Case 2:22-cv-00263-JRG-RSP Document 42-14 Filed 01/10/23 Page 1 of 29 PageID #:
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`EXHIBIT 13
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`Case 2:22-cv-00263-JRG-RSP Document 42-14 Filed 01/10/23 Page 2 of 29 PageID #:
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`AGIS SOFTWARE DEVELOPMENT LLC,
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`Plaintiff,
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`§
`Case No. 2:22-cv-00263-JRG-RSP
`§
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`§
`JURY TRIAL DEMANDED
`§
`§
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`§
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`§
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`PLAINTIFF’S FIRST SET OF INTERROGATORIES TO
`DEFENDANTS SAMSUNG ELECTRONICS CO., LTD. AND
`SAMSUNG ELECTRONICS AMERICA, INC. (NOS. 1-14)
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`v.
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`SAMSUNG ELECTRONICS CO., LTD.,
`ET AL.,
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`Defendants.
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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 Defendants Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc.
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`(collectively, “Samsung” or “Defendants”) respond to the following Interrogatories in writing,
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`under oath, and in accordance with the following definitions and instructions, within thirty (30)
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`days of the date of service thereof. These Interrogatories are continuing in nature and require
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`supplementation in accordance with the Federal Rules of Civil Procedure.
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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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`“Samsung,” “Defendant,” “Defendants,” “You,” and “Your” shall mean
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`Defendants Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. including,
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`without limitation, all predecessors-in-interest, successors in-interest, parents, subsidiaries,
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`affiliates, and all past or present officers, directors, trustees, employees, agents, consultants,
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`attorneys, patent agents, entities acting in joint venture, licensing or partnership relationships with
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`any of the defendants in any country.
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`3.
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`The terms “Accused Functionality” and “Accused Functionalities” are defined as
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`the features disclosed in the Complaint, representative infringement charts, and any amendments
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`or supplements thereto.
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`4.
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`“Accused Products” include any and all of Defendants’ products (including
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`applications, services, devices, and servers) that implement the Accused Functionalities, including
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`any such products that were released six years preceding the Complaint in this case and any such
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`products that will be released on or before the date of trial in this Action. “Accused Products”
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`includes any and all products identified in the Complaint, initial disclosures, infringement
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`contentions, and any amendments and supplements thereto. “Accused Products” includes any and
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`all products identified by Defendant in response to discovery requests, including these
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`Interrogatories. For example, “Accused Products” includes Samsung Tactical and Samsung Knox
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`services. For example, “Accused Products” includes but is not limited to each and every version
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`of Samsung devices and servers running: Samsung Tactical, TAK, ATAK, and CivTAK, and
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`Samsung Knox. For example, “Accused Products” includes but is not limited to the following
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`devices running Samsung Tactical, TAK, ATAK, and CivTAK, and Samsung Knox: the Galaxy
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`S20 Tactical Edition, Galaxy XCover FieldPro, Galaxy XCover Pro, GT-I7500 Galaxy, i5700
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`Galaxy Spica, Galaxy S, Galaxy SL, Galaxy S II, Galaxy S Advance, Galaxy S III, Galaxy S Duos,
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`Galaxy S III Mini, Galaxy S II Plus, Galaxy S4, Galaxy S4 Active, Galaxy S4 Mini, Galaxy S4
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`Zoom, Galaxy S Duos 2, Galaxy S III Slim, Galaxy S5, Galaxy S III Neo, Galaxy S5 Active,
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`Galaxy S5 Mini, Galaxy S Duos 3, Galaxy S5 Plus, Galaxy S6, Galaxy S6 Edge, Galaxy S5 Neo,
