Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`ESTTA710799
`ESTTA Tracking number:
`11/25/2015
`
`Filing date:
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`91184047
`Plaintiff
`Farmaco-Logica B.V.
`PAUL KUKS
`FARMACO-LOGICA BV
`WOLKENDEK 17
`3454 TG DE MEERN,
`NETHERLANDS
`paul.kuks@farmlog.net
`Plaintiff's Notice of Reliance
`Paul Kuks
`Paul.Kuks@farmlog.net
`/paul kuks/
`11/25/2015
`AO15K25CA.oppositionTo77029672-opposersFirstNoticeOfReliance.pdf(44746
`24 bytes )
`
`Proceeding
`Party
`
`Correspondence
`Address
`
`Submission
`Filer's Name
`Filer's e-mail
`Signature
`Date
`Attachments
`
`

`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`In the matter of Application Serial No. 77029672
`By The TriZetto Group, Inc. for the mark: FACETS
`Filed: October 26, 2006
`Published for opposition on May 29, 2007
`
`Farmaco-Logica B.V.
`
`versus
`
`Opposer,
`
`TriZetto Corporation f/k/a The TriZetto
`Group, Inc.
`
`Applicant.
`
`Opposition no. 91184047
`
`Serial no. 77029672
`
`OPPOSER'S FIRST NOTICE OF RELIANCE
`
`In conformance with 37 C.F.R. 2.120 and 37 C.F.R. 2.122, Opposer Farmaco-
`
`Logica B.V. (hereinafter: “Opposer”) hereby indicates its intention to rely upon the
`
`following documents as evidence to support its opposition in the above-captioned
`
`proceeding.
`
`Exhibit A is a copy of Opposer's Third Set of Requests for Admission served to
`
`Applicant on August 15, 2011. This document is relevant for showing that Applicant's
`
`FACETS mark has been used on Applicant's web site adjacent to the statutory
`
`registration symbol and in connection with computer software.
`
`Exhibit B is a copy of Applicant's responses to Opposer's Third Set of Requests for
`
`Admission served to Opposer on July 26, 2012. This document is relevant because it
`
`contains admissions concerning Applicant's misuse of the statutory registration symbol.
`
`Opposer's First Notice of Reliance, opposition number 91184047
`AO15K25CA
`
`page 1 of 2
`
`

`
`Exhibit C contains part of Opposer's Second Set of Requests for Admission served
`
`to Applicant on November 7, 2010. This document is relevant because it contains the
`
`relevant part of an exhibit to which Applicant's responses (in Exhibit D) pertain.
`
`Exhibit D contains the relevant part of Applicant's responses to Opposer's Second
`
`Set of Requests for Admission served to Opposer on December 13, 2010. This
`
`document is relevant because it contains admissions of Applicant concerning its misuse
`
`of the statutory registration symbol.
`
`Dated: November 25, 2015
`
`Respectfully submitted,
`
`Paul Kuks
`Farmaco-Logica B.V.
`Wolkendek 17
`3454 TG DE MEERN
`The Netherlands
`
`Paul.Kuks@farmlog.net
`
`managing director of plaintiff
`
`Opposer's First Notice of Reliance, opposition number 91184047
`AO15K25CA
`
`page 2 of 2
`
`

`
`EXHIBIT A
`
`Opposer's First Notice of Reliance, opposition number 91184047
`AO15K25CA
`
`

`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`In the matter of Application Serial No. 77029672
`By The TriZetto Group, Inc. for the mark: FACETS
`Filed: October 26, 2006
`Published for opposition on May 29, 2007
`
`Farmaco-Logica B. V.
`
`versus
`
`The TriZetto Group, Inc.
`
`Opposition no. 91184047
`
`Serial no. 77029672
`
`Opposer,
`
`Applicant.
`
`OPPOSER'S THIRD SET OF REQUESTS FOR ADMISSION TO
`APPLICANT
`
`Pursuant to Rule 33 of the Federal Rules of Civil Procedure, Opposer Farmaco-
`
`Logica B.V. ("Opposer"), by and through its managing director, hereby serves the
`
`following Requests for Admission to be answered separately and fully in writing and
`
`under oath by Applicant, The TriZetto Group, Inc. ("Applicant"). Applicant must serve its
`
`Answers to these Requests on Opposer at its offices (Wolkendek 17,
`
`3454 TG DE MEERN, The Netherlands) within thirty (30) days following service of these
`
`Requests.
`
`INSTRUCTIONS AND DEFINITIONS
`
`The instructions and definitions contained in Opposer's Third Set of
`
`Interrogatories to Applicant are incorporated herein by reference.
`
`Opposer's third set of requests for admission to Applicant, opposition
`number 91184047
`A011H15AA
`
`page 1 ot7
`
`l�
`
`

