Case 2:17-cv-00514-JRG Document 219-14 Filed 02/21/19 Page 1 of 23 PageID #: 19124
`Case 2:17-cv-00514—JRG Document 219-14 Filed 02/21/19 Page 1 of 23 PageID #: 19124
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`EXHIBIT 13
`EXHIBIT 13
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`Case 2:17-cv-00514-JRG Document 219-14 Filed 02/21/19 Page 2 of 23 PageID #: 19125
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`AGIS SOFTWARE DEVELOPMENT, LLC,
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`Plaintiff,
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`
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`v.
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`HUAWEI DEVICE USA INC., ET AL.,
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`Defendants.
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`AGIS SOFTWARE DEVELOPMENT LLC,
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`Plaintiff,
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`v.
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`LG ELECTRONICS, INC.,
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`Defendant.
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`Case No. 2:17-cv-513-JRG
`(LEAD CASE)
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`JURY TRIAL DEMANDED
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`Case No. 2:17-cv-515-JRG
`(CONSOLIDATED CASE)
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`JURY TRIAL DEMANDED
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`§
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`PLAINTIFFS’ FIRST SET OF INTERROGATORIES
`TO LG ELECTRONICS, INC. (NOS. 1-10)
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`PLEASE TAKE NOTICE that, pursuant to Rules 26 and 33 of the Federal Rules of Civil
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`Procedure, Plaintiff AGIS Software Development LLC (“AGIS”) hereby requests that Defendant
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`LG Electronics Inc. (“LG”) respond to the following Interrogatories in writing, under oath, and
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`in accordance with the following definitions and instructions, within thirty (30) days of the date
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`of service thereof. These Interrogatories are continuing in nature and require supplementation in
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`accordance with the Federal Rules of Civil Procedure.
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`Case 2:17-cv-00514-JRG Document 219-14 Filed 02/21/19 Page 3 of 23 PageID #: 19126
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`DEFINITIONS
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`1.
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`“AGIS,” “AGIS Software” and “Plaintiff” shall mean Plaintiff, AGIS Software
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`Development LLC.
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`2.
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`“LG,” “Defendant,” “You,” and “Your” shall mean Defendant, LG Electronics,
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`Inc., including without limitation all predecessors-in-interest, successors in-interest, parents,
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`subsidiaries, affiliates, and all past or present officers, directors, trustees, employees, agents,
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`consultants, attorneys, patent agents, entities acting in joint venture, licensing or partnership
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`relationships with any of the defendants in any country.
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`3.
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`“LG Accused Products” means any and all products made, used, sold, offered for
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`sale, or imported into the United States by LG––and entities controlled by LG, under the
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`instruction of LG, or doing business with LG for the purposes of making, using, selling, offering
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`for sale, or importing any and all such products into the United States––that incorporate
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`technology as defined and alleged in AGIS’s complaints, infringement contentions, initial
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`disclosures, and expert reports. Any products or devices accused of infringing any patent later
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`asserted by Plaintiff in this Action will also be included in the definition of “LG Accused
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`Products.” “LG Accused Products” include each of the instrumentalities identified in AGIS’s
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`Preliminary Infringement Contentions including but are not limited to: V30 (H931, LS998U,
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`H932, H932U, VS996, US998, AS998), X charge (US601, SP320, M327, M322), Q6 (US700),
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`G6+ (US997U), G6 (US997, VS988, AS993, H871, H872, LS993), Fiesta 2 (L173BL, L164VL),
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`V20 (LS997, H910, H918, US996, VS995), X venture (US701, H700), Stylo 3 (LS777), Stylo 3
