Case 3:14-cv-00757-REP-DJN Document 106-4 Filed 04/24/15 Page 1 of 29 PageID# 15432
`Case 3:14-cv-00757-REP-DJN Document 106-4 Filed 04/24/15 Page 1 of 29 PageID# 15432
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`EXHIBIT 4
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`EXHIBIT 4
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`Case 3:14-cv-00757-REP-DJN Document 106-4 Filed 04/24/15 Page 2 of 29 PageID# 15433
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF VIRGINIA
`Richmond Division
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`Civil Action No. 3:14CV757-REP
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`SAMSUNG ELECTRONICS CO., LTD.
`et al.,
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`Plaintiffs,
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`v.
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`NVIDIA CORPORATION,
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`et al.,
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`Defendants.
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`NVIDIA’S SECOND SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS
`AND THINGS TO SAMSUNG (NOS. 48-110)
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`Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure, Defendant NVIDIA
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`Corporation ( “Defendant”), requests that Plaintiffs Samsung Electronics Company, Ltd. and
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`Samsung Electronics America, Inc. respond to these requests in writing, in accordance with the
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`definitions and instructions contained herein, and produce all documents and things in
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`Samsung’s possession, custody, or control that are requested below, within thirty (30) days after
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`service pursuant to the Federal Rules of Civil Procedure, and at the office of Latham & Watkins
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`LLP, 555 11th Street NW, Suite 1000, Washington, DC 20004, or at such other time and place as
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`the parties may agree upon.
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`As used herein and in all further Interrogatories, unless specified otherwise, the following
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`DEFINITIONS
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`definitions apply:
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`1.
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`“Samsung,” “Plaintiff,” “You,” or “Your” means Samsung Electronics Company,
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`Ltd. and Samsung Electronics America, Inc. and all parents, subsidiaries, and affiliates thereof,
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`all divisions, predecessors-in-interest, successors, and assigns of each of the foregoing, and all
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`principals, officers, investors, employees, directors, agents, consultants, attorneys, and all other
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`persons acting or purporting to act on behalf of or under the control of any of the foregoing.
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`2.
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`“Defendants” means NVIDIA Corporation, Velocity Micro, Inc., and Velocity
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`Holdings, LLC and their officers, directors, agents, representatives, employees, attorneys, and
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`investigators, and others acting on their behalf.
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`3.
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`References to this “lawsuit,” “case,” or “action” mean the above-captioned action
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`brought by Samsung.
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`4.
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`“The
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`’158 Patent” means U.S. Patent No. 5,860,158—including any
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`reexamination certificate and certificate of correction.
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`5.
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`“The
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`’938 Patent” means U.S. Patent No. 6,262,938—including any
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`reexamination certificate and certificate of correction.
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`6.
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`“The
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`’902 Patent” means U.S. Patent No. 6,287,902—including any
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`reexamination certificate and certificate of correction.
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`7.
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`“The
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`’602 Patent” means U.S. Patent No. 6,819,602—including any
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`reexamination certificate and certificate of correction.
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`8.
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`“The
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`’675 Patent” means U.S. Patent No. 8,252,675—including any
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`reexamination certificate and certificate of correction.
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`9.
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`“The
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`’724 Patent” means U.S. Patent No. 6,804,724—including any
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`reexamination certificate and certificate of correction.
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`10.
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`“The
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`’054 Patent” means U.S. Patent No. 7,073,054—including any
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`reexamination certificate and certificate of correction.
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`11.
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`“The
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`’854 Patent” means U.S. Patent No. 5,777,854—including any
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`reexamination certificate and certificate of correction.
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`12.
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` “Samsung-Patents-In-Suit” means the ’158 Patent, the ’938 Patent, the ’902
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`Patent, the ’602 Patent, the ’675 Patent, the ’724 Patent, the ’054 Patent, and the ’854 Patent,
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`collectively, any other patent that may be added to this litigation by Samsung in amended
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`pleadings, and the applications that lead to any of the foregoing patents. Any Interrogatory
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`referring to “Patent-In-Suit” or “Patents-In-Suit” seeks information as to each and every one of
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`the Samsung-Patents-In-Suit.
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`13.
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` “Asserted Samsung Claim(s)” means each claim of the Samsung-Patents-In-Suit
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`that Samsung asserts one or more Defendants infringe, either directly or indirectly, literally or by
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`the doctrine of equivalents.