`
`REQUESTS FOR ADMISSION
`
`REQUEST NO. 1:
`Admit that Applicant's Chief Executive Officer knew on May 8, 2006 that The
`
`TriZetto Group, Inc. did not own a FACETS trademark registration for computer software
`
`products.
`
`RESPONSE TO REQUEST NO. 1:
`
`REQUEST NO. 2:
`Admit that Applicant's Chief Executive Officer knew on August 7, 2006 that The
`
`TriZetto Group, Inc. did not own a FACETS trademark registration for computer software
`
`products.
`
`RESPONSE TO REQUEST NO. 2:
`
`REQUEST NO. 3:
`Admit that Applicant's Chief Executive Officer knew on March 16, 2007 that The
`
`TriZetto Group, Inc. did not own a FACETS trademark registration for computer sofware
`
`products.
`
`RESPONSE TO REQUEST NO. 3:
`
`REQUEST NO. 4:
`Admit that Applicant's Chief Executive Officer knew on May 8, 2007 that The
`
`TriZetto Group, Inc. did not own a FACETS trademark registration for computer software
`
`Opposer's third set of requests for admission to Applicant, opposition
`number 91184047
`A01Hl5AA
`
`page 2 of7
`
`

`
`products.
`
`RESPONSE TO REQUEST NO. 4:
`
`REQUEST NO. 5:
`Admit that Applicant's Chief Executive Officer knew on August 8, 2007 that The
`
`TriZetto Group, Inc. did not own a FACETS trademark registration for computer software
`
`products.
`
`RESPONSE TO REQUEST NO. 5:
`
`REQUEST NO. 6:
`Admit that Applicant's Chief Executive Officer knew on November 2, 2007 that
`
`The TriZetto Group, Inc. did not own a FACETS trademark registration for computer
`
`software products.
`
`RESPONSE TO REQUEST NO. 6:
`
`REQUEST NO. 7:
`Admit that Applicant's Chief Executive Officer knew on August 8, 2008 that The
`
`TriZetto Group, Inc. did not own a FACETS trademark registration for computer software
`
`products.
`
`RESPONSE TO REQUEST NO. 7:
`
`REQUEST NO. 8:
`Admit that Exhibit A, attached hereto, accurately reflects the Internet website page
`
`Opposer's third set of requests for admission to Applicant, opposition
`number 91184047
`A011H15AA
`
`

`
`at www.trizetto.com/company/corporateHistory.asp as of August 1, 2011.
`
`RESPONSE TO REQUEST NO. 8:
`
`REQUEST NO. 9:
`Admit that Exhibit B, attached hereto, accurately reflects the Internet website page
`
`at www.trizetto.com/company/corporateprofile.asp s of August 11, 2011.
`
`RESPONSE TO REQUEST NO. 9:
`
`REQUEST NO. 10:
`Admit that Exhibit C, attached hereto, accurately reflects the Internet website page
`
`at www.trizetto.com/hpSolutions/coreAdministration.asp as of August 11, 2011.
`
`RESPONSE TO REQUEST NO. 10:
`
`REQUEST NO. 1:
`Admit that Exhibit D, attached hereto, accurately reflects the Internet website page
`
`at www.trizetto.com/hpsolutions/facetsfxi.asp as of August 11, 2011.
`
`RESPONSE TO REQUEST NO. 1:
`
`REQUEST NO. 12:
`
`Admit that Exhibit E, attached hereto, accurately reflects the Internet website page
`
`at ww.trizetto.com/hpsolutions/medicaid.asp s of August 1, 2011.
`
`RESPONSE TO REQUEST NO. 2:
`
`Opposer's third set of requests for admission to Applicant, opposition
`number 91184047
`A011H15AA
`
`