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`Plus (MP450, TP450), Tribute HD (LS676), Rebel 2 (L57BL, L58BL, L58VL), Fiesta LTE
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`(L63BL, L64VL), Stylo 3 LTE (L83BL, L84VL), K20 plus (MP260, TP260), Grace LTE
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`(L59BL), K3 (AS110, US110, LS450), Stylo 3 (LS777, M430), Phoenix 3 (M150), Risio 2
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`2
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`Case 2:17-cv-00514-JRG Document 219-14 Filed 02/21/19 Page 4 of 23 PageID #: 19127
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`(M154), K8 2017 (US215), Stylo 2 V (VS835), K20 (M255, RS501), K20 V (VS501), Aristo
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`(M210), Harmony (M257), G5 (VS987, AS992, H820, H830, LS992, RS988, US992), Aristo
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`Silver (MS210), Aristo Cobalt Blue (MS210UK), Stylo 2 Plus (MS550BK, K550), Fortune
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`(M153), Tribute HD (LS676), X power (K212, K450, LS755, US610), K10 (MS428, K425,
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`K428SG), Stylo 2 (LS775, K540), G Vista (VS880), Escape 3 (K373), Classic (L18VC), Rebel
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`LTE (L43AL, L44VL), Treasure LTE (L51AL, L52VL), Premier LTE (L61AL, L62VL), Stylo 2
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`LTE (L82VL), K7 (MS330, AS375, K330), K8 (RS500, US375), G4 (US991), K4 (VS425),
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`Optimus Zone 3 (VS425PP), K8 V (VS500, VS500PP), Phoenix 2 (K371), Tribute 5 (LS675),
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`Spree (K120), G Vista 2 (H740), Escape 2 (H443), Risio (H343), Access LTE (L31L), Leon
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`LTE (H345, MS345), G Stylo (H631, MS631, H634, LS770), Volt 2 (LS751), Tribute 2
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`(LS665), Escape 2 (H445), Logos (US550), Transpyre (VS810PP), G3 (D850, LS990, D851,
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`AS985, VS985, AS990, US990), Ultimate 2 (L41C), Tribute (LS660), G3 Vigor (D725), Realm
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`(LS620), G Vista (D631), Volt (LS740), Optimus Fuel (L34C), Optimus L90 (D415), Optimus
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`F3Q (D520), D820 (D820), G2 (VS9801, D800, D801, LS980), Optimus F6 (D500), Enact
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`(VS890), Optimus F3 (VM720, LS720), Rumor Reflex S (LN272S), Optimus F7 (LG870,
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`US780), Optimus F5 (AS870), Optimus G Pro (E980), Lucid2 (VS870), Spirit 3G (MS870),
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`LGE960 (LGE960), Optimus REGARD (LW770), Mach (LS860), Optimus G (LS970, E970),
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`Optimus L9 (P769), Venice (LG730), Escape (P870), Spectrum 2 (VS930), Splendor (US730),
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`Intuition (VS950), Motion 4 (MS770), Optimus Plus (AS695), Elite (LS696), Viper (LS840),
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`Optimus M+ (MS695), Lucid (VS840), Nitro (P930), Spectrum (VS920), Marquee (LG855),
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`Connect 4G(MS830), Optimus Q (LGL55C), Optimus 2 (AS680), Ignite (AS855), myTouch Q
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`(LGC800DG, LGC800VL), Optimus One (P504), myTouch (LGE739BK), DoublePlay (C729),
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`Optimus Slider (VM701), Esteem (MS910), Enlighten (VS700), Marquee (LS855), Thrill 4G
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`3
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`Case 2:17-cv-00514-JRG Document 219-14 Filed 02/21/19 Page 5 of 23 PageID #: 19128
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`(P925), Revolution (VS910), Genesis (US760), G2x (P999), Thrive (P506), Phoenix (P505),
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`Optimus C (LW690), Optimus V (WM670), Optimus U (US670), Optimus M (MS690), Axis
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`(LGAS740), Apex (US740), Vortex (VS660), Optimus S (LS670), Ally (VS740), and Optimus T
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`(P509), and any variants of the listed models thereof.
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`4.
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`“This Action” means AGIS Software Development LLC v. LG Electronics, Inc.,
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`2:17-cv-00515-JRG (E.D. Tex.) which was consolidated into lead case AGIS Software
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`Development LLC v. Huawei Device USA Inc., et al., 2:17-cv-00513-JRG (E.D. Tex.).
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`5.
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`“’970 Patent” means U.S. Patent No. 8,213,970, entitled “Method of Utilizing
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`Forced Alerts for Interactive Remote Communications.”
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`6.
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`“’055 Patent” means U.S. Patent No. 9,408,055, entitled “Method to Provide Ad
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`Hoc and Password Protected Digital and Voice Networks.”