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`2
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`Galaxy S6 Active, Galaxy S6 Edge+, Galaxy S7, Galaxy S7 Edge, Galaxy S7 Active, Galaxy S8,
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`Galaxy S8+, Galaxy S8 Active, Galaxy S9, Galaxy S9+, Galaxy S10e, Galaxy S10, Galaxy S10+,
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`Galaxy S10 5G, Galaxy S21, Galaxy S20 FE, Galaxy Alpha, Galaxy A3, Galaxy A5, Galaxy A7,
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`Galaxy A8, Galaxy A3, Galaxy A5, Galaxy A7, Galaxy A8, Galaxy A8+, Galaxy A6, Galaxy A6+,
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`Galaxy A8 Star, Galaxy A7, Galaxy A9, Galaxy A6s, Galaxy A8s, Galaxy A30, Galaxy A50,
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`Galaxy A10, Galaxy A20, Galaxy A40, Galaxy A70, Galaxy A20e, Galaxy A80, Galaxy A40s,
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`Galaxy A60, Galaxy A10s, Galaxy A20s, Galaxy A10e, Galaxy C5, Galaxy C7, Galaxy C9,
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`Galaxy C9 Pro, Galaxy C7 Pro, Galaxy C5, Pro, Galaxy C8, Galaxy J, Galaxy J1, Galaxy J5,
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`Galaxy J7, Galaxy J2, Galaxy J1 Ace, Galaxy J1 Nxt, Galaxy J1 Mini, Galaxy J5 (2016), Galaxy
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`J3 Pro, Galaxy J7, Galaxy J Max, Galaxy J1 Ace Neo, Galaxy J1 (2016), Galaxy J5 Prime, Galaxy
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`J7, Prime, Galaxy J1 Mini Prime, Galaxy J2 Prime, Galaxy J3 Emerge, Galaxy J7 V, Galaxy J3
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`Prime, Galaxy J7 Pro, Galaxy J7 Max, Galaxy J7 Nxt, Galaxy J3 Luna Pro, Galaxy J7 Sky Pro,
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`Galaxy J7+, Galaxy J2 Pro, Galaxy J7 Prime 2, Galaxy J7 Duo, Galaxy J4, Galaxy J6, Galaxy J3
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`(2018), Galaxy J7 (2018), Galaxy J2 Core, Galaxy J4+, Galaxy J6+, Galaxy J4 Core, Galaxy M,
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`Galaxy M10, Galaxy M20, Galaxy M30, Galaxy M40, Galaxy E5, Galaxy E7, Galaxy Grand,
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`Galaxy Core, Galaxy Core Plus, Galaxy Grand 2, Galaxy Grand Neo, Galaxy Core Prime, Galaxy
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`Grand Prime Plus, Galaxy Grand Prime Pro, Galaxy Mega 5.8, Galaxy Mega 6.3, Galaxy Mega 2,
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`Galaxy Mini, Galaxy Mini 2, Galaxy Trend, Galaxy Trend Lite, Galaxy Trend Plus, Galaxy Ace,
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`Galaxy Ace Plus, Galaxy Ace 2, Galaxy Ace 3, Galaxy Ace Style, Galaxy Ace 4, Galaxy On7,
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`Galaxy On5, Galaxy On5 Pro, Galaxy On7 Pro, Galaxy On8, Galaxy On Nxt, Galaxy On Max,
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`Galaxy On7 Prime, Galaxy On6, Galaxy On8 (2018), Galaxy R, Galaxy R Style, Galaxy Y, Galaxy
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`Y Duos, Galaxy Young, Galaxy Young 2, Galaxy Pocket, Galaxy Pocket Plus, Galaxy Pocket
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`Neo, Galaxy Pocket Duos, Galaxy Pocket 2, Galaxy U, Galaxy Neo, Galaxy Pro, Galaxy
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`3
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`Precedent, Galaxy Z, Galaxy Rush, Galaxy 5, Galaxy W, Galaxy Fit, Galaxy Gio, Galaxy Prevail,
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`Galaxy Nexus, Galaxy Discover, Galaxy Reverb, Galaxy Stellar, Galaxy Appeal, Galaxy Express,
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`Galaxy Express 2, Galaxy Fame, Galaxy Star, Galaxy Win, Galaxy Win Pro, Galaxy Star Pro,
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`Galaxy Fame Lite, Galaxy Round, Galaxy Light, Galaxy V, Galaxy V Plus, Galaxy V2, Galaxy K
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`Zoom, Galaxy Folder, Galaxy Active Neo, Galaxy Folder 2, Galaxy Fold, Galaxy Note, Galaxy
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`Note II, Galaxy Note 3, Galaxy Note 4, Galaxy Note Edge, Galaxy Note 5, Galaxy Note 7, Galaxy
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`Note Fan Edition, Galaxy Note 8, Galaxy Note 9, Galaxy Note 10, Galaxy Note 10+, Galaxy Note
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`10+ 5G, Galaxy Tab, Galaxy Tab 7.0, Galaxy Tab 10.1, Galaxy Tab 10.1N, Galaxy Tab 10.1v,
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`Galaxy Tab 8.9, Galaxy Tab 7.0 Plus, Galaxy Tab 7.7, Galaxy Tab 2 7.0, Galaxy Tab 2 10.1,
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`Galaxy Tab 3 7.0, Galaxy Tab 3 Lite 7.0, Galaxy Tab 3 8.0, Galaxy Tab 3 10.1, Galaxy Tab 4 7.0,
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`Galaxy Tab 4 8.0, Galaxy Tab 4 10.1, Galaxy Tab Pro 8.4, Galaxy Tab Pro 10.1, Galaxy Tab Pro
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`12.2, Galaxy Tab S 8.4, Galaxy Tab S 10.5, Galaxy Tab S2 8.0, Galaxy Tab S2 9.7, Galaxy Tab
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`S3 9.7, Galaxy Tab S4 10.5, Galaxy Tab E 8, Galaxy Tab E 9.6, Galaxy Tab A 8.0, Galaxy Tab A
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`9.7, Galaxy Tab A 6.0, Galaxy Tab A 7.0, Galaxy Tab A 10.1, Galaxy Tab A 10.5, Galaxy Tab
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`Pro S 12.0, Galaxy Book 10.6, Galaxy Book 12.0, Galaxy Tab Active, Galaxy Tab Active 2,
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`Galaxy View, Galaxy Note 8.0, Galaxy Note 10, Galaxy Note 10.1, Galaxy Note Pro 12.2, Galaxy