`
`REQUEST NO. 13:
`REQUEST N0. 13:
`Admit that Exhibit F, attached hereto, accurately reflects the Internet website page
`Admit that Exhibit F, attached hereto, accurately reflects the Internet website page
`
`at ww.trizetto.com/hpsolutions/memberEnrollment.asp as of August 1, 2011.
`at www.trizetto.com/hpsolutions/memberEnrol|ment.asp as of August 11. 2011.
`
`RESPONSE TO REQUEST NO. 13:
`RESPONSE TO REQUEST NO. 13:
`
`REQUEST NO. 14:
`REQUEST N0. 14:
`Admit that Exhibit G, attached hereto, accurately reflects the Internet website page
`Admit that Exhibit G, attached hereto. accurately reflects the Internet website page
`
`at www.trizetto.com/hpsolutions/memberService.asp as of August 1, 2011.
`at wvwv.trizetto.com/hpsolutions/memberService.asp as of August 11. 2011.
`
`RESPONSE TO REQUEST NO. 14:
`RESPONSE TO REQUEST NO. 14:
`
`REQUEST NO. 15:
`REQUEST N0. 15:
`Admit that Exhibit H, attached hereto, accurately reflects the Internet website page
`Admit that Exhibit H. attached hereto. accurately reflects the Internet website page
`
`at ww.trizetto.com/hpsolutions/providerService.asp as of August 11, 2011.
`at www.trizetto.com/hpsolutions/providerservice.asp as of August 11, 2011.
`
`RESPONSE TO REQUEST NO. 15:
`RESPONSE TO REQUEST NO. 15:
`
`REQUEST NO. 16:
`REQUEST N0. 16:
`Admit that Exhibit I, attached hereto, accurately reflects the Internet website page at
`Admit that Exhibit I. attached hereto. accurately reflects the Internet website page at
`
`www.trizetto.com/newsEvents/pressKitGiossary.asp as of August 11, 2011.
`wvvw.trizetto.com/news Events/pressKitGlossary.asp as of August 11, 2011.
`
`RESPONSE TO REQUEST NO. 16:
`RESPONSE TO REQUEST NO. 16:
`
`REQUEST NO. 17:
`REQUEST NO. 17:
`Admit that Exhibit J, attached hereto, accurately reflects the Internet website page
`Admit that Exhibit J. attached hereto. accurately reflects the Internet website page
`
`at www.trizetto.com/newsEvents/pressKitHIPAAfaqs.asp as of August 11, 2011.
`at wvvw.trizetto.com/newsEvents/pressKitHIPAAfaqs.asp as of August 11. 2011.
`
`RESPONSE TO REQUEST NO. 17:
`RESPONSE TO REQUEST NO. 17:
`Opposer's third set of requests for admission to Applicant, opposition
`Opposer's third set of requests for admission to Applicant, opposition
`number 9118404 7
`number 91184047
`AO1lHl5AA
`A011H15AA
`
`page 5 of7
`page 5 017
`
`I?»
`
`

`
`REQUEST NO. 18:
`
`Admit that Exhibit K, attached hereto, accurately reflects the Internet website page
`
`at www.trizetto.com/newsEvents/pressKitlndustrylnfo.asp as of August 1, 2011.
`
`RESPONSE TO REQUEST NO. 18:
`
`REQUEST NO. 19:
`Admit that Exhibit L, attached hereto, accurately reflects the Internet website page
`
`at www. trizetto.com/newsEvents/pressReleases/2009-11-17 _ VBBSolutions.asp as of
`
`August 1, 2011.
`
`RESPONSE TO REQUEST NO. 19:
`
`REQUEST NO. 20:
`Admit that Exhibit M, attached hereto, accurately reflects the Internet website page
`
`at www.trizetto.com/newsEvents/pressReleases/2010-02-04_CCHP.asp as of
`
`August 1, 2011.
`
`RESPONSE TO REQUEST NO. 20:
`
`REQUEST NO. 21:
`
`Admit that Exhibit N, attached hereto, accurately reflects the Internet website page
`
`at ww. trizetto.com/newsEvents/pressReleases/2011-05-25 _highest posbrating.asp as
`
`of August 1, 2011.
`
`RESPONSE TO REQUEST NO. 21:
`
`Opposer's third set of requests for admission to Applicant, opposition
`number 91184047
`AOlHSAA
`
`page 6 of7
`
`