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`7.
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`“’251 Patent” means U.S. Patent No. 9,445,251, entitled “Method to Provide Ad
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`Hoc and Password Protected Digital and Voice Networks.”
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`8.
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`“’838 Patent” means U.S. Patent No. 9,467,838, entitled “Method to Provide Ad
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`Hoc and Password Protected Digital and Voice Networks.”
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`9.
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`“Asserted Patents” means the ’970 Patent, the ’055 Patent, the ’251 Patent, and
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`the ’838 Patent.
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`10.
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`“Related Patent Application” means any patent application or issued patent
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`having a relation by continuation application, continuation-in-part application, and/or divisional
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`application, as defined by the Manual of Patent Examining Procedure (Ninth Edition, Revision
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`07.2015) §§ 201.06–08, with respect to the Asserted Patents. “Related Patent Application”
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`means any international application and/or foreign counterpart of the Asserted Patents. “Related
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`4
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`Case 2:17-cv-00514-JRG Document 219-14 Filed 02/21/19 Page 6 of 23 PageID #: 19129
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`Patent Application” includes any patent application or issued patent within a chain of co-
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`pendency with respect to any of the Asserted Patents.
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`11.
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`“Document(s)” shall have the broadest meaning ascribed to it by Federal Rule of
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`Civil Procedure 34 and Federal Rule of Evidence 1001, and shall include within its meaning any
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`and all papers, videotapes or video recordings, photographs, films, recordings, memoranda,
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`books, records, accounts, letters, telegrams, correspondence, notes of meetings, notes of
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`conversations, notes of telephone calls, inter-office memoranda or written communications of
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`any nature, recordings of conversations either in writing or by means of any mechanical or
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`electrical recording device, notes, papers, reports, analyses, invoices, canceled checks or check
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`stubs, receipts, minutes of meetings, time sheets, diaries, desk calendars, ledgers, schedules,
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`licenses, financial statements, telephone bills, logs and any differing versions of the foregoing
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`whether denominated formal, informal or otherwise, as well as copies of the foregoing which
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`differ in any way, including handwritten notations or other written or printed matter of any
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`nature, from the original. The foregoing specifically includes the information stored in any form,
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`including electronic form, on a computer or in a computer database or otherwise, including
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`electronic mail. Moreover, the term “document” shall also include all “technical documents,”
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`such as source code, specifications, schematics, flow charts, artwork, drawing, pictures, pictorial
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`representations, formulas, troubleshooting guides, service bulletins, technical bulletins,
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`production specification sheets, white papers, operator manuals, operation manuals and
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`instruction manuals.
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`12.
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`“Communication(s)” shall mean, including its usual and customary meaning, any
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`transmission, conveyance or exchange of a word, statement, fact, thing, idea, document,
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`5
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`Case 2:17-cv-00514-JRG Document 219-14 Filed 02/21/19 Page 7 of 23 PageID #: 19130
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`instruction, information, demand or question by any medium, whether by written, oral or other
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`means, including, but not limited to, electronic communications and electronic mail.
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`13.
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`“Thing(s)” refers to any physical specimen or tangible item, including research
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`and development models, samples, prototypes and the like.
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`14.
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`“Person(s)” refers to all natural persons and all types and kinds of business or
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`other entities, including, but not limited to, corporations, limited liability companies,
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`partnerships, joint ventures, associations, sole proprietorships, government bodies and
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`government agencies. Any reference to an individual person, either singularly or as part of a
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`defined group, includes that person’s employees, agents, legal and non-legal representatives,
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`heirs, successors, assigns and any other person or entity acting on the behalf of such individual
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`person. Any reference to a corporation or any other entity also refers to and includes any and all
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`parents, subsidiaries, predecessors, successors, affiliates, partners, joint venturers, agents,
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`employees, representatives, accountants, investment bankers, consultants or attorneys acting on
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`behalf of the corporation or other entity. The masculine includes the feminine and vice versa; the
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`singular includes the plural and vice versa.
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`15.
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`“Patent Laws” shall refer to Title 35 of the United States Code.
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`16.