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`Gear, Gear Sport, Gear S3 Frontier, Galaxy Watch, Galaxy Watch Active, and Galaxy Watch
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`Active 2 from July 2016 to the present. For the avoidance of doubt, the term “Accused Products”
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`does not include the Google Find My Device application, the Samsung Find My Mobile
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`application, and the Google Maps Mobile application with Share Location feature.
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`5.
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`“This Action” means AGIS Software Dev. LLC v. Samsung Elecs. Co., Case No.
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`2:22-cv-00263-JRG-RSP (E.D. Tex.).
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`6.
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`“’970 Patent” means U.S. Patent No. 8,213,970, entitled “Method of Utilizing
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`4
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`Forced Alerts for Interactive Remote Communications.”
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`7.
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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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`8.
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`“’829 Patent” means U.S. Patent No. 9,749,829, 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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`“’123 Patent” means U.S. Patent No. 9,820,123, entitled “Method to Provide Ad
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`Hoc and Password Protected Digital and Voice Networks.”
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`10.
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`“Asserted Patents” means the ’970 Patent, the ’838 Patent, the ’829 Patent, and the
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`’123 Patent.
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`11.
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`“Related Patent Application” means any patent application or issued patent having
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`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” means
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`any international application and/or foreign counterpart of the Asserted Patents. “Related Patent
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`Application” includes any patent application or issued patent within a chain of copendency with
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`respect to any of the Asserted Patents.
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`12.
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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, books,
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`records, accounts, letters, telegrams, correspondence, notes of meetings, notes of conversations,
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`notes of telephone calls, inter-office memoranda or written communications of any nature,
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`recordings of conversations either in writing or by means of any mechanical or electrical recording
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`device, notes, papers, reports, analyses, invoices, canceled checks or check stubs, receipts, minutes
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`of meetings, time sheets, diaries, desk calendars, ledgers, schedules, licenses, financial statements,
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`telephone bills, logs and any differing versions of the foregoing whether denominated formal,
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`informal or otherwise, as well as copies of the foregoing which differ in any way, including
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`handwritten notations or other written or printed matter of any nature, from the original. The
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`foregoing specifically includes the information stored in any form, including electronic form, on a
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`computer or in a computer database or otherwise, including electronic mail. Moreover, the term
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`“document” shall also include all “technical documents,” such as source code, specifications,
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`schematics, flow charts, artwork, drawing, pictures, pictorial representations, formulas,
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`troubleshooting guides, service bulletins, technical bulletins, production specification sheets,
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`white papers, operator manuals, operation manuals and instruction manuals.
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`13.
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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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`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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`14.
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`“Thing(s)” refers to any physical specimen or tangible item, including research and
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`development models, samples, prototypes and the like.
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`15.
