Case 2:21-cv-00072-JRG-RSP Document 221-2 Filed 11/17/21 Page 1 of 6 PageID #: 7584
`Case 2:21-cv-00072-JRG-RSP Document 221-2 Filed 11/17/21 Page 1of6PagelD #: 7584
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`EXHIBIT A
`EXHIBIT A
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`Case 2:21-cv-00072-JRG-RSP Document 221-2 Filed 11/17/21 Page 2 of 6 PageID #: 7585
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`SPECIFIC OBJECTIONS AND RESPONSES
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`INTERROGATORY NO. 11
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`Identify every AGIS or AGIS Inc. product and versions of such product that you assert
`practices the Asserted Claims, including LifeRing and ASSIST products, and, for each such
`product, state the complete basis for that assertion including, but not limited to, a claim chart
`showing how each element of each Asserted Claim is met by each AGIS or AGIS Inc. product,
`including citations to all source code in any AGIS or AGIS, Inc. product alleged to practice the
`Asserted Claims, and identify all facts, witnesses, documents, and source code in support of or
`against your assertion, including at least the three people most knowledgeable about your assertion
`that AGIS or AGIS Inc. product embody the claims.
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`RESPONSE TO INTERROGATORY NO. 11
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`AGIS incorporates by reference its General Objections as if fully set forth herein. AGIS
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`objects to this Interrogatory as overly broad, unduly burdensome, and seeking information not
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`proportional to the needs of the case. AGIS objects to this Interrogatory to the extent that it seeks
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`information protected by the attorney-client privilege, work product doctrine, and/or any other
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`applicable privilege. AGIS objects to this Interrogatory as seeking information that is properly the
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`subject of expert reports before the deadline for such disclosures. AGIS further objects to this
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`Interrogatory to the extent it calls for a legal conclusion. AGIS objects to this Interrogatory as
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`seeking information that is not relevant to the claims or defenses of any party to this action and
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`not proportional to the needs of the case. AGIS further objects to this Interrogatory as unclear,
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`vague, and ambiguous, particularly with respect to phrases “AGIS or AGIS Inc. product and
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`versions of such product,” “state the complete basis for that assertion,” and “identify all facts,
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`witnesses, documents, and source code in support of or against your assertion.” AGIS objects to
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`this Interrogatory as having multiple subparts, each counting towards Defendant’s total number of
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`Interrogatories.
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`Subject to and without waiving its General and Specific Objections, AGIS responds as
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`follows:
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`Case 2:21-cv-00072-JRG-RSP Document 221-2 Filed 11/17/21 Page 3 of 6 PageID #: 7586
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`AGIS Software Development LLC does not presently sell any commercial products.
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`AGIS Software Development LLC identifies the LifeRing and ASSIST software products,
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`both of which are made and sold by AGIS Software Development LLC’s sister company, AGIS,
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`Inc., as products that practice the claimed inventions. AGIS, Inc. is a licensee of the Asserted
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`Patents.
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`On September 2, 2021, counsel for AGIS Software Development LLC informed Defendant
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`that a first production of source code was available for inspection on a secure computer at McKool
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`Smith’s Dallas Office, 300 Crescent Court, #1500, Dallas, Texas 75201.
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`AGIS identifies, pursuant to Fed. R. Civ. P. 33(d), the source code production made
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`available in its entirety on the secure computer at McKool Smith’s Dallas Office, from which
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`information responsive to this Interrogatory may be obtained.
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`AGIS incorporates by reference, as if fully set forth herein, its Disclosure of Asserted
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`Claims and Infringement Contentions and accompanying document production, served on May
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`19, 2021. AGIS will supplement its response to this Interrogatory if necessary, once the Court
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`and/or the parties clarify the scope of the claims by virtue of the claim construction process. AGIS
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`incorporates by reference, as if fully set forth herein, its forthcoming expert report on technical
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`issues, damages, validity, and/or infringement, which will be served in accordance with the Court’s
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`Docket Control Order (Dkt. 80).
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`Discovery in this case is ongoing and AGIS continues to investigate this matter. AGIS
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`reserves the right to supplement its response to this Interrogatory to identify additional documents,
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`e.g., pursuant to Fed. R. Civ. P. 33(d).