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`“Infringe” or any variation thereof, including “infringing,” “infringement” and
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`“infringer” shall refer to the commission of any act constituting infringement under the Patent
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`Laws, including but not limited to 35 U.S.C. § 271 and “infringement” mean direct infringement,
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`contributory infringement, infringement by inducement, literal infringement, and infringement
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`by the doctrine of equivalents.
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`6
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`Case 2:17-cv-00514-JRG Document 219-14 Filed 02/21/19 Page 8 of 23 PageID #: 19131
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`17.
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`“Entity” or “Entities” means, including without limitation, corporation, company,
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`firm, partnership, joint venture, association, governmental body or agency, or persons other than
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`a natural person.
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`18.
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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, patents, physical devices, prototypes, uses, sales, and
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`offers for sale, and any documents or other items evidencing any of the foregoing.
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`19.
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`“Identify” shall mean to state the following: (1) when referring to a person, the
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`person’s full name, present or last known address, and the last known title and place of
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`employment; (2) when referring to a business, legal, or governmental entity or association, the
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`name of the entity or association, and the address of its main office; (3) when referring to a fact,
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`the fact and the identity of the documentary or testimonial support for that fact; (4) when
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`referring to a product or thing, the title or model name/number, any code name, project name or
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`other name by which it has been referred, and a general description of the product or thing; (5)
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`when referring to a written communication, the identity of the document(s) in which the
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`communication was made; (6) when referring to an oral communication, the identity of all
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`persons participating in the communication; (7) when referring to non-patent documents, the
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`Bates number, type of document, its general nature and subject matter, date of creation, and all
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`author(s), addressee(s) and recipient(s); and (8) when referring to patent documents, the country,
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`patent and/or application number, dates of filing, publication and grant, and the names of the
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`patentees or applicants.
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`20.
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`“Describe” shall mean, in addition to its usual and customary meaning, to identify
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`all persons with knowledge of the information sought in the interrogatory and to identify all
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`documents referring, regarding or relating to the information sought in the interrogatory.
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`7
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`Case 2:17-cv-00514-JRG Document 219-14 Filed 02/21/19 Page 9 of 23 PageID #: 19132
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`21.
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`The terms “relate to,” “reflecting,” “relating to,” or “concerning” or any variations
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`thereof, shall mean relating to, referring to, concerning, mentioning, reflecting, regarding,
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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), or are between (as
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`in the context of communications), as the context makes appropriate.
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`22.
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`“And” and “or” shall be construed either disjunctively or conjunctively as
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`necessary to bring within the scope of each interrogatory all responses that might otherwise be
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`construed outside the scope.
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`23.
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`“Any” shall include “all” and “All” shall include “any.”
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`24.
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`The term “including” shall mean including without limitation.
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`25.
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`The use of the singular form of any word includes the plural and vice versa.
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`26.
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`The use of any tense of any word includes all other tenses.
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`27.
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`Definitions or usages of words or phrases in these interrogatories are not intended
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`to be, and shall not be, construed as admissions as to the meaning of words or phrases at issue in
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`the action, and shall have no binding effect on Plaintiff in this or in any other proceeding.
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`28.
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`All interrogatories are for discovery purposes only, and are not to be construed as
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`limiting or reflecting Plaintiff’s positions in this case regarding claim construction.
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`INSTRUCTIONS
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`The following instructions shall apply to each of the Interrogatories herein:
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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 any of your attorneys, directors,
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`officers, agents, employees, representatives, associates, investigators or division affiliates,
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`8
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`Case 2:17-cv-00514-JRG Document 219-14 Filed 02/21/19 Page 10 of 23 PageID #: 19133
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`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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`2.
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`If you cannot fully respond to the following Interrogatories after exercising due
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`diligence to secure the information requested thereby, so state, and specify the portion of each
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`Interrogatory that cannot be responded to fully and completely.
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`3.
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` If any documents referred to in your response to the following Interrogatories
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`were, but are no longer are, in your possession, custody, or control, state what disposition was
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`made of them and when. If any documents referred-to in response to the following
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`Interrogatories have been lost or destroyed, describe in detail the circumstances of such loss or
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`destruction, identify each lost or destroyed document (and all files that contained such
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`documents), and describe in detail any efforts you have taken to recover such documents.