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`14.
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`“Named Samsung Inventors” refers to the persons named as inventors on the face
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`of the Patents-In-Suit, including Jung-bae Lee, Choong-sun Shin, Dong-yang Lee, Du-hyung
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`Kim, Seong-young Seo, Jung-bae Lee, Byong-mo Moon, Jongwon Lee, Boun Yoon, Sang Yeob
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`Han, Chae Lyoung Kim, Randall S. Welch, Bao Gia Le, Yet-Ping Pai, Le T. Nguyen, Seung-Gi
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`Shin, In-soo Kim, and Kyung-young Kim.
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`15.
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`“Samsung File history” means the United States Patent and Trademark Office
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`(“PTO”) records of all communications and all documents and things sent between the PTO and
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`the patent applicant(s) in connection with the prosecution of the Samsung-Patents-In-Suit.
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`16.
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`“Samsung Foreign Counterpart Application” means any patent application filed
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`3
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`anywhere in the world outside the United States (i) that claims priority in whole or in part from
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`an application that resulted in a given patent; (ii) that is the basis for the claim of priority in
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`whole or part (including without limitation claims of benefits under 35 U.S.C. §§ 119(e) or 120)
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`for a given patent; or (iii) that discloses the same subject matter as a given patent.
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`17.
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`“Related Samsung Application” means any parent or ancestral application related
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`in any way to a given patent and any continuing application, continuation-in-part application,
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`divisional application, file-wrapper continuation, reexamination proceeding, reissue application,
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`abandoned application or foreign counterpart application for that patent.
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`18.
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`“Related Samsung Patent” means any patent that issued from any Related
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`Samsung Application.
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`19.
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`“The
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`’590 Patent” means U.S. Patent No. 7,339,590—including any
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`reexamination certificate and certificate of correction.
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`20.
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`“The
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`’414 Patent” means U.S. Patent No. 7,095,414—including any
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`reexamination certificate and certificate of correction.
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`21.
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`“The
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`’013 Patent” means U.S. Patent No. 6,532,013—including any
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`reexamination certificate and certificate of correction.
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`22.
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`“The
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`’531 Patent” means U.S. Patent No. 8,174,531—including any
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`reexamination certificate and certificate of correction.
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`23.
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`“NVIDIA-Patents-In-Suit” means the ’590 Patent, ’414 Patent, ’013 Patent and
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`’531 patent, collectively, any other patent that may be added to this litigation by NVIDIA in
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`amended pleadings, and the applications that lead to any of the foregoing patents. Any
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`Interrogatory referring to “NVIDIA-Patent-In-Suit” seeks information as to each and every one
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`of the NVIDIA-Patents-In-Suit.
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`24.
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` “Asserted NVIDIA Claim(s)” means each claim of the NVIDIA-Patents-In-Suit
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`that NVIDIA asserts Samsung infringes, either directly or indirectly, literally or by the doctrine
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`of equivalents.
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`25.
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`“Named NVIDIA Inventors” refers to the persons named as inventors on the face
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`of the NVIDIA-Patents-In-Suit, including Jeffrey B. Moskal, David C. Tannenbaum, Andrew D.
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`Bowen, Jakob Nebeker, John Erik Lindholm, Simon Moy, David B. Kirk, Paolo E. Sabella,
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`Matthew N. Papakipos, Liang Peng, Brett W. Coon, Stuart F. Oberman, Ming Y. Siu, Matthew
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`P. Gerlach and Harold Robert Feldman Zatz.
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`26.
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`“NVIDIA File history” means the United States Patent and Trademark Office
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`(“PTO”) records of all communications and all documents and things sent between the PTO and
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`the patent applicant(s) in connection with the prosecution of the NVIDIA-Patents-In-Suit.
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`27.
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`“NVIDIA Foreign Counterpart Application” means any patent application filed
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`anywhere in the world outside the United States (i) that claims priority in whole or in part from
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`an application that resulted in a given patent; (ii) that is the basis for the claim of priority in
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`whole or part (including without limitation claims of benefits under 35 U.S.C. §§ 119(e) or 120)
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`for a given patent; or (iii) that discloses the same subject matter as a given patent.
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`28.