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`“Person(s)” refers to all natural persons and all types and kinds of business or other
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`entities, including, but not limited to, corporations, limited liability companies, partnerships, joint
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`ventures, associations, sole proprietorships, government bodies and government agencies. Any
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`reference to an individual person, either singularly or as part of a defined group, includes that
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`person’s employees, agents, legal and non-legal representatives, heirs, successors, assigns and any
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`other person or entity acting on the behalf of such individual person. Any reference to a corporation
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`or any other entity also refers to and includes any and all parents, subsidiaries, predecessors,
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`6
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`successors, affiliates, partners, joint venturers, agents, employees, representatives, accountants,
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`investment bankers, consultants or attorneys acting on behalf of the corporation or other entity.
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`The masculine includes the feminine and vice versa; the singular includes the plural and vice versa.
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`16.
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`17.
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`“Patent Laws” shall refer to Title 35 of the United States Code.
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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” shall mean direct
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`infringement, contributory infringement, infringement by inducement, literal infringement, and
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`infringement by the doctrine of equivalents.
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`18.
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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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`19.
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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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`20.
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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 referring
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`to a product or thing, the title or model name/number, any code name, project name or other name
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`by which it has been referred, and a general description of the product or thing; (5) when referring
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`to a written communication, the identity of the document(s) in which the communication was
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`7
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`made; (6) when referring to an oral communication, the identity of all persons participating in the
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`communication; (7) when referring to non-patent documents, the Bates number, type of document,
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`its general nature and subject matter, date of creation, and all author(s), addressee(s) and
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`recipient(s); and (8) when referring to patent documents, the country, patent and/or application
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`number, dates of filing, publication and grant, and the names of the patentees or applicants.
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`21.
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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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`22.
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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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`23.
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`“And” and “or” shall be construed either disjunctively or conjunctively as necessary
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`to bring within the scope of each interrogatory all responses that might otherwise be construed
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`outside the scope.
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`24.
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`25.
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`26.
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`27.
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`28.
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`“Any” shall include “all” and “All” shall include “any.”
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`The term “including” shall mean including without limitation.
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`The use of the singular form of any word includes the plural and vice versa.
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`The use of any tense of any word includes all other tenses.
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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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`8
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`29.
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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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`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 were,
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`but are no longer are, in your possession, custody, or control, state what disposition was made of
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`them and when. If any documents referred-to in response to the following Interrogatories have
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`been lost or destroyed, describe in detail the circumstances of such loss or destruction, identify
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`each lost or destroyed document (and all files that contained such documents), and describe in
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`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, electronic
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`records and computerized information must be produced in an intelligible format, together with a
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`description of the system from which they were derived sufficient to permit rendering the records
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`and information intelligible.
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`9
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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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`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. Civ.
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`P. 33(d), for each such Interrogatory and subpart thereof, specify the production numbers (i.e.,
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`Bates numbers) of the specific document or group of documents accompanying your 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 ability
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`to provide a response to that Interrogatory, you must specify whether the inability to provide a
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`response is because the particular item or category of information never existed, has been
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`destroyed, has been lost, misplaced, or stolen, or has never been, or is no longer, in your possession,
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`custody, or control, in which case the name and address of any person or entity known or believed
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`10
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`by you to have possession, custody, or control of that information or category of information must
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`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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`11
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`INTERROGATORY NO. 1
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`INTERROGATORIES
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`Identify all Accused Products distributed and/or sold to customers and made available for
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`download and/or purchase by customers from July 2016 to the present. For each Accused Product
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`that is a Samsung application or Samsung service, provide at least the following information: (i)
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`an identification of the names and codenames (including internal and external names) and platform
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`(e.g., operating system) for each Accused Product; (ii) an identification of each version and
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`revision (including internal and external names) of the Accused Products; (iii) the first and last
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`dates each version and revision of the Accused Products was made available for download and/or
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`purchase; and (iv) a detailed explanation of the timeline (including the first date) of testing for
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`each version and revision (including any corresponding pre-release test or beta versions) of the
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`Accused Products. For each Accused Product that is a Samsung server, provide at least the
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`following information: (i) the internal and external name(s), code names, and model number(s) of
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`each Samsung server; (ii) the physical location of each Samsung server; (iii) an identification of
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`each version and revision of each Samsung application or Samsung service used with or provided
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`by each Samsung server; (iv) the identification of each function or service (e.g., accounts, maps,
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`payments) carried out by each Samsung server; and (v) the identification of each Entity and/or
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`Samsung business unit that puts into practice each Samsung server. For each Accused Product
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`that is a Samsung device (such as a phone, tablet, laptop, or watch), provide at least the following
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`information: (i) the internal and external name(s), code name(s), and model number(s) of each
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`Samsung device; (ii) the version number and release number/designation; (iii) the earliest date
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`Samsung first began making, using, offering for sale, selling, and importing the product; (iv) an
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`identification of each component (e.g., GPS chip, operating system, chipset, modem, antenna)
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`12
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`involved in or responsible for the device’s ability to implement the Accused Functionalities for
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`each Accused Product; and (v) an identification of the software build identification number(s) for
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`each Accused Product and each Accused Functionality in each Accused Product.