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`4.
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`If you are producing documents in connection with these Interrogatories,
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`electronic records and computerized information must be produced in an intelligible format,
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`together with a description of the system from which they were derived sufficient to permit
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`rendering the records and information intelligible.
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`5.
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`If you are producing documents in connection with these Interrogatories, selection
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`of documents from the files and other sources and the numbering of such documents shall be
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`performed in such a manner as to ensure that the source of each document may be determined, if
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`necessary.
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`6.
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`If you are producing documents in connection with these Interrogatories, file
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`folders with tabs or labels or directories of files identifying documents must be produced intact
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`with such documents.
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`9
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`Case 2:17-cv-00514-JRG Document 219-14 Filed 02/21/19 Page 11 of 23 PageID #: 19134
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`7.
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`If you are producing documents in connection with these Interrogatories,
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`documents attached to each other shall not be separated. All documents that respond, in whole or
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`in part, to any portion of any request shall be produced in their entirety, including all attachments
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`and enclosures.
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`8.
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`If you respond to any of the following Interrogatories as authorized by Fed. R.
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`Civ. P. 33(d), for each such Interrogatory and subpart thereof, specify the production numbers
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`(i.e., Bates numbers) of the specific document or group of documents accompanying your
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`response.
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`9.
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`Separately with respect to each piece of information called for by these
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`Interrogatories which is withheld under a claim of privilege or otherwise, provide an explanation
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`of the claim being asserted and a description of the information withheld in accordance with Fed.
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`R. Civ. P. 26(b)(5).
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`10.
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`If your response to a particular Interrogatory is a statement that you lack the
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`ability to provide a response to that Interrogatory, you must specify whether the inability to
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`provide a response is because the particular item or category of information never existed, has
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`been destroyed, has been lost, misplaced, or stolen, or has never been, or is no longer, in your
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`possession, custody, or control, in which case the name and address of any person or entity
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`known or believed by you to have possession, custody, or control of that information or category
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`of information must be identified.
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`11.
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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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`10
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`Case 2:17-cv-00514-JRG Document 219-14 Filed 02/21/19 Page 12 of 23 PageID #: 19135
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`INTERROGATORY NO. 1
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`INTERROGATORIES
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`Identify all LG Accused Products sold to customers and made available for purchase by
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`customers in the United States from January 2011 to the present, providing at least the following
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`information: (i) the internal and external name(s) and model number(s) of the LG Accused
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`Products; (ii) each Entity to whom the LG Accused Products were offered for sale or sold, and
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`(iii) the supplier of each LG Accused Product and components thereof, as well as an
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`identification of which components are supplied by each supplier.
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`RESPONSE TO INTERROGATORY NO. 1
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`11
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`Case 2:17-cv-00514-JRG Document 219-14 Filed 02/21/19 Page 13 of 23 PageID #: 19136
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`INTERROGATORY NO. 2
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`For each LG Accused Products sold to customers and made available for purchase by
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`customers in the United States from January 2011 to the present, providing at least the following
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`information: (i) the identity, including the version number, of all applications installed on the
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`Accused Product including but not limited to: Android Device Manager, Find My Device,
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`Google Latitude, Google Plus, Google Hangouts, Google Maps, Google Assistant, Google
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`Search, Google Messages, Android Messenger, Google Allo, Google Duo, GMail, and Google
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`Chrome (ii) the identify, including the version number, of each of the applications identified
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`above that are supported by the Accused Products, or that may be installed by a user of the
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`Accused Products.
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`RESPONSE TO INTERROGATORY NO. 2
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`12
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`Case 2:17-cv-00514-JRG Document 219-14 Filed 02/21/19 Page 14 of 23 PageID #: 19137
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`INTERROGATORY NO. 3
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`Identify all smartphone and tablet products sold by LG to customers and/or made
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`available for purchase by customers in the United States from January 2011 to the present that
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`include a touch screen and utilize the Android Operating System, providing at least the following
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`information: (i) the internal and external name(s) and model number(s) of the product; (ii) the
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`time of first sale of each product.