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`“Related NVIDIA Application” means any parent or ancestral application related
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`in any way to a given patent and any continuing application, continuation-in-part application,
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`divisional application, file-wrapper continuation, reexamination proceeding, reissue application,
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`abandoned application or foreign counterpart application for that patent.
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`29.
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`“Related NVIDIA Patent” means any patent that issued from any Related
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`NVIDIA Application.
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`30.
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`“Infringe,”
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`“infringing,”
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`“infringed,” or
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`“infringement” means direct
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`infringement, indirect infringement, contributory infringement, induced infringement, literal
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`infringement and/or infringement under the doctrine of equivalents.
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`31.
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`“Prior Art” is used in these Interrogatories in the same sense that it is used in 35
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`U.S.C. §§ 102 or 103 and includes without limitation, any patent, publication, physical device,
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`prototype, knowledge, use, sale, offer for sale, any documents or other items evidencing any of
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`the foregoing, and/or any other act or event defined in 35 U.S.C. § 102, taken singly or in
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`combination, and having or occurring at a date such as to be potentially relevant under any
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`subsection of 35 U.S.C. §§ 102 or 103.
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`32.
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`“Person” or “individual” means any natural person or any business, legal or
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`government entity, or association—including, but not limited to, any proprietorship, partnership,
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`firm, company, or corporation.
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`33.
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`“Third party” means and includes any person or persons other than Samsung and
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`Defendants.
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`34.
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`“Accused NVIDIA Products” means and includes any system, method, product,
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`component, and/or service made, used, sold, offered for sale, or imported by Defendants that
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`Samsung contends infringes any claim of the Samsung-Patents-In-Suit. In referring to any
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`product as an “Accused NVIDIA Product,” Defendants in no way communicate their agreement
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`that the Accused NVIDIA Products infringe any claim of the Samsung-Patents-In-Suit or are
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`rightfully the subject of suit in this action.
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`35.
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`“Accused Samsung Products” means collectively and individually, each and every
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`product accused of infringement in NVIDIA’s Counterclaims and in any infringement
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`contentions served by NVIDIA, and any subsequent amendments to either, that (1) was made,
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`used, sold, offered for sale, or sold by Samsung or on Samsung’s behalf at any time from April
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`14, 2009 to the present anywhere in the world, or (2) was imported into the United States by
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`Samsung or on Samsung’s behalf at any time from April 14, 2009 to the present. The term
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`“Accused Samsung Product(s)” also includes products under development by Samsung, that you
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`may or intend to make, use, sell or offer for sale in the future, anywhere in the world. For
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`avoidance of doubt, the phrase “any Accused Samsung Product” relates to each and every
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`Accused Samsung Product and to any group of products that includes any Accused Samsung
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`Product (e.g., an analysis of Samsung’s SoCs in general would be responsive to a request for
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`analyses of any Accused Samsung Product).
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`36.
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`“SoC(s)” and “System(s)-on-a-Chip” means, for
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`the purposes of
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`these
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`Interrogatories only, any integrated circuit that that integrates multiple components of a
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`computer (including processing) and other electronic circuits onto a single chip, which includes
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`both a CPU and GPU.
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`37.
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` “GPU(s)” and “Graphics Processing Unit(s)” means, for the purposes of these
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`Interrogatories only, any specialized processor, electronic circuit within a chip, or semiconductor
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`intellectual property core that is designed, at least in part, to process graphics data for the
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`purpose of rendering images, animations, video and other content for a visual display. “GPU(s)”
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`also includes without limitation GPU elements within an SoC.
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`38.
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` “Date” means the exact day, month and year if so ascertainable or, if not, the best
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`approximation (e.g., relationship to seasons or other events).
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`39.
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`The terms “identify,” “identity,” and “identification” shall mean, as the context
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`shall make appropriate:
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`a. With respect to a person, the person’s full name, present or last known address,
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`telephone number, occupation, and employer. Once a person has been identified
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`in accordance with this subparagraph, only the name of that person need be listed
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`in response to subsequent discovery requesting the identification of that person;
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`b. With respect to a document, the (i) type of document; (ii) general subject matter;
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`(iii) date of the document; and (iv) author(s), addressee(s) and recipient(s);
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`c. With respect to a telephone conversation, the full name, occupation, telephone
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`number, and address of each party to the telephone conversation, the date of the
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`conversation, and the subject matter discussed;
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`d. With respect to an oral conversation other than a telephone conversation, the full
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`name, occupation, telephone number, and address of each party to such
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`conversation, the date of the conversation, and the subject matter discussed;
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`e. With respect to a corporation, partnership, association, or other entity, its full
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`name, form of organization, present or last known address, and telephone number;
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`and
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`f. With respect to any event or action, the dates or approximate dates thereof, a
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`description of what occurred, and all persons involved.