`
`Dated: August 15, 2011
`
`Respectfully submitted,
`
`Paul Kuks
`Farmaco-Logica B.V.
`Wolkendek 17
`3454 TG DE MEERN
`The Netherlands
`
`Paui.Kuks@farmlog.net
`
`managing director of plaintiff
`
`Opposer's third set of requests for admission to Applicant, opposition
`number 91184047
`A011H15AA
`
`page 7 of7
`
`

`
`Exhibit A
`
`Opposer's third set of requests for admission to Applicant, opposition
`number 91184047
`A01Hl5AA
`
`

`
`TRIZETTO
`
`I Home
`
`I C
`
`J Power Star Awa
`
`nded in 1997, The TriZetto Group, Inc., is an information technology and
`"''rv'"'� company focused on the healhcare industry.
`
`name TriZetto is derived from an Italian musical term, terzetto, which is a
`r,,mnn�itinn consisting of three parts. Similarly, TriZetto seamlessly blends the
`ntial technology and service components- infrastructure, primary
`(a)plictticms and information access and reporting - to create a complete solution
`works for your organization.
`
`2008
`
`January - TriZetto announces the availability of the TriZetto
`Member Benefit Profile•M and TriZetto Treatment Cost Navigator•M to
`healthcare payers. Additionally, significant enhancements are added
`to the company's Benefit Cost Modeler•M application. The three
`consumer-facing Web applications enable plan members to make
`better healthcare decisions by providing real-time, personalized
`information about benefit choices, treatment options, related costs
`and health benefit usage.
`
`Blue Shield of Califonia contracts with TriZetto to acquire software
`for a major system-wide technology upgrade with the company's
`Facet® software. The technology infrastructure improvement Is
`expected to ease doing business with the not-for-profit health plan,
`which has more than 3 million members and 4,500 employees.
`
`February - TriZetto repos increases of 30 percent in revenue and
`45 percent in adjusted EBITDA for full-year 2007 and posts
`bookings of $163 million for 04.
`
`Blue Cross & Blue Shield of Rhode Island selecs TriZetto's Facet®
`enterprise administration system, along with TriZetto's Facets
`Workflow•M, NetworX PricerTM, Benefit Cost Modeler•M, Facets Inter­
`Plan Telepocessing System (ITS) and Provider POS Direct'M, to
`improve the health plan's claims proessing, premium billing,
`
`hup://www.trizetto.om/comny/corpoateHistory.sp (l of9) [11·8·2011 14:57:28]
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`

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`membership administration and other core administrative functions.
`TriZetto also will provide long-term application management and
`hosting, as well as implementation consult.ing services to BCBSRI.
`
`QuaiChoice of Arkansas, the state's scond-largest managed care
`company and health benefits administrator, selects TriZetto's
`comprehensive suite of fraud, waste and abuse services. These
`services will help QuaiChoice identify, recover and subsequently
`prevent claims overpayments resulting from fraud and abuse.
`
`March - TriZetto announces that Triple-S Management Corporation
`(NYSE: GTS) signed a sofware licensing and professional services
`agreement in December of 2007 for TriZetto's QNXT'"' core
`administrative enterprise system and associated implementation,
`training and other professional services. Based in San Juan, Triple-S
`is Puerto Rico's largest managed care health plan, seving
`approximately 1 million members.
`
`April - TriZetto agrees to be taken private by Apax Partners. Apax
`Partners is a growth-focused, global private equity firm with $35
`billion in funds under advice and significant expertise in healthcare
`and technology. Valued at approximately $1.4 billion, the
`transaction is funded in part by BlueCross BlueShield of Tennessee
`and The Regence Group, both customers of TriZetto.
`
`TriZetto reports diluted eanings per share for the first quarter of
`2008 of $0.09 on revenue of $106.8 million. The company reports
`record new contract bookings of $236.4 million and record net cash
`provided by operating activities of $37.4 million, which grew 52%
`over the prior year quarter.
`
`May - TriZetto announces a five-year agreement to host its QNXT''
`core administration system for Health Alliance Medical Plans, a
`managed care organization providing coverage for 250,000 people
`in Illinois and Iowa.
`
`TriZetto announces a five-year, non-exclusive, revenue-sharing
`agreement under which Unisys Nederland NV will market, distribute
`and maintain TriZetto software to health Insurers in The
`Netherlands. Although TriZetto serves intenational clients, this
`marks the company's first overseas channel partner agreement,
`providing the company a vehicle for broader acess to this market.
`
`June - TriZetto announces an agreement with Microsoft Corp which
`TriZetto will develop a connector for its payer customers that
`enables members of health plans to use TriZetto's Member Benefit
`ProfileT' application with Microsoft HealthVauJtT"'.
`
`TriZetto announces that the Universal American Corporation (NYSE:
`UAM) health plan is implementing TriZetto's CareAdvance
`MedicareT"' software module.
`
`http:l/www.triecto.com/company/corporatHistory.asp (2 of 9) [11-8·2011 14:57:28]
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`

