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`Case 1:19-cv-11586-FDS Document 319-1 Filed 02/23/22 Page 1 of 18
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`EXHIBIT 1
`EXHIBIT 1
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`Case 1:19-cv-11586-FDS Document 319-1 Filed 02/23/22 Page 1 of 18
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`EXHIBIT 1
`EXHIBIT 1
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`Case 1:19-cv-11586-FDS Document 319-1 Filed 02/23/22 Page 2 of 18
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`UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF MASSACHUSETTS
`
`PHILIPS NORTH AMERICA LLC,
`
`v.
`
`FITBIT, INC.,
`
`Plaintiff,
`
`Defendant.
`
`Civil Action No. 1:19-cv-11586-IT
`
`PHILIPS NORTH AMERICA LLC’S NOTICE OF
`DEPOSOTION TO DEFENDANT FITBIT, INC.
`
`TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
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`PLEASE TAKE NOTICE that pursuant to Rule 30 of the Federal Rules of Civil
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`Procedure, Plaintiff Philips North America LLC (“Philips”) through its attorneys of record, will
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`take the deposition of Fitbit, Inc. (“Defendant”), concerning the Topics set forth in Appendix A.
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`The deposition will commence at a mutually agreeable date and time at the offices of
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`Philips’s counsel, Foley & Lardner LLP, or at such other place as has been mutually agreed by
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`the parties. For purposes of this Notice, Philips proposes September 14, 2020.
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`Pursuant to Federal Rule of Civil Procedure 30, the deposition will be taken before an
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`authorized court reporter and will be videotaped.
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`Defendant shall designate one or more officers, directors, managing agents, or other
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`persons who consent to testify on their behalf with respect to what is known or is reasonably
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`available to Defendant concerning each of the topics of examination set forth in Appendix A
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`attached hereto. For each person designated, Defendant shall advise Philips of the identity of that
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`person and the topic(s) on which that person shall testify at least five (5) business days in
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`advance of the deposition.
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`Case 1:19-cv-11586-FDS Document 319-1 Filed 02/23/22 Page 3 of 18
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`PHILIPS NORTH AMERICA LLC,
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`Dated, August 24, 2020
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`By Its Attorneys,
`
`/s/ Ruben J. Rodrigues
`Ruben Rodrigues (BBO 676,573)
`Lucas I. Silva (BBO 673,935)
`John Custer (BBO 705,258)
`FOLEY & LARDNER LLP
`111 Huntington Avenue
`Suite 2500
`Boston, MA 02199-7610
`Phone: (617) 342-4000
`Fax: (617) 342-4001
`rrodrigues@foley.com
`lsilva@foley.com
`jcuster@foley.com
`
`
`Eley O. Thompson (pro hac vice)
`FOLEY & LARDNER LLP
`321 N. Clark Street
`Suite 2800
`Chicago, IL 60654-5313
`Phone: (312) 832-4359
`Fax: (312) 832-4700
`ethompson@foley.com
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`Case 1:19-cv-11586-FDS Document 319-1 Filed 02/23/22 Page 4 of 18
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`APPENDIX A
`INSTRUCTIONS
`You are to prepare fully and completely to testify regarding the
`1.
`following Topics for Examination after conducting a diligent and thorough
`investigation into all information within Your possession, custody, or control. If
`You cannot fully and completely testify regarding any Topic, You are to prepare to
`testify regarding the Topic to the extent possible, specify the portion of the Topic
`You are unable to prepare for, and provide any information You have regarding
`that portion.
`If any Topic seeks testimony referencing or regarding a document or
`2.
`thing that has been lost, discarded, destroyed, or is otherwise unavailable for any
`reason, You should prepare to testify as to: the pertinent information contained in
`the document, the date of disposal, the manner of disposal, the reason for disposal,
`any person, firm or corporation who has possession, custody, or control of a full,
`partial, or incomplete copy of such document, and the identity of all persons who
`participated in the destruction or discarding or who have knowledge of the data and
`circumstances surrounding the destruction or discarding of the document or thing.
`3.
`If any Topic is objected to in part, You should prepare to testify
`regarding all portions of the Topic not objected to.
`4.
`If You claim that a Topic is overbroad and/or unduly burdensome,
`identify the respect in which the Topic is allegedly overbroad and/or unduly
`burdensome, and prepare to testify regarding any unobjectionable portion of the
`Topic.
`If You claim that a Topic is vague or ambiguous, identify the
`5.
`particular words, terms or phrases that You contend make the Topic vague and/or
`ambiguous, and specify the meaning You attribute to those words, terms, or
`phrases for purposes of Your testimony pertaining thereto.
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`Case 1:19-cv-11586-FDS Document 319-1 Filed 02/23/22 Page 5 of 18
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`These Topics shall include information acquired or identified up to the
`6.
`deposition and shall be deemed to be continuing. Therefore, You shall promptly
`supplement Your deposition testimony with any additional information that You
`identify, acquire, or become aware of up to and including the time of hearing.