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`40.
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`“Communicate” or “communication” means, without limitation, any manner or
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`means of disclosure, transfer, transmission, conveyance, or exchange of information whether by
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`written, oral, or other means (such as person-to-person, in a group, by telephone, letter,
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`facsimile, electronic or computer mail, voicemail, telex, telecopy, or any other process, electric,
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`electronic or otherwise).
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`41.
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`“Document” is synonymous in meaning and equal in scope to the usage of the
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`term “documents or electronically stored information” in Rule 34(a)(1)(A) of the Federal Rules
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`of Civil Procedure. A draft or non-identical copy is a separate document within the meaning of
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`this term. By way of illustration, and without limitation, documents include at least the
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`following: originals, drafts, and all non-identical copies of memoranda, reports, notes, graphs,
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`laboratory notebooks, correspondence, interoffice communications, letters, diaries, calendars,
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`photographs, motion pictures, sketches, drawings, promotional material, technical papers, printed
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`publications, patents, records, reports, and all other writings, as well as all non-paper information
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`storage means such as sound reproductions, computer inputs and outputs, tape, film and
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`computer memory devices, as well as tangible things such as models, modules, prototypes, and
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`commercially saleable products.
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`42.
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`“Thing” shall mean any tangible item, including without limitation, models,
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`prototypes and samples of any device or apparatus or product.
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`43.
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`“Reflect,” “reflecting,” “concern,” “concerning,” “related,” “relating,” “relate,”
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`“refer,” or “referring” and other variations thereof, as used herein shall be construed in their
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`broadest possible sense, and mean without limitation and whether in whole or in part: referring
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`to, constituting, bearing upon, commenting upon, reflecting, evidencing, pertaining to,
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`describing, depicting, consisting of, containing, comprising, embodying, identifying, stating,
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`discussing, analyzing, studying, summarizing, dealing with, relating to, or having any logical or
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`factual connection whatsoever with the subject addressed, regardless whether the factual
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`connection is favorable to or adverse to you.
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`44.
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`“Product” means any machine, manufacture, apparatus, device, system, process,
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`service, method, or instrumentality which is designed to function together electrically,
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`mechanically, chemically, or otherwise, to achieve a particular function or purpose, including
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`those offered for sale, sold, imported, or under development.
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`45.
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`“Covered Product” means any product that Samsung contends practices or
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`embodies (or has at any time practiced or embodied) any alleged invention described or claimed
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`in any of the Patents-In-Suit, including any products made by Samsung or third parties, but
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`excluding Defendants products.
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`46.
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`“Your predecessors-in-interest” means any former interest holder in any of the
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`Patents-In-Suit, including without limitation any employers of Named Inventors, assignees of
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`any of the Patents-In-Suit, and security interest holders in any of the Patents-In-Suit.
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`47.
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`As used herein, the term “facts” shall have its ordinary meaning and, pursuant to
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`Federal Rule of Civil Procedure 33(a)(2), also shall mean related opinions, related contentions,
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`and the application of law to fact.
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`INSTRUCTIONS
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`1.
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`The following shall apply to all Requests:
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`a. The singular of any word includes its plural, and vice versa, to bring within the
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`scope of these Requests any information that might otherwise be deemed outside
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`their scope;
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`b. The terms “and” and “or” shall be construed either conjunctively or disjunctively,
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`to bring within the scope of these Requests any information that might otherwise
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`be deemed outside their scope;
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`c. The terms “all,” “any,” and “each” shall be construed as encompassing any and
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`all to bring within the scope of these Requests any information that might
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`otherwise be deemed outside their scope;
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`d. “Including” shall not be used to limit any general category or description that
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`precedes it and shall mean “including without limitation” so as to be inclusive;
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`and
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`e. The present tense shall be construed to include the past tense and vice versa.
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`2.