`
`Results of the 2008 IHM Survey by TriZetto show that patients,
`doctors and other healthcare constituents agree hat more shared
`information and aligned incentive programs are key to helping solve
`the healthcare affordability crisis and that health plans are best
`positioned to coordinate these improvements.
`
`TriZetto announces two new customers for the company's real-time
`patient liability and point-of-service claims adjudication software,
`Provider POS Direct'M. Blue Cross and Blue Shield of ns City
`(BCBSKC) and Blue Cross and Blue Shield of Rhode Island (BCBSRI)
`become the latest health plans embracing the value of real-time
`claims adjudication by selecting TriZetto's Provider POS Direct
`application. BCBSKC has nearly 900,000 members and 4,000
`network providers; BCBSRI has more than 680,000 members and
`nearly 3,900 network providers.
`
`July - TriZetto announces its selection of Eliza Corporation's phone­
`based, speech-enabled outreach programs as an integrated part of
`TriZetto's CareAdvance Enterpris® care management applicaion
`and Healthwis® Smart Campaigns.
`
`August - On August 4, 2008, TriZetto and Apax Partners
`announed the closing of the merger pursuant to which funds
`advised by Apax Partners, together with minority investors
`BlueCoss BlueShield f Tennessee and e Regence Group,
`acquired all of TriZetto's common shares for $2. The last day of
`trading of TriZetto's stock was August 4.
`
`2007
`
`January - TriZetto completes the acquisition of privately held OCSI
`(Quality Care Solutions, Inc.), combining the power of QCSI's
`QXT'M administrative engine for smaller payers with the broad
`capabilities and financial strength of TriZetto.
`
`February - Humana Inc., one of the nation's largest publicly traded
`health benefits companies, transitions the first phase of its
`commercial membership to TriZetto's Clinial CareAdvanceTM
`software. The software is one of two modules comprising
`CareAdvance Enterprise, systems that automate all aspects of care
`management, creating significant productivity improvements for
`medical management and enabling health plans to guide consumers
`in making better health decisions that can lower medical costs and
`improve health outcomes.
`
`BlueCross BlueShield of Tennessee reports good early results from
`initial launch of TriZetto's real-time patient liability and point-of­
`service claims adjudication software, Provider POS Direct'M, in two
`of five pilot provider offices. Provider POS Direct can help provide
`price transparency for patients and providers via real-time acess to
`medical benefit and procedure information in order to determine
`
`hup:/www.triztto.com/companyfcorporateHistory.asp (3 of9) [11-8-2011 14:57:28]
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`

`
`covered benefits and the exact provider reimbursement due from
`both member and health plan.
`
`March - Premera Blue Cross, seving more than 1 million members
`in Alaska and Washington, successfully goes live on TriZetto's
`Clinical CareAdVance'M software. Clinical CareAdvance integrates
`with TriZetto's Facet® administrative system, which Premera has
`used since 2001.
`
`November - TriZetto previews Integrated Healthcare Management
`(IHM) to executives representing 40 percent of the insured U.S.
`population at the company's Executive Vision Summit in Naples, Fla.
`IHM is the systematic application of processes and shared
`information to optimize the coordination of benefits and care for the
`healthcare consumer. Introduced by TriZetto, the IHM framework is
`driven by the convergence of health benefit administration, care
`management and payers' engagement of constituens - employers,
`providers, members and brokers.
`
`2006
`
`February - TriZetto announces its first full profitable year, with
`diluted eanings per share EPS) for the full year 2005 of $0.48, on
`revenue of $292.2 million. EPS performance was $0.03 better than
`the high end of the company's guidance range and represents an
`increase of 167 percent over full-year 2004 EPS.
`
`TriZetto's outstanding results for 2005 and strong expectations for
`2006 demonstrate the company's leadership position at the
`confluence of some of the most dramatic changes that the
`healthcare industry has experienced in 20 years.
`
`August - TriZetto announced that its personal health record
`technology, Personal CareAdvanc®, will be used in a six-month
`feasibility test for the Centers for Medicare and Medicaid Sevices
`(CMS). The government ran only two such tests to determine how
`best to transform CMS claims data into personal health records that
`offer value to both Medicare beneficiaries and their care providers.
`
`2005
`
`Januay - Blue Cross Blue Shield of Tennessee selects TriZetto
`aene'M Enterprise, powered by CareKey'M, as its single
`platform for automating case, disease and population management.
`
`TriZetto reports its first full profitable year, eaning $0.18 per share
`on revenue of $274.6 million in 2004. Annual new-contract bookings
`increased 45 percent over the prior year, to $335 million.
`
`March - TriZetto introduces Facets 2 CDH Suite, an integrated
`http:/www.trireuo.com/compa.nylcorporateistory.asp (4 of9) [I 1·8·201 I 14:57:28]
`
`

