Case 2:21-cv-00072-JRG-RSP Document 122-2 Filed 08/13/21 Page 1 of 8 PageID #: 2961
`Case 2:21-cv-00072-JRG-RSP Document 122-2 Filed 08/13/21 Page 1 of 8 PagelD #: 2961
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`EXHIBIT B
`EXHIBIT B
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`Case 2:21-cv-00072-JRG-RSP Document 122-2 Filed 08/13/21 Page 1 of 8 PagelD #: 2961
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`EXHIBIT B
`EXHIBIT B
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`Case 2:21-cv-00072-JRG-RSP Document 122-2 Filed 08/13/21 Page 2 of 8 PageID #: 2962
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`AGIS SOFTWARE DEVELOPMENT LLC,
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`Plaintiff,
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`v.
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`T-MOBILE USA, INC. and T-MOBILE US,
`INC.,
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`Defendants.
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`§
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`§
`Case No. 2:21-cv-00072-JRG
`§
`(LEAD CASE)
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`JURY TRIAL DEMANDED
`§
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`Case No. 2:21-cv-00029-JRG
`(MEMBER CASE)
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`JURY TRIAL DEMANDED
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`AGIS SOFTWARE DEVELOPMENT LLC,
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`Plaintiff,
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`v.
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`WHATSAPP, INC.,
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`Defendant.
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`PLAINTIFFS’ SECOND SET OF INTERROGATORIES
`TO DEFENDANT WHATSAPP, LLC (NOS. 10-13)
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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” or “Plaintiff”) hereby requests
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`that Defendant WhatsApp, LLC (“WhatsApp” or “Defendant”) respond to the following
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`Interrogatories in writing, under oath, and in accordance with the following definitions and
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`instructions, within thirty (30) days of the date of service thereof. These Interrogatories are
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`continuing in nature and require supplementation in accordance with the Federal Rules of Civil
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`Procedure.
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`Case 2:21-cv-00072-JRG-RSP Document 122-2 Filed 08/13/21 Page 3 of 8 PageID #: 2963
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`DEFINITIONS
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`The Definitions and Instructions from Plaintiff’s First Set of Interrogatories to Defendant
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`WhatsApp, LLC (Nos. 1-9), served June 9, 2021, are incorporated herein by reference as if fully
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`set forth in their entireties.
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`INTERROGATORY NO. 10
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`INTERROGATORIES
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`Identify all physical property, offices, facilities, coworking spaces, warehouses, tangible
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`and intangible property, equipment, servers, data centers, and other physical locations located
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`within all counties of the Eastern District of Texas and all counties adjacent to the Eastern District
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`of Texas, that are leased, owned, or otherwise used by WhatsApp, any affiliate of WhatsApp, or
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`any employees, consultants, or personnel of WhatsApp or any affiliate of WhatsApp. This request
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`is limited to any lease or ownership in effect at any time during the period of 2017 to present or
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`any use occurring at any time during the period of 2017 to present.
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`RESPONSE TO INTERROGATORY NO. 10
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`2
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`Case 2:21-cv-00072-JRG-RSP Document 122-2 Filed 08/13/21 Page 4 of 8 PageID #: 2964
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`INTERROGATORY NO. 11
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`Identify and produce all past and present agreements, leases, contracts, and any legal rights
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`for all physical property, offices, facilities, coworking spaces, warehouses, tangible and intangible
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`property, equipment, servers, data centers, other physical locations, communications services,
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`utility services, and all vendor services located or performed within all counties of the Eastern
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`District of Texas and all counties adjacent to the Eastern District of Texas. This request is limited
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`to agreements, leases, contracts, and legal rights effective at any time during the period of 2017 to
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`present.
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`RESPONSE TO INTERROGATORY NO. 11
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`3
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`Case 2:21-cv-00072-JRG-RSP Document 122-2 Filed 08/13/21 Page 5 of 8 PageID #: 2965
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`INTERROGATORY NO. 12
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`Identify all past and present employees, officers, directors, contractors, vendors, agents,
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`and third parties of WhatsApp and its affiliates including, but not limited to, all Person(s) that
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`reside in or work in any county of the Eastern District of Texas and any county adjacent to the
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`Eastern District of Texas. This request is limited to the time period of 2017 to present.
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`RESPONSE TO INTERROGATORY NO. 12
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`4
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`Case 2:21-cv-00072-JRG-RSP Document 122-2 Filed 08/13/21 Page 6 of 8 PageID #: 2966
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`INTERROGATORY NO. 13
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`Identify and describe, in detail, all past and present business, services, transactions, and
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`work conducted and performed in any county of the Eastern District of Texas and any county
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`adjacent to the Eastern District of Texas by or on behalf of WhatsApp and its affiliates. This
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`request is limited to the time period of 2017 to present.
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`RESPONSE TO INTERROGATORY NO. 13
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`5
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`Case 2:21-cv-00072-JRG-RSP Document 122-2 Filed 08/13/21 Page 7 of 8 PageID #: 2967
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`Dated: August 13, 2021
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`FABRICANT LLP
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`
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`/s/ Vincent J. Rubino, III
`Alfred R. Fabricant
`NY Bar No. 2219392
`Email: afabricant@fabricantllp.com
`Peter Lambrianakos
`NY Bar No. 2894392
`Email: plambrianakos@fabricantllp.com
`Vincent J. Rubino, III
`NY Bar No. 4557435
`Email: vrubino@fabricantllp.com
`Enrique W. Iturralde
`NY Bar No. 5526280
`Email: eiturralde@fabricantllp.com
`FABRICANT LLP
`411 Theodore Fremd Avenue,
` Suite 206 South
`Rye, New York 10580
`Telephone: 212-257-5797
`Facsimile: 212-257-5796
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`Samuel F. Baxter
`Texas State Bar No. 01938000
`Email: sbaxter@mckoolsmith.com
`Jennifer L. Truelove
`Texas State Bar No. 24012906
`Email: jtruelove@mckoolsmith.com
`McKOOL SMITH, P.C.
`104 East Houston Street, Suite 300
`Marshall, Texas 75670
`Telephone: 903-923-9000
`Facsimile: 903-923-9099
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`ATTORNEYS FOR PLAINTIFF, AGIS
`SOFTWARE DEVELOPMENT LLC
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`Case 2:21-cv-00072-JRG-RSP Document 122-2 Filed 08/13/21 Page 8 of 8 PageID #: 2968
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that on August 13, 2021, a true and correct copy of the
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`above and foregoing document has been served on all counsel of record by email.
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`/s/ Vincent J. Rubino, III
` Vincent J. Rubino, III
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