Case 4:23-cv-01147-ALM Document 91-2 Filed 02/20/25 Page 1 of 7 PageID #:
`6471
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`Exhibit A
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`Case 4:23-cv-01147-ALM Document 91-2 Filed 02/20/25 Page 2 of 7 PageID #:
`6472
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`SHERMAN DIVISION
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`Civil Action No. 4:23-cv-01147-ALM
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`Jury Trial Demanded
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`R2 Solutions LLC,
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` Plaintiff,
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`v.
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`Databricks, Inc.,
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` Defendant.
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`PLAINTIFF R2 SOLUTIONS LLC’S FOURTH SET OF INTERROGATORIES TO
`DEFENDANT DATABRICKS, INC. (NOS. 21-35)
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`Pursuant to Rules 26 and 33 of the Federal Rules of Civil Procedure and the applicable
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`local rules and orders of the Court, Plaintiff R2 Solutions LLC serves the following interrogatories
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`upon Defendant Databricks, Inc. Thirty days from service of this document, these interrogatories
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`are to be answered fully and separately, in writing, and under oath, by an officer or agent of
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`Defendant who is authorized to give answers on Defendant’s behalf.
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`Case 4:23-cv-01147-ALM Document 91-2 Filed 02/20/25 Page 3 of 7 PageID #:
`6473
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`DEFINITIONS & INSTRUCTIONS
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`Plaintiff incorporates by reference each and every definition and instruction included in
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`Plaintiff R2 Solutions LLC’s First, Second, and Third Sets of Interrogatories to Defendant
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`Databricks, Inc. (Nos. 1-20). Plaintiff additionally provides the following definitions.
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`1.
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`The term “Databricks Runtime” means Databricks Runtime as discussed on
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`Databricks’ website. See, e.g., https://www.databricks.com/glossary/what-is-databricks-runtime.
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`2.
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`The term “Demo Data” means the data that Databricks uses in conjunction with the
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`Accused Instrumentalities to demonstrate functionality of the Accused Instrumentalities for its
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`customers.
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`3.
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`The term “Internal Data” means data that Databricks maintains regarding its
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`business.
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`4.
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`The term “DBU” means “Databricks Unit” as discussed on Databricks’ website.
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`See, e.g., https://www.databricks.com/product/pricing.
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`5.
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`The term “SKU” has the meaning attributed to it on Databricks’ website. See, e.g.,
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`https://www.databricks.com/product/sku-groups.
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`6.
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`The term “Apache Spark” means the Apache Spark project as described by
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`https://spark.apache.org/.
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`Case 4:23-cv-01147-ALM Document 91-2 Filed 02/20/25 Page 4 of 7 PageID #:
`6474
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`INTERROGATORY NO. 21
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`INTERROGATORIES
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`For each year since 2017, identify the number of Databricks’ customers and the percentage
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`of Databricks’ customers that use Databricks Runtime.
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`INTERROGATORY NO. 22
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`Describe in detail how Databricks uses Databricks Runtime with its own data, including in
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`Your response how Databricks uses Databricks Runtime with its Demo Data as well as its Internal
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`Data.
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`INTERROGATORY NO. 23
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`Identify the amount of Databricks’ revenue and the percentage of Databricks’ total revenue
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`that is or was derived from Databricks Runtime on a monthly, quarterly, and yearly basis since
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`December 2017.
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`INTERROGATORY NO. 24
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`For each year since 2017, identify (1) the total number of customer queries to Databricks
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`Runtime and (2) the percentage of such total customer queries that result in joinder or merger of
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`data.
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`INTERROGATORY NO. 25
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`For each year since 2017, identify (1) the total number of Databricks’ customers that use
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`Databricks Runtime and (2) the percentage of all Databricks’ customers that use Databricks
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`Runtime to process data sets that are larger than 10MB.
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`Case 4:23-cv-01147-ALM Document 91-2 Filed 02/20/25 Page 5 of 7 PageID #:
`6475
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`INTERROGATORY NO. 26
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`Describe in detail how Databricks generates revenue via the Accused Instrumentalities,
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`including in Your answer a description of what DBUs are, how DBUs are calculated, how DBUs
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`are utilized to charge customers, why the price-per-DBU varies, and what factors cause the price-
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`per-DBU to vary.
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`INTERROGATORY NO. 27
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`Describe in detail how Databricks calculates the number of DBUs used by a customer.
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`INTERROGATORY NO. 28
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`Describe in detail what percentage of a DBU is attributable to processing power for
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`Databricks Runtime.
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`INTERROGATORY NO. 29
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`Describe in detail the relationship between Databricks Runtime and the Accused
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`Instrumentalities, including in Your response a description of the features and/or functionalities
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`included in Databricks Runtime.
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`INTERROGATORY NO. 30
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`Describe in detail Your costs related to Databricks Runtime on a monthly, quarterly, and
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`yearly basis since December 2017.
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`INTERROGATORY NO. 31
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`Identify by name and SKU which of Databricks’ products and/or software packages
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`include Databricks Runtime, and which do not.
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`INTERROGATORY NO. 32
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`Describe each SKU that does not include Databricks Runtime, including in Your
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`description an identification of the features included in each such SKU.
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`4
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`Case 4:23-cv-01147-ALM Document 91-2 Filed 02/20/25 Page 6 of 7 PageID #:
`6476
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`INTERROGATORY NO. 33
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`For each Databricks SKU, describe in detail Databricks’ revenue and profits attributable
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`to, and the DBUs consumed by, such SKU on a monthly, quarterly, and yearly basis since
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`December 2017.
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`INTERROGATORY NO. 34
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`For each Databricks SKU, describe in detail the historical pricing of such SKU since
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`December 2017.
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`INTERROGATORY NO. 35
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`For each year since 2017, identify which versions of Apache Spark were included with or
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`supported by Databricks Runtime.
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`Dated: December 20, 2024
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`Respectfully submitted,
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`/s/ Carder W. Brooks
`Edward R. Nelson, III
`State Bar No. 00797142
`Brent N. Bumgardner
`State Bar No. 00795272
`Christopher G. Granaghan
`State Bar No. 24078585
`John P. Murphy
`State Bar No. 24056024
`Carder W. Brooks
`State Bar No. 24105536
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`NELSON BUMGARDNER CONROY PC
`3131 West 7th Street, Suite 300
`Fort Worth, Texas 76107
`817.377.9111 (telephone)
`ed@nelbum.com
`brent@nelbum.com
`chris@nelbum.com
`murphy@nelbum.com
`carder@nelbum.com
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`Case 4:23-cv-01147-ALM Document 91-2 Filed 02/20/25 Page 7 of 7 PageID #:
`6477
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`COUNSEL FOR PLAINTIFF
`R2 SOLUTIONS LLC
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that a true and correct copy of the above and foregoing document
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`was served on all counsel of record via email on December 20, 2024.
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`/s/ Carder W. Brooks
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`6
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