`
`solution that delivers the full range of capabilities necessary to cost­
`effectively implement and administer consumer-directed health
`plans.
`
`May - TriZetto announces the availability of FastTrak, which enables
`Medicare and Medicaid health plans to quickly get up and running on
`Facets 2.
`
`December- TriZetto announces it has completed the acquisition of
`privately held CareKey Inc., a leading provider of advanced care
`management software. The combination expands TriZetto's market
`opportunities and increases its customers' ability to improve the
`cost and quality of care for their members.
`
`2004
`
`Januay- The Regence Group and TriZetto announce a seven-year
`hosting agreement under which Regence will move its members to
`Faces 2. TriZetto will host Facets 2 and the HealthWeb Suite on
`behalf of Regene.
`
`February - TriZetto reports $290 million in revenue for 2003, up 9
`percent from 2002.
`
`March - John Muir/Mt. Diablo Health System becomes the fifth
`organization in the last two years to select Facets 2 to replace a
`legacy Amisys system.
`
`May - TriZetto introduces CareAdvance EnterpriserM, powered by
`CareKeyrM. This software application involves consumers more
`directly in their healthcare by enhancing and automating the entire
`care management spctrum-case, disease and population
`management.
`
`November- Kathleen Earley, an AT&T executive, joins TriZetto as
`president and chief operating officer.
`
`TriZetto announces the availability of DirectUnkrM, which provides
`secure, direct connectivity between payers' back-office systems and
`their constituents' systems.
`
`December- TriZetto's NetworxrM Suite is recognized as the "Most
`Innovative Use of Technology to Improve Claims Prcessing" at The
`Emerging Technologies and Healthcare Innovations Congress.
`
`TriZetto completes the purchase of more than 12.1 million shares of
`TriZetto common stock held by IMS Health, Inc.
`
`hup://www.trieuo.com/oompany/corporateistory.asp (5 of 9) [11·8·2011 14:57:28]
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`2003
`
`

`
`January - TriZetto announces a software license agreement with
`Blue Cross and Blue Shield of Louisiana. BCBSL is he 14th Blues
`plan to become a customer of TriZetto, which now serves one-third
`of the nation's Blue Cross and Blue Shield organizations.
`
`March - TriZetto introduces Facets Extended Enterprise- (Facets
`2"4), a major expansion of s administrative system for health
`plans. This expanded administrative system helps health plans
`anticipate industry change and improve service to consumers.
`
`September - TriZetto opens the TriZetto Solution Center, a live
`representation of how TriZetto's technology and services enable
`health plan organizations to operate in an environment that is highly
`efficient and customer-centric, offering real-time connectivity and
`instant access to key information.
`
`October - Deloitte & Touche, for the second consecutive year,
`names TriZetto one of the 500 fastest-growing technology
`companies in the United States.
`
`November- TriZetto introduces NetworXModeler'M, a software
`application that predicts the financial impact of new or revised
`provider contracts.
`
`Deember- TriZetto announces the availability of the Facets 2
`Worklow application, which automates manual processes and
`streamlines workflows.
`
`2002
`
`January - TriZetto announces a $32 million, six-year
`comprehensive outsourcing agreement with M-Pian, an HMO based
`in Indianapolis.
`
`Februay- TriZetto announces revenue of $218 million for 2001,
`up 145 percent from 2000 revenue. Fourth quarter 2001 revenue
`was $61.6 million, up 80 percent from the $34.2 million reported in
`the fourth quarter of 2000, an increase primarily driven by organic
`growth of 49 percent.
`
`April - TriZetto achieves the milestone of its systems' being
`contracted to serve more than 1 00 million healthcare payer
`members.
`
`TriZetto announces a 28 million, five-year hosting agreement with
`the Specialized Care Services (SCS) division of UnitedHeaith Group.
`
`August - TriZetto Is named the largest application sevice provider
`
`hup://www.uizeuo.om/ompny/cooatestory.sp (6 of9) [11·8·2011 14:57:28)
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`

