTIFICATE OF SERVICE
`
`I hereby certify that on April 21, 2022, the foregoing was served via email on all counsel of record.
`
`/s/ Haihang Wang
`Haihang Wang
`
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`17
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