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`In responding to these Requests, You are required to furnish all information that
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`is available to You or subject to Your reasonable inquiry, including information in the
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`possession of Your present and former attorneys, accountants, advisors, representatives, agents,
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`employees, or other persons directly or indirectly employed by or connected with You, and
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`anyone else otherwise subject to Your control. All documents and things that respond, in whole
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`or in part, to any portion of the Requests below shall be produced in their entirety, including all
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`attachments and enclosures.
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`3.
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`If there are no documents or things responsive to a particular request, You should
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`so state in writing.
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`4.
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`If You believe that any of the following Requests calls for an assertion of a claim
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`of privilege or work product immunity, answer so much of the Request as is not objected to, state
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`that part of each Request to which You raise an objection, and set forth the basis for Your claim
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`of privilege or immunity with respect to such information You refuse to give—including
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`providing a log having sufficient particularity that will enable Defendants to assess Your claim
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`of privilege or immunity in accordance with Federal Rule of Civil Procedure 26(b)(5).
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`5.
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`In the event You contend that any of these Requests are objectionable, in whole or
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`in part, state with particularity each such objection and the bases therefore, and respond to the
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`remainder of the Request to the extent that You are not objecting to it.
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`6.
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`If any Request is ambiguous or unclear to You, please contact undersigned
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`counsel as soon as possible so that the Request can be clarified to avoid unnecessary delays in
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`discovery.
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`7.
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`Each Request shall be deemed continuing, in accordance with the requirements of
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`Rule 26(e) of the Federal Rules of Civil Procedure, so as to require supplemental or mandatory
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`responses should You obtain additional or different responsive information subsequent to Your
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`initial responses.
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`8.
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`If You do not agree with any definition of the terms provided herein, You are
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`instructed to provide a reasonable, alternative definition for that term, consistent with industry
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`custom and usage.
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`9.
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`Each of the definitions and instructions contained herein shall be fully applicable
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`to each Request notwithstanding that a definition or instruction above may, in whole or in part,
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`be reiterated in a particular Request and notwithstanding that a particular Request may
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`incorporate supplemental instructions or definitions. If, however, You provided any alternate
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`definitions in accordance with these Instructions, indicate whether and how, any answer to any
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`Request would differ if You relied on Your alternate definition in responding to that Request
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`instead of the definitions provided.
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`10.
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`Each Request shall be construed independently, and no Request shall be viewed
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`as limiting the scope of any other Request.
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`11.
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`Each and every copy of a document or Thing that is different from the original
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`because of stamps, indications of the recipient(s), handwritten notes, marks, attachments, or any
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`other reason, is a separate document or Thing that must be produced.
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`12.
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`In further accordance with Rule 34 of the Federal Rules of Civil Procedure, all
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`documents and things produced for inspection and copying shall be organized and labeled to
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`correspond with the categories in the Request or shall be produced as they are kept in the normal
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`course of business.
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`13.
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`If You produce any tape, disk, card, wire, or other electronic or mechanical
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`recording or transcript, or any computer program in response to any Request, You shall also
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`produce such documents, software, and instructions as are necessary for the decoding, playing
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`back, printing, and/or interpretation thereof, and any other documents that are necessary to
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`convert said information into a useable format.
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`14.
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`If production of any requested document(s) is objected to on the grounds that
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`production is unduly burdensome, describe the burden or expense of the proposed discovery.
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`REQUESTS FOR PRODUCTION
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`REQUEST FOR PRODUCTION NO. 48:
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`All documents related to design, research, development, operation, implementation, and
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`use of any Accused Samsung Product or any SoC or GPU contained within an Accused Samsung
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`Product, including technical reference manuals, architecture descriptions, instruction set
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`architectures, user manuals, specifications, circuit diagrams, schematics, functional diagrams,
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`block diagrams, layout diagrams, installation guides, readme files, product descriptions,
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`instructions, and technical support information.
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`REQUEST FOR PRODUCTION NO. 49:
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`Documents and things sufficient to identify all internal and external identifiers for each
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`Accused Samsung Product or any SoC or GPU contained within an Accused Samsung Product,
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`including, without limitation, all product names, product numbers, part numbers, code names,
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`SKUs, and any other similar identification systems used for internal or external identification.
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`REQUEST FOR PRODUCTION NO. 50:
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`Documents sufficient to identify, by name and model number, all Accused Samsung
`
`Products that contain a Mali GPU, and the name and model/part number of the GPU and SoC
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`used in each such Accused Samsung Product.