`
`(ASP) in the world, based on 2001 hosted software revenue, by I DC,
`a global market intelligence and advisory firm.
`
`October- TriZetto is named second-fastest growing technology
`company in Deloitte & Touche's "Fast 50" program. The five-year
`growth rate is 8,561 percent.
`
`2001
`
`Januay - TriZetto signs a first-of-its-kind agreement with the Blue
`Cross and Blue Shield Association, to enable Faces to integrate with
`the Blues' ITS system.
`
`Februay - TriZetto announces revenue of $89.1 million for 2000,
`up 171 percent from 1999 revenue. The peroentage of revenue
`derived from recurring sources reaches 69 percent in 2000, up from
`59 percent in 1999.
`
`April - TriZetto acquires INFOTRUST Company, a subsidiary of
`TRUSO Holdings.
`
`May- Analyst fim IDC ranks TriZetto as the No. 1 healthcare ASP
`and the No. 2 overall ASP woldwide.
`
`July - TriZetto announces a seven-year, $100 million ASP contract
`with Altius Health Plans of Utah. TriZetto also purchases Altius'
`service center in Salt Lake City.
`
`In its second-quarter 2001 earnings statement, TriZetto announces
`that it has achieved positive EBITDA (earnings before interest,
`taxes, depreciation and amortization), an important milestone on
`the company's path toward profitability.
`
`2000
`
`January - TriZetto acquires Health Media Enterprises (HME), a
`Petaluma, Calif.-based Internet development company.
`
`September - TriZetto acquires approximately 40 employees from
`Maxicare, the result of a seven-year, $50 million contract with the
`health plan.
`
`October- TriZetto acquires Erisco, Inc., producer of the nation's
`leading managed care application.
`
`November - Facets benchmark demonstrates scalability beyond 4
`million members.
`
`hup:/www.trizetto.com/companyicorporateHistory.asp (7 of 9) I 11-8-2011 14:57:28)
`
`

`
`December- TriZetto acquires RIMS, the nation's largest provider of
`automated claims-processing technology and services for the
`benefits administration market. TriZetto now has approximately
`1 ,500 employees and 600 customers.
`
`1999
`
`Februay- In simultaneous transactions, TriZetto acquires two
`Texas firms, Creative Business Solutions, Inc. , and HealthWe®
`Systems, Ltd.
`
`March - TriZetto acquires Management and Technology Solutions
`(MTS), of Louisville, Ky. , and integrates MTSNet - a portal product
`helping physician offices communicate with each other, health plan
`offices and hospitals - with is HealthWeb product.
`
`August - Healthcare Informatics names TriZetto one of the fastest­
`growing healthcare IT companies in the country.
`
`TriZetto files a registration statement with the Securities and
`Exchange Commission for an initial public offering (I PO).
`
`October- TriZetto's IPO raises approximately $37.5 million.
`
`November- TriZetto acquires Novalis Corp., an Albany, N.Y.-based
`provider of applications services for the healthcare industry.
`
`December - TriZetto acquires Finserv Healh Care Systems, Inc.
`Headquartered in Albany, N.Y., Finserv creates and supplies
`reimbursement-management software and services for healthcare
`providers.
`
`1998
`
`March - Company name is changed to The TrlZetto Group, Inc.
`
`TriZetto raises $8.5 million in private funding, increases its
`workforce 72 percent and experienes a 353-percent increase in
`revenues.
`
`1997
`
`May- TriZett® is incorporated in Delaware as M C Health
`Holdings, Inc.
`
`October - Shares f common stock of M C Health Holdings are
`exchanged for all equity interests in Croghan & Associates, Inc., a
`
`btp://www.itto.com/ompny/rpolitory.sp (8 of 9) [1 1-8-201 1 14:57:28]
`
`

