Case 2:21-cv-00040-JRG Document 88-2 Filed 09/30/21 Page 1 of 4 PageID #: 2087
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`Exhibit A
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`Exhibit A
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`Case 2:21-cv-00040-JRG Document 88-2 Filed 09/30/21 Page 2 of 4 PageID #: 2088
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`processors or systems-on chips that are part of the Accused Products.
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`18.
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`The term “Gesture” means movement, position, or state of a body part, including,
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`but not limited to, the whole body, any part thereof, and facial expressions.
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`19.
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`The term “Applications” means any software application that runs on the Accused
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`Products that uses one or more Components for determining Gestures for use by the Application,
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`including, but not limited to, user applications, application programming interfaces (API),
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`firmware, drivers, operating-system components, and the like.
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`20.
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`The term “Relevant Time Period” means the time period beginning with six years
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`before the filing of the Complaint in this case through the expiration of the Patents-in-Suit. The
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`term “Relevant Time Period” in no way limits or modifies any period of time that is otherwise
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`expressly stated or identified in any request herein.
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`21.
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`All terms used herein that are capitalized, either initially or in their entireties, shall
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`be construed as if they appeared in lower case letters, as may be necessary to bring within the
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`scope of these Interrogatories all responses that might otherwise be construed to be outside its
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`scope.
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`22.
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`The terms “all” and “each” shall be construed either disjunctively or conjunctively
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`as necessary to bring within the scope of the discovery request all responses that might otherwise
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`be construed to be outside of its scope.
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`23.
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`The connectives “and” and “or” shall be construed either disjunctively or
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`conjunctively as necessary to bring within the scope of the document request all productions that
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`might otherwise be construed to be outside of its scope.
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`24.
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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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`The term “person” or “entity” refers to natural persons, groups of natural persons,
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`5
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`Case 2:21-cv-00040-JRG Document 88-2 Filed 09/30/21 Page 3 of 4 PageID #: 2089
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`DEPOSITION TOPICS
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`1. The identity and description of each mobile device, handheld device, mobile phone,
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`cellular phone, smartphone, or tablet (“Devices”) and Accused Product made, created, configured,
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`acquired, put into service, used, offered for sale, or sold, within the United States, or imported into
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`the United States by or for Defendant during the Relevant Time Period, including, for each
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`Accused Product and Device:
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`(a)
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`name;
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`(b) model number and product code;
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`(c)
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`(d)
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`(e)
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`(f)
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`wireless carrier (if applicable);
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`all internal names, code names and designations;
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`initial operating system version;
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`any chipset(s) responsible for the detection, identification, or interpretation of
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`Gestures;
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`(g)
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`date first sold or offered for sale in the United States.
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`2. The identity and description of the Components for each Accused Product and each Device
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`that are responsive to Topic No. 1.
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`3. The identity and description of every Application, that can detect, process, interpret,
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`respond to, or be controlled by Gestures, that is (1) preloaded on the Accused Products and/or
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`Devices or (2) available for download on the Accused Products or Devices that are responsive to
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`Topic No. 1, including for each Application:
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`(a)
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`(b)
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`the name of the Application;
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`whether the Application was preloaded on the Accused Products and/or Devices or
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`available for download on the Accused Products or Devices;
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`-8-
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`Case 2:21-cv-00040-JRG Document 88-2 Filed 09/30/21 Page 4 of 4 PageID #: 2090
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`(c)
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`the Accused Products and/or Devices for which the Application was preloaded or
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`available for download;
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`(d)
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`the Gestures that the Application can detect, process, interpret, respond to, or use
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`for control; and
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`(e)
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`the function(s) of the Application that are controlled by Gesture(s).
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`4. The design and manufacturing of the Accused Products and the Devices that are responsive
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`to Topic No. 1.
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`5. The algorithms used in the Accused Products and Devices responsive to Topic No. 1 to
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`detect, process, interpret, respond to, or be controlled by Gestures.
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`6. The use of a Light Source in the Accused Products and Devices responsive to Topic No. 1
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`to detect, process, interpret, respond to, or be controlled by Gestures.
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`7. Your decision to include the capability to detect, process, interpret, respond to, or be
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`controlled by Gestures in the Accused Products and Devices responsive to Topic No. 1.
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`8. The complete process for designing, developing, and manufacturing the Accused Products
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`and the Devices that are responsive to Topic No. 1.
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`9. The complete process for designing, selecting, developing, and/or implementing
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`Components on the Accused Products and the Devices that are responsive to Topic No. 1.
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`10. The complete process for designing and developing the Applications that are responsive to
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`Topic No. 3.
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`11. On a monthly basis for the Relevant Time Period, the identity and description all of Your
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`revenue and expenditures associated with the Accused Products and the Devices that are
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`responsive to Topic No. 1, including, but not limited to:
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`(a)
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`quantity sold;
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`-9-
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