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`RESPONSE TO INTERROGATORY NO. 1
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`13
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`INTERROGATORY NO. 2
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`For each Accused Product, identify: (i) each Entity and/or Samsung business unit involved
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`with the design, development, testing, manufacture, assembly, marketing, offer for sale, sale,
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`distribution, use, importation, and exportation of each Accused Functionality and Accused
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`Product; (ii) a description of the functions of each Entity or Samsung business unit identified in (i)
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`above; (iii) each location where the design, development, testing, manufacture, assembly,
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`marketing, offer for sale, sale, distribution, importation, and exportation took place; and (iv) three
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`Person(s) (employed by Samsung or otherwise) most knowledgeable about the design,
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`development, testing, manufacture, assembly, marketing, offer for sale, sale, distribution, use,
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`importation, and exportation of each Accused Product.
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`RESPONSE TO INTERROGATORY NO. 2
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`14
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`INTERROGATORY NO. 3
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`For each Accused Product, identify, on a monthly basis from July 2016 to present: the
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`volume of sales (in units and in U.S. Dollars), the gross revenue, net profits, profit margins, fixed
`
`and variable costs, average cost per unit (i.e., application, service, and server) and transfer pricing,
`
`and set forth all bases for your response.
`
`RESPONSE TO INTERROGATORY NO. 3
`
`
`
`
`
`15
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 42-14 Filed 01/10/23 Page 17 of 29 PageID #:
`1602
`
`INTERROGATORY NO. 4
`
`Identify: (i) any agreements, licenses, or contracts, including attachments or exhibits to
`
`those documents, relating to any Accused Product, including but not limited to, intellectual
`
`property license agreements, settlement agreements, and technology agreements; (ii) which of
`
`these agreements you contend are comparable to an agreement resulting from a hypothetical
`
`negotiation between You and AGIS, and (iii) the Person(s) most knowledgeable concerning any
`
`such agreements, licenses, or contracts, and attachments or exhibits to those documents.
`
`RESPONSE TO INTERROGATORY NO. 4
`
`
`
`
`
`16
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 42-14 Filed 01/10/23 Page 18 of 29 PageID #:
`1603
`
`INTERROGATORY NO. 5
`
`Explain in detail all factual and legal bases for any contention by You that You have not
`
`infringed the Asserted Patents, including without limitation the identification of (i) each claim
`
`element of the Asserted Patents that You allegedly do not practice; (ii) all documents,
`
`circumstances, or other information that supports each contention that You do not practice a claim
`
`element; (iii) the three Person(s) knowledgeable with respect to any such contention; and (iv) any
`
`documents, things, persons and/or witnesses that You intend to rely on to support such a
`
`contention.
`
`RESPONSE TO INTERROGATORY NO. 5
`
`
`
`
`
`17
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 42-14 Filed 01/10/23 Page 19 of 29 PageID #:
`1604
`
`INTERROGATORY NO. 6
`
`Identify the date and circumstances under which You first became aware of the Asserted
`
`Patents, the patent applications of the Asserted Patents, and any Related Patent Applications,
`
`including but not limited to: (i) a description of when and how You first became aware of the
`
`Asserted Patents (including awareness through reference or citation to the Asserted Patents), the
`
`patent applications of the Asserted Patents, and any Related Patent Applications; (ii) an
`
`identification of those Person(s) who first became aware of the Asserted Patents, the patent
`
`applications of the Asserted Patents, and any Related Patent Applications; (iii) a description of the
`
`actions taken by You in response to becoming aware of the Asserted Patents, the patent
`
`applications of the Asserted Patents, and any Related Patent Applications; and (iv) identify all
`
`documents relating to, supporting, or evidencing the foregoing.