`
`REQUEST FOR PRODUCTION NO. 51:
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`13
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`Case 3:14-cv-00757-REP-DJN Document 106-4 Filed 04/24/15 Page 15 of 29 PageID# 15446
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`All Documents relating to the structure, development, design, architecture, function, and
`
`operation of Mali GPUs in the Accused Samsung Products and in the SoCs used in the Accused
`
`Samsung Products, including but not limited to, instruction sets, instruction set architectures,
`
`internal architecture specifications, microarchitecture specifications, documentation on operation
`
`code (opcode) functions, design specifications, hardware description code, white papers, design
`
`rules, programming guides, sample code, device drivers, all drivers used with the GPU
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`(including OpenGL drivers), test and verification drivers, functional descriptions of the GPU,
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`functional models of the GPU and of the RTL (including Source Code), register level
`
`programming descriptions, register transfer language (RTL) and hardware description code for
`
`the GPU including header files, block diagrams of the GPU and SoC, test plans and code,
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`assembler code, compilers, graphics pipeline diagrams, graphics pipeline timing specifications,
`
`3D class documentation, and benchmarking software and tools.
`
`REQUEST FOR PRODUCTION NO. 52:
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`All Source Code, specifications, schematics, circuit diagrams, flow charts, artwork,
`
`formulas, and other Documents that show the operation, use and implementation of the Mali
`
`GPU in each Accused Samsung Product and in the SoCs used in the Accused Samsung Products.
`
`REQUEST FOR PRODUCTION NO. 53:
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`All Documents reflecting Communications between You and ARM related to or
`
`concerning Mali GPUs used, or intended or planned for use, in the Accused Samsung Products.
`
`REQUEST FOR PRODUCTION NO. 54:
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`All RTL, Source Code, drivers, software, SDKs, block diagrams, specifications and other
`
`Documents you received from ARM related to Mali GPUs used, or intended or planned for use,
`
`in any of the Accused Samsung Products.
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`
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`14
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`Case 3:14-cv-00757-REP-DJN Document 106-4 Filed 04/24/15 Page 16 of 29 PageID# 15447
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`REQUEST FOR PRODUCTION NO. 55:
`
`Documents sufficient to identify, by name and model, all Accused Samsung Products that
`
`contain a PowerVR GPU, and the name and model/part number of the GPU and SoC used in
`
`each such Accused Samsung Product.
`
`REQUEST FOR PRODUCTION NO. 56:
`
`Documents sufficient to identify, by name and model/part number, all Third Party SoCs
`
`(in Accused Samsung Products) that contain a PowerVR GPU, and the name and model/part
`
`number of their GPUs.
`
`REQUEST FOR PRODUCTION NO. 57:
`
`All Documents relating to the structure, development, design, architecture, function, and
`
`operation of PowerVR GPUs in the Accused Samsung Products and in the SoCs used in the
`
`Accused Samsung Products, including but not limited to, instruction sets, instruction set
`
`architectures,
`
`internal
`
`architecture
`
`specifications, microarchitecture
`
`specifications,
`
`documentation on operation code (opcode) functions, design specifications, hardware description
`
`code, white papers, design rules, programming guides, sample code, device drivers, all drivers
`
`used with the GPU (including OpenGL drivers), test and verification drivers, functional
`
`descriptions of the GPU, functional models of the GPU and of the RTL (including Source Code),
`
`register level programming descriptions, register transfer language (RTL) and hardware
`
`description code for the GPU including header files, block diagrams of the GPU and SoC, test
`
`plans and code, assembler code, compilers, graphics pipeline diagrams, graphics pipeline timing
`
`specifications, 3D class documentation, and benchmarking software and tools.
`
`REQUEST FOR PRODUCTION NO. 58:
`
`
`
`15
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`

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`Case 3:14-cv-00757-REP-DJN Document 106-4 Filed 04/24/15 Page 17 of 29 PageID# 15448
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`All Source Code, specifications, schematics, circuit diagrams, flow charts, artwork,
`
`formulas, or other Documents that show the operation, use and implementation of the PowerVR
`
`GPU in each Accused Samsung Product and in the SoCs used in the Accused Samsung Products.