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`RESPONSE TO INTERROGATORY NO. 3
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`13
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`Case 2:17-cv-00514-JRG Document 219-14 Filed 02/21/19 Page 15 of 23 PageID #: 19138
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`INTERROGATORY NO. 4
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`For each LG Accused Product, state the total number of systems, units, or components
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`purchased or acquired from each supplier thereof, the cost of purchasing or acquiring such
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`systems, units, or components, the price associated with purchasing or acquiring such systems,
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`units, or components, and identify all documents related thereto and the three (3) persons most
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`knowledgeable of the foregoing.
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`RESPONSE TO INTERROGATORY NO. 4
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`14
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`Case 2:17-cv-00514-JRG Document 219-14 Filed 02/21/19 Page 16 of 23 PageID #: 19139
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`INTERROGATORY NO. 5
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`For each LG Accused Product, Identify: (i) each Entity involved with the design,
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`development, testing, manufacture, assembly, marketing, offer for sale, sale, distribution, and
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`importation of the LG Accused Product; (ii) a description of the functions of each Entity
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`identified in (i); (iii) each location where the design, development, testing, manufacture,
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`assembly, marketing, offer for sale, sale, distribution, and importation took place, and (iv) the
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`three Person(s) (employed by Defendants or otherwise) most knowledgeable about the design,
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`development, testing, manufacture, assembly, marketing, offer for sale, sale, distribution, and
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`importation.
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`RESPONSE TO INTERROGATORY NO. 5
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`15
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`Case 2:17-cv-00514-JRG Document 219-14 Filed 02/21/19 Page 17 of 23 PageID #: 19140
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`INTERROGATORY NO. 6
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`For each LG Accused Product, state the number of units sold, as well as (in U.S. dollars)
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`the gross revenue, net profits, profit margins, fixed and variable costs, average cost per unit and
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`transfer pricing on a quarterly basis from January 2011 to the present, and set forth all bases for
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`your response.
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`RESPONSE TO INTERROGATORY NO. 6
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`16
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`Case 2:17-cv-00514-JRG Document 219-14 Filed 02/21/19 Page 18 of 23 PageID #: 19141
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`INTERROGATORY NO. 7
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`Identify: (i) any agreements, licenses, or contracts, including attachments or exhibits to
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`those documents, relating to any LG Accused Product, and (ii) the Person(s) most
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`knowledgeable concerning any such agreements, licenses, or contracts, and attachments or
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`exhibits to those documents.
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`RESPONSE TO INTERROGATORY NO. 7
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`17
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`Case 2:17-cv-00514-JRG Document 219-14 Filed 02/21/19 Page 19 of 23 PageID #: 19142
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`INTERROGATORY NO. 8
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`Explain in detail all factual and legal bases for any contention by you that Defendants
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`have not infringed the Asserted Patents, including without limitation the identification of (i) each
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`claim element of the Asserted Patents that you allegedly do not practice; (ii) all documents,
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`circumstances, or other information that supports each contention that you do not practice a
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`claim element; (iii) the Person(s) knowledgeable with respect to any such contention; and (iv)
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`any documents, things, persons and/or witnesses that Defendants intend to rely on to support
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`such a contention.
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`RESPONSE TO INTERROGATORY NO. 8
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`18
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`Case 2:17-cv-00514-JRG Document 219-14 Filed 02/21/19 Page 20 of 23 PageID #: 19143
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`INTERROGATORY NO. 9
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`Identify the dates and circumstances under which you first became aware of the Asserted
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`Patents, the patent applications of the Asserted Patents, and any Related Patent Applications,
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`including but not limited to: (i) a description of when and how you first became aware of the
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`Asserted Patents (including awareness through reference or citation to the Asserted Patents), the
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`patent applications of the Asserted Patents, and any Related Patent Applications; (ii) an
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`identification of those Persons who first became aware of the Asserted Patents, the patent
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`applications of the Asserted Patents, and any Related Patent Applications; and (iii) a description
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`of the actions taken by Defendants in response to becoming aware of the Asserted Patents, the
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`patent applications of the Asserted Patents, and any Related Patent Applications.