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`Case 2:21-cv-00072-JRG-RSP Document 221-2 Filed 11/17/21 Page 4 of 6 PageID #: 7587
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`11/3/2021 SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 11:
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`AGIS incorporates by reference its General Objections as if fully set forth herein. Subject
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`to and without waiving its General and Specific Objections, AGIS responds as follows:
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`AGIS identifies the following documents as containing information responsive to this
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`Interrogatory: AGISSOFTWARE_0660161-AGISSOFTWARE_0660615.
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`Case 2:21-cv-00072-JRG-RSP Document 221-2 Filed 11/17/21 Page 5 of 6 PageID #: 7588
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`INTERROGATORY NO. 12
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`For each AGIS or AGIS Inc. Product identified in response to Interrogatory No. 11 that is
`an application on or service for a phone or other mobile device, providing at least the following
`information: (i) an identification of the name (including internal and external names) and platform
`(e.g., operating system) for each AGIS or AGIS Inc. Product; (ii) an identification of each version
`and revision (including internal and external names) of the AGIS or AGIS Inc. Products; (iii) the
`first and last dates each version and revision of the AGIS or AGIS Inc. Products was made
`available for download and/or purchase; and (iv) a detailed explanation of the timeline (including
`the first date) of testing for each version and revision (including any corresponding pre-release test
`or beta versions) of the AGIS or AGIS Inc. Products. For each AGIS or AGIS Inc. Product
`identified in response to Interrogatory No. 11 that is a server, provide at least the following
`information: (i) the internal and external name(s) and model number(s) of each AGIS or AGIS Inc.
`server; (ii) the physical location of each AGIS or AGIS Inc. server; (iii) an identification of each
`version and revision of each AGIS or AGIS Inc. application or AGIS or AGIS Inc. service used
`with or provided by each AGIS or AGIS Inc. server; (iv) the identification of each function or
`service (e.g., accounts, maps, payments) carried out by each AGIS or AGIS Inc. server; and (v) the
`identification of each Entity and/or AGIS or AGIS Inc. business unit that puts into practice each
`AGIS or AGIS Inc. server.
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`RESPONSE TO INTERROGATORY NO. 12
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`AGIS incorporates by reference its General Objections as if fully set forth herein. AGIS
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`objects to this Interrogatory as overly broad, unduly burdensome, and seeking information not
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`proportional to the needs of the case. AGIS objects to this Interrogatory to the extent that it seeks
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`information protected by the attorney-client privilege, work product doctrine, and/or any other
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`applicable privilege. AGIS objects to this Interrogatory as seeking information that is properly the
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`subject of expert reports before the deadline for such disclosures. AGIS further objects to this
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`Interrogatory to the extent it calls for a legal conclusion. AGIS objects to this Interrogatory as
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`seeking information that is not relevant to the claims or defenses of any party to this action, and
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`not proportional to the needs of the case. AGIS further objects to this Interrogatory as unclear,
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`vague, and ambiguous, particularly with respect to phrases “earliest priority date,” “the subject
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`matter to which each person contributed,” and “the dates and places each such person assisted,
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`supervised, or was otherwise so involved.” AGIS objects to this Interrogatory as having multiple
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`subparts, each counting towards Defendant’s total number of Interrogatories.
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`Case 2:21-cv-00072-JRG-RSP Document 221-2 Filed 11/17/21 Page 6 of 6 PageID #: 7589
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`Subject to and without waiving its General and Specific Objections, AGIS responds as
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`follows:
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`AGIS incorporates by reference, as if fully set forth herein, its response to Interrogatory
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`No. 2.
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`Discovery in this case is ongoing and AGIS continues to investigate this matter. AGIS
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`reserves the right to supplement its response to this Interrogatory to identify additional documents,
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`e.g., pursuant to Fed. R. Civ. P. 33(d).
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`11/3/2021 SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 12:
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`AGIS incorporates by reference its General Objections as if fully set forth herein. Subject
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`to and without waiving its General and Specific Objections, AGIS responds as follows:
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`AGIS identifies the following documents as containing information responsive to this
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`Interrogatory: AGISSOFTWARE_0660161-AGISSOFTWARE_0660615. AGIS incorporates its
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`response to Interrogatory No. 11.
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