`DEFINITIONS
`The following definitions apply to the Topics set forth below and to the
`other definitions and instructions provided.
`1.
`“Fitbit,” “You,” and “Your” mean Fitbit, Inc. and any present or
`former parent, subsidiary, department, division, subdivision, branch, affiliate,
`predecessor, successor-in-interest, or other related company, and includes any
`present or former officer, director, agent, employee, consultant, counsel, or
`representative of Fitbit, and any other person acting on or purporting to act on their
`behalf, including outside counsel or patent agents.
`2.
`The “’007 Patent” means U.S. Patent No. 6,013,007.
`3.
`The “’233 Patent” means U.S. Patent No. 7,088,233.
`4.
`The “’377 Patent” means U.S. Patent No. 8,277,377.
`5.
`“Asserted Patent(s)” mean the ’007 Patent, the ’233 Patent, and the
`’377 Patent.
`“Accused Products” means any of the activity tracker products offered
`6.
`by Fitbit that were identified in Philips’s L.R. 16.6 Disclosures, as well as any
`software products related to, associated with, or used in conjunction with said
`activity tracker products (regardless of whether such software runs on the activity
`tracker itself, a mobile device, desktop/laptop computer, server, or other computing
`device), including but not limited to the Fitbit App and the Fitbit.com Dashboard.
`7.
`“Communication” means any transmission of information from one
`person to another, regardless of the medium, and includes, without limitation, oral,
`electronic and written transmissions of information.
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`
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`“Date” means the precise day, month, and year, if known, or as
`8.
`precise a statement of the day, month, and year as is permitted by Your knowledge
`and the information available to You.
`9.
`“Document” or “documents” has the meaning prescribed in Federal
`Rule of Civil Procedure 34 and Federal Rule of Evidence 1001. The term
`“document” includes documents in any form, including documents stored
`electronically. Any comment or notation appearing on any document, and not part
`of the original text, is to be considered a separate “document.”
`10.
`“Person” means any natural person, individual, firm, corporation,
`partnership, proprietorship, joint venture, unincorporated associations, government
`agency, and all other groups of persons, organizations, or entities of any type.
`11.
`“Thing” has the meaning prescribed in Federal Rule of Civil
`Procedure 34. “Thing” specifically includes, without limitation, any disc, tape, or
`other electronic media storage device, any product, and any model, prototype, or
`experimental device or part or subassembly thereof.
`12. To “identify” a product means to provide the manufacturer and
`distributor of the product and all applicable designations including, without
`limitation, the product number, model number, product designations, trademarks,
`and trade names used in the industry, and if there are multiple versions of the
`product, the version number or designation of each version.
`13. To “identify” a communication means to provide the date of the
`communication, the identity of the person who initiated the communication, the
`identity of each person who received such communication (including any cc or bcc
`recipients), the form of the communication, and a general description of the
`content of the communication.
`14. To “identify” a document means to provide the date of preparation and,
`if different, the date of the document itself, the identity of each author, the identity
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`Case 1:19-cv-11586-FDS Document 319-1 Filed 02/23/22 Page 7 of 18
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`of each addressee and copy recipient, the format of the document (e.g., hardcopy or
`electronic), the number of pages and the type of document, and the present location
`and the identity of each person who has possession, custody or control of the
`document, and the production number of such document.
`15. To “identify” a person means to provide the person’s full name,
`present or last known residence address and telephone number, present or last
`known employer or other business affiliation, and the person’s present or last
`known employment address and telephone number.
`16. To “identify” an entity means to provide its full name, present or last
`known address, date and location of incorporation or organization, the name under
`which it was organized, the name of the chief executive officer or person holding a
`comparable position, and the identity of all natural persons within the entity having
`knowledge of the subject matter with respect to which the entity is being identified
`in response to an interrogatory.
`17. The phrases “relate(s) to,” “relating to,” “refer(s) to,” “referring to,”
`“regard(s),” “regarding,” “concern(s),” and “concerning” mean embodying,
`identifying, confirming, containing, showing, or pertaining to in any way, directly
`or indirectly, or having any logical or factual connection with the subject matter in
`question.
`18. The terms “and,” “or,” and “and/or” shall be construed in the
`conjunctive and the disjunctive.
`19. The singular shall be construed to include the plural and vice versa.
`
`DEPOSITION TOPICS
`The factual bases concerning Your contention that each Accused
`1.
`Product does not infringe the ’007 Patent, including whether:
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`Case 1:19-cv-11586-FDS Document 319-1 Filed 02/23/22 Page 8 of 18
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`(a)
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`(b)
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`(b)
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`(b)
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` each Accused Product infringes by direct infringement,
`induced infringement, and/or contributory infringement; and
`each limitation is present literally or under the Doctrine of
`Equivalents in each Accused Product.
`The factual bases concerning Your contention that each Accused
`2.
`Product does not infringe the ’233 Patent, including whether:
`(a)
` each Accused Product infringes by direct infringement,
`induced infringement, and/or contributory infringement; and
`each limitation is present literally or under the Doctrine of
`Equivalents in each Accused Product.