`
`Exhibit B
`
`Opposer's third set of requests for admission to Applicant, opposition
`number 91184047
`AOUH15AA
`
`

`
`ATRIZETTO
`
`I Home
`
`I C
`
`_I Power Star Awa
`
`is Powering Integrated Healthcare Managemen®. With technology
`touching more than half the U.S. population today, TriZetto is uniquely
`nn.oTonnoAn to drive the convergence of core benefit administration, care
`and constituent engagement. TriZetto provides premier information
`ogy solutions hat enable payers and other constituents in the healthcare
`chain to improve the coordination of benefits and care for healthcare
`
`provides core administration solutions, care and network management
`and a wide range of constituent Web solutions. Comprehensive solutions
`M>nu�t·A Advantage and managed Medicaid plans also are available, along with
`business and professional services.
`
`htp:l/www.izeto.com/compny/corporteprofle.sp (I of 2) [ 1 1-8-20 1 1 15:02:41]
`
`

`
`ore Benefit Administration
`Tri7ottn'c industry-leading core administration solutions are flexible,
`""n"'"ensive, integrated platforms that support multiple lines of business,
`consume-directed health plans. Solutions include Facet®, QNXT'M and
`systems. Facets delivers advanced functionality and technology for
`payers, with capabilities that address enterprise-wide business and e-
`needs. The QNXT system delivers a poweful administrative engine wih
`ar�hit.�tural flexibility for healthcare payers. The QicUnk platform for TPAs delivers
`""'m.ron>nciiv> functionality and improved efficiency.
`
`and Network Management
`CareAdvance Enterpris® application automates and streamlines the full
`sn'c'""n of care management, including case, disease, utilization and population
`anagement, while the NetworXTM Suite of applications provides unmatched tools
`advanced network management, including automated pricing of claims and rapid
`m�l�li•n of provider contracts. These solutions help payers manage both the unit
`and the usage costs of funding care.
`
`nstituent Engagement
`Constituent Web Solutions help payers meet the needs of members,
`nr,vi1>r> employers and brokers, and address the emerging consumer retail
`Member solutions include tools for benefit modeling, enrollment, self­
`personal health management, treatment navigation, and benefit and fund
`Provider solutions include capabilities for self-service, access to patient
`calculation of real-time, accurate patient out-of-pocket costs and claims
`... : • -.:-- Employer and Broker solutions include tools for self-service,
`ment and billing.
`
`provides business and professional services that enable payers to
`rate he achievement of key business objectives. Through Application Hosting
`TriZetto can host and manage customer applications from a state-of-the­
`. _,,,_ .. _ data center or remotely manage the applications that reside within
`,tnr,A>' premises. TriZetto Business Process Outsourcing (BPO) Services allow
`to improve strategic focus and outsource non-critical functions,
`claims administration, enrollment and premium billing, and business rules
`TriZetto's Professional Services team offers solutions that service
`from end-to-end. Services include product consulting, business
`program and project management, training and certification, technology
`and customer-specific solutions.
`
`Information
`
`For more detailed information, please call 1-800-569-1222.
`
`About TriZetto Healthare Solutions Healthcae Servies Privay Poliy Terms and Conditions
`© 2000-2011 The TriZeto Group, Inc. All rights reserved.
`
`bnp://www.triwto.co/compny/corporateprolc.sp (2 of2) [11-8-2011 15:02:41)
`
`

`
`Exhibit C
`
`Opposer's third set of requests for admission to Applicant, opposition
`number 91184047
`A01Hl5AA
`
`

`
`TRIZETTO.
`
`I Home
`
`I C
`
`meet today's challenges and those that lie ahead, every healthcare organization
`a powerful software engine - one that automates business processes,
`Anh�n.A� efficiency and provides the flexibility to administer diverse plan designs,
`nt'""t"' with third party solutions, and adapt to the rapidly changing business and
`environment.
`
`has the right enterprise software to help you meet these challenges -
`, and with less risk and greater return on investment. Our core administration
`utions include:
`
`is an enterprise-wide core administration solution for all commercial,
`special�{. consumer-directed, Managed Medicaid and Medicare Advantage
`organizations. A