`Patent 6,993,658
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`AMAZON.COM, INC.
`
`Petitioners,
`v.
`DYNAPASS IP HOLDINGS LLC
`
`Patent Owner
`__________________
`Inter Partes Review No. IPR2024-00283
`Patent No. 6,993,658
`
`DYNAPASS IP HOLDINGS LLC’S
`DISCOVERY REQUESTS TO PETITIONER
`
`Ex. 2002, p. 1
`Amazon.com, Inc. v. Dynapass IP Holdings LLC, IPR2024-00283
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`
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`IPR2024-00283
`Patent 6,993,658
`
`
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`Patent Owner Dynapass IP Holdings LLC (“Patent Owner”) requests that
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`Petitioner Amazon.com, Inc. (“Petitioner”) respond to the following Interrogatories.
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`Instructions
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`1.
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`Petitioner must answer each Interrogatory fully, in writing, and under
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`oath. Fed. R. Civ. P. 33(b)(3).
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`2.
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`If Petitioner claims that the attorney-client privilege or any other
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`privilege or protection is applicable to any of the information requested by an
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`Interrogatory, Petitioner shall set forth separately: (a) the type of information
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`withheld; (b) a detailed description of the subject matter of the information; (c) the
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`name, address, and job title of each person who received or conveyed this
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`information; and (d) a statement of the basis upon which the claim of privilege or
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`protection is made.
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`3.
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`Petitioner has an ongoing obligation to timely supplement its response
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`if Petitioner learns that its response is incomplete or incorrect. Fed. R. Civ. P.
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`26(e)(1).
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`Discovery Requests
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`Interrogatory No. 1: Identify whether Petitioner has ever been a direct or
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`indirect member of Unified Patents, LLC.
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`
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`1
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`Ex. 2002, p. 2
`Amazon.com, Inc. v. Dynapass IP Holdings LLC, IPR2024-00283
`
`
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`IPR2024-00283
`Patent 6,993,658
`
`
`
`Interrogatory No. 2: To the extent Petitioner has ever been a direct or indirect
`
`member of Unified Patents, LLC, identify the date(s) when Petitioner was a direct
`
`or indirect member of Unified Patents, LLC.
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`Dated March 29, 2024
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`Respectfully submitted,
`
`By: /John Wittenzellner/
`John Wittenzellner
`USPTO Registration No. 61,662
`Counsel for Patent Owner
`Dynapass IP Holdings LLC
`
`
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`2
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`Ex. 2002, p. 3
`Amazon.com, Inc. v. Dynapass IP Holdings LLC, IPR2024-00283
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`
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