`
`RESPONSE TO INTERROGATORY NO. 6
`
`
`
`
`
`18
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 42-14 Filed 01/10/23 Page 20 of 29 PageID #:
`1605
`
`INTERROGATORY NO. 7
`
`For each Asserted Patent, identify and describe in detail each allegedly design-around
`
`and/or non-infringing alternative that You contend can be used as an alternative to each Asserted
`
`Patent, including but not limited to: (i) a description of each alleged design-around and/or non-
`
`infringing alternative; (ii) a description of when and how each alleged design-around and/or non-
`
`infringing alternative was developed (if applicable); (iii) the identity of the Person(s) involved in
`
`developing each alleged design-around and/or non-infringing alternative (if applicable), including
`
`their titles and departments if they are current or former employees of Defendant; (iv) dates when
`
`each alleged design-around and/or non-infringing alternative was incorporated in Your products
`
`(if applicable); (v) costs associated with developing and implementing each design-around and/or
`
`alleged non-infringing alternative; (vi) steps and the time required to develop and implement each
`
`alleged design-around and/or non-infringing alternative; (vii) the advantages and disadvantages of
`
`the alternative to You as compared to Your current approach; and (viii) any impact (however
`
`measured by You) that each such alternative would have, if implemented by You, on the
`
`performance, function or acceptability of each of the Accused Products.
`
`RESPONSE TO INTERROGATORY NO. 7
`
`
`
`
`
`19
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 42-14 Filed 01/10/23 Page 21 of 29 PageID #:
`1606
`
`INTERROGATORY NO. 8
`
`For each Accused Product, identify and describe in detail any agreements and contracts
`
`You have entered into with any third party to make, use, test, offer to sell, sell, import into the
`
`United States, and/or otherwise supply the Accused Functionalities and the Accused Products,
`
`including identifying all person(s) (both internal and external to Samsung) with knowledge of the
`
`agreements and contracts and any correspondence, documents, and things relating thereto.
`
`RESPONSE TO INTERROGATORY NO. 8
`
`
`
`
`
`20
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 42-14 Filed 01/10/23 Page 22 of 29 PageID #:
`1607
`
`INTERROGATORY NO. 9
`
`For each Accused Product, identify and describe in detail any and all internal and external
`
`surveys, market studies, metrics, summaries, and industry analysis relating to the importance,
`
`value, engagement, and use of Accused Functionalities and the Accused Products, and describe in
`
`detail Defendants’ knowledge and capabilities to track its customers’ use of the Accused
`
`Functionalities in the United States, how the customers’ use data is tracked, and identification of
`
`all customer use data related to the Accused Functionalities in Defendants’ document production.
`
`RESPONSE TO INTERROGATORY NO. 9
`
`21
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 42-14 Filed 01/10/23 Page 23 of 29 PageID #:
`1608
`
`INTERROGATORY NO. 10
`
`For each Accused Product, Identify (i) each instance of a transaction, purchase, order, sale,
`
`subscription, and distribution, and for each instance provide a corresponding unique identifier
`
`(e.g., order number, invoice number), date, description, version of the Accused Product, customer
`
`information, recipient information, and price, and (ii) each and every sales agreement, purchase
`
`invoice, and contract relating to the Accused Products.
`
`RESPONSE TO INTERROGATORY NO. 10
`
`22
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 42-14 Filed 01/10/23 Page 24 of 29 PageID #:
`1609
`
`INTERROGATORY NO. 11
`
`Identify and describe, in detail, all communications, correspondence, documents, and
`
`information about or referencing AGIS, AGIS Software Development LLC, Advanced Ground
`
`Information Systems, Inc., Malcolm K. Beyer, Jr., Malcolm Beyer, Cap Beyer, Christopher R.
`
`Rice, Sandel Blackwell, the Asserted Patents, and any Related Patents including, but not limited
`
`to, communications, correspondence, documents, and information from the aforementioned
`
`entities and individuals to any employees or agents of Defendants and any follow-up
`
`communications, correspondence, documents, and information from any employees or agents of
`
`Defendant.
`
`RESPONSE TO INTERROGATORY NO. 11
`
`
`
`23
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 42-14 Filed 01/10/23 Page 25 of 29 PageID #:
`1610
`
`INTERROGATORY NO. 12
`
`For each Accused Functionality and each Accused Product, identify the following internal
`
`and external documents in your possession, custody, and/or control: source code, business
`
`requirements, product requirements, technical manuals and specifications, reference designs,
`
`product briefs, application notes, component and product testing documentation and reports,
`
`market studies, and consumer surveys. For each identification, provide the production numbers
`
`(Bates nu