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`RESPONSE TO INTERROGATORY NO. 9
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`19
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`Case 2:17-cv-00514-JRG Document 219-14 Filed 02/21/19 Page 21 of 23 PageID #: 19144
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`INTERROGATORY NO. 10
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`For each Asserted Patent, Identify and describe in detail each allegedly design-around
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`and/or non-infringing alternative that you contend can be used as an alternative to each Asserted
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`Patent, including but not limited to: (i) a description of each alleged design-around and/or non-
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`infringing alternative; (ii) a description of when and how each alleged design around and/or non-
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`infringing alternative was developed (if applicable); (iii) the identity of individuals involved in
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`developing each alleged design around and/or non-infringing alternative (if applicable),
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`including their titles and departments if they are current or former employees of Defendants;
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`(iv) dates when each alleged design around and/or non-infringing alternative was incorporated in
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`your products (if applicable); (v) costs associated with developing and implementing each
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`design-around and/or alleged non-infringing alternative; and (vi) steps and the time required to
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`develop and implement each alleged design-around and/or non-infringing alternative.
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`RESPONSE TO INTERROGATORY NO. 10
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`Case 2:17-cv-00514-JRG Document 219-14 Filed 02/21/19 Page 22 of 23 PageID #: 19145
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`
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`Dated: January 8, 2018
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`BROWN RUDNICK LLP
`
`
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`
`
`/s/ Vincent J. Rubino, III
`Alfred R. Fabricant
`NY Bar No. 2219392
`Email: afabricant@brownrudnick.com
`Lawrence C. Drucker
`NY Bar No. 22303089
`Email: ldrucker@brownrudnick.com
`Peter Lambrianakos
`NY Bar No. 2894392
`Email: plambrianakos@brownrudnick.com
`Vincent J. Rubino, III
`NY Bar No. 4557435
`Email: vrubino@brownrudnick.com
`Alessandra C. Messing
`NY Bar No. 5040019
`Email: amessing@brownrudnick.com
`John A. Rubino
`NY Bar No. 5020797
`Email: jrubino@brownrudnick.com
`Enrique W. Iturralde
`NY Bar No. 5526280
`Email: eiturralde@brownrudnick.com
`BROWN RUDNICK LLP
`7 Times Square
`New York, NY 10036
`Telephone: 212-209-4800
`Facsimile: 212-209-4801
`
`Samuel F. Baxter
`Texas State Bar No. 01938000
`sbaxter@mckoolsmith.com
`Jennifer L. Truelove
`Texas State Bar No. 24012906
`jtruelove@mckoolsmith.com
`McKOOL SMITH, P.C.
`104 East Houston Street, Suite 300
`Marshall, Texas 75670
`Telephone: 903-923-9000
`Facsimile: 903-923-9099
`
`ATTORNEYS FOR PLAINTIFF, AGIS
`SOFTWARE DEVELOPMENT LLC
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`21
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`Case 2:17-cv-00514-JRG Document 219-14 Filed 02/21/19 Page 23 of 23 PageID #: 19146
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`CERTIFICATE OF SERVICE
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`I hereby certify that on January 8, 2018, a true and correct copy of the above and
`foregoing document has been served by email on:
`
`
`Gregory Blake Thompson
`blake@themannfirm.com
`Mann Tindel & Thompson
`300 W. Main
`Henderson, TX 75652
`
`
`James Mark Mann
`mark@themannfirm.com
`Mann Tindel & Thompson
`300 W. Main
`Henderson, TX 75652
`
`
`
`
`James S Blackburn
`james.blackburn@apks.com
`Arnold & Porter
`Kay Scholer LLP
`777 South Figueroa Street, 44th Floor
`Los Angeles, CA 90017-5844
`
`Nicholas H. Lee
`nicholas.lee@aporter.com
`Arnold & Porter
`Kay Scholer LLP
`777 South Figueroa Street, 44th Floor
`Los Angeles, CA 90017
`
`Michael Anthony Berta
`michael.berta@apks.com
`Arnold & Porter
`Kay Scholer LLP
`Three Embarcadero Center, 10th Floor
`San Francisco, CA 94111-4024
`
`
`
`Attorneys for Defendant LG Electronics, Inc.
`
`
`/s/ Enrique W. Iturralde
` Enrique W. Iturralde
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