`
`REQUEST FOR PRODUCTION NO. 59:
`
`All Documents reflecting Communications between You and Imagination Technologies
`
`related to or concerning PowerVR GPUs used, or intended or planned for use, in the Accused
`
`Samsung Products.
`
`REQUEST FOR PRODUCTION NO. 60:
`
`All RTL, Source Code, drivers, software, SDKs, block diagrams, specifications and other
`
`Documents you received from Imagination Technologies related to PowerVR GPUs used, or
`
`intended or planned for use, in any of the Accused Samsung Products.
`
`REQUEST FOR PRODUCTION NO. 61:
`
`Documents sufficient to identify, by name and model, all Accused Samsung Products that
`
`contain an Adreno GPU, and the name and model/part number of the GPU and SoC used in each
`
`such Accused Samsung Product.
`
`REQUEST FOR PRODUCTION NO. 62:
`
`Documents sufficient to identify, by name and model/part number, all Qualcomm SoCs
`
`used in Accused Samsung Products, the name and model/part number of the GPU used in each
`
`such Qualcomm SoC, the name and model/part number of the Qualcomm SoC, and the name and
`
`model/part number of the Accused Samsung Product using the Qualcomm SoC.
`
`REQUEST FOR PRODUCTION NO. 63:
`
`All Documents relating to the structure, development, design, architecture, function, and
`
`operation of Adreno GPUs in the Accused Samsung Products and in the Qualcomm SoCs used in
`
`
`
`16
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`

`

`Case 3:14-cv-00757-REP-DJN Document 106-4 Filed 04/24/15 Page 18 of 29 PageID# 15449
`
`
`the Accused Samsung Products, including but not limited to, instruction sets, instruction set
`
`architectures,
`
`internal
`
`architecture
`
`specifications, microarchitecture
`
`specifications,
`
`documentation on operation code (opcode) functions, design specifications, hardware description
`
`code, white papers, design rules, programming guides, sample code, device drivers, all drivers
`
`used with the GPU (including OpenGL drivers), test and verification drivers, functional
`
`descriptions of the GPU, functional models of the GPU and of the RTL (including Source Code),
`
`register level programming descriptions, register transfer language (RTL) and hardware
`
`description code for the GPU including header files, block diagrams of the GPU and SoC, test
`
`plans and code, assembler code, compilers, graphics pipeline diagrams, graphics pipeline timing
`
`specifications, 3D class documentation, and benchmarking software and tools.
`
`REQUEST FOR PRODUCTION NO. 64:
`
`All Source Code, specifications, schematics, circuit diagrams, flow charts, artwork,
`
`formulas, and other Documents that show the operation, use and implementation of the Adreno
`
`GPU in each Accused Samsung Product and in the Qualcomm SoCs used in the Accused
`
`Samsung Products.
`
`REQUEST FOR PRODUCTION NO. 65:
`
`All Documents reflecting Communications between You and Qualcomm related to or
`
`concerning Adreno GPUs or Qualcomm SoCs used, or intended or planned for use, in the
`
`Accused Samsung Products.
`
`REQUEST FOR PRODUCTION NO. 66:
`
`All RTL, Source Code, drivers, software, SDKs, block diagrams, specifications and other
`
`Documents you received from Qualcomm related to Adreno GPUs or Qualcomm SoCs used, or
`
`intended or planned for use, in any of the Accused Samsung Products.
`
`
`
`17
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`

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`Case 3:14-cv-00757-REP-DJN Document 106-4 Filed 04/24/15 Page 19 of 29 PageID# 15450
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`
`REQUEST FOR PRODUCTION NO. 67:
`
`All Documents that refer, relate to, and/or describe any component, software or Source
`
`Code stored on or shipped with an Accused Samsung Product that in any way relates to the
`
`generation of graphics and/or visual data using the GPU, including but not limited to, user
`
`interfaces, application software, graphics rendering APIs, libraries, OpenGL ES interfaces,
`
`OpenGL ES drivers and other drivers for the GPU, and all applications and application layers
`
`that are used to generate graphics using the GPU.
`
`REQUEST FOR PRODUCTION NO. 68:
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`All Documents relating to the development or use of any Source Code or software
`
`Release referred to in these Document Requests or responsive to these Document Requests,
`
`including but not limited to release notes, memos, communications, configuration guides,
`
`installation guides, configu