`The factual bases concerning Your contention that each Accused
`3.
`Product does not infringe the ’377 Patent, including whether:
`(a)
` each Accused Product infringes by direct infringement,
`induced infringement, and/or contributory infringement; and
`each limitation is present literally or under the Doctrine of
`Equivalents in each Accused Product.
` Your policies and procedures for generating, maintaining, and
`4.
`disposing of records.
`5.
`The facts and circumstances surrounding any investigations, analyses,
`or efforts relating to any attempts to, plans to, and/or analyses of ways to design
`around any claim of any of the Asserted Patents, and the results of such
`investigations, analyses, or efforts, including whether and why any design-around
`alternative was incorporated into any Accused Product.
`6.
`The facts and circumstances surrounding any business decisions made
`by Fitbit and/or other actions taken in response to learning of any of the Asserted
`Patents and other patents claiming overlapping priority, and/or the filing of this
`Action.
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`
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`Case 1:19-cv-11586-FDS Document 319-1 Filed 02/23/22 Page 9 of 18
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`The facts and circumstances surrounding any communication between
`7.
`You and any person concerning Philips or any of the Asserted Patents and other
`patents claiming overlapping priority.
`8.
`The marketing and sales of each of the Accused Products including,
`but not limited to:
`For each Accused Product: the sales, offers for sale, gross and
`
`a.
`net revenues, costs of goods sold, gross and net profits, expenses, and any
`discounts for each Accused Product, broken down by year and month,
`from the time period of the introduction of each Accused Product to
`present.
`Your annual budgets, financial projections and forecasts
`b.
`relating to revenues, costs, sales volumes and profits for the Accused
`Products, from the time period of the introduction of each Accused
`Product to present.
`c.
`The profitability and expected profitability of each Accused
`Product.
`Your decision to market, sell, license, distribute, promote,
`d.
`and/or offer to sell each Accused Product.
`e.
`Your pricing strategies, policies and procedures for each
`Accused Product.
`
`f.
`All sales, marketing and/or business plans, market segments,
`predictions concerning the past, present, or future size of the market,
`competitors, and market share, development of strategies for marketing
`for each Accused Product.
`g.
`Your strategy to differentiate each of the Accused Products
`from competitors’ products.
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`Case 1:19-cv-11586-FDS Document 319-1 Filed 02/23/22 Page 10 of 18
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`Your marketing efforts and materials related to the benefits,
`h.
`drawbacks, value, and/or importance of each Accused Product.
` Fitbit’s organizational structure for the following areas: engineering,
`9.
`
`design, and research and development; manufacture, fabrication, and assembly;
`and marketing, sales, and promotion.
`10. The facts and circumstances surrounding any claim for
`indemnification or potential indemnification Fitbit has made or will make relating
`to this Action, including the entity from which indemnification was, is, or will be
`sought or to which indemnification was, is, or will be given.
`11. The facts and circumstances surrounding any communications relating
`to this Action between Fitbit and any third party involved in the design,
`development, manufacture, distribution, or importation of each of the Accused
`Products since Philips’s filing of the Complaint in this Action, including
`communications relating to the allegations made in this Action and any effect this
`Action might have on Fitbit’s continued manufacture and sale of the Accused
`Products.
`12. The factual bases for Your contention that any of the Asserted Patents
`are invalid under any subsection of 35 U.S.C. §§ 101, 102, 103, and/or 112.
`13. The factual bases for Your assertion that Fitbit is “entitled to its
`attorney’s fees and costs under 35 U.S.C. 285 and Rule 11.”
`14. The factual bases concerning the secondary considerations of non-
`obviousness of the Asserted Patents.
`
`15. The facts and circumstances concerning when Fitbit first became
`aware of the Asserted Patents or any other patents claiming overlapping priority to
`the Asserted Patents, including the individuals involved and the original source of
`information from which Fitbit learned of them.
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`16. Knowledge by people developing the Accused Products of
`competitive or related products, including reference to such products and review of
`technical information relating to such products.
`17. Fitbit’s policies with regards to determining whether or not any of its
`products, including the Accused Products, practice the patents of other or infringe
`upon the intellectual property of others, including patent searches, and
`communications related to such efforts.
`18. Fitbit’s efforts to stay apprised of intellectual property that might
`relate to its products and services.
`19. Fitbit’s efforts to clear each of the Accused Products of potential
`patent infringement, including patent searches, and communications related to such
`efforts in regards to the Asserted Patents or other patents claiming overlapping
`priority.
`20. Fitbit’s refusal to take a royalty-bearing license under the Patents-in-
`
`Suit.
`
`21. Fitbit’s implementation of GPS functionality in each of the Accused
`Products.
`22. For each of the Accused Products that include GPS functionality, the
`operation of such functionality including any calculated outputs derived from GPS
`waypoints as well as the methods by which the Accused Products (including any
`Fitbit app or server) calculate those outputs.
`23. For each of the Accused Products that include or utilize the Fitbit App
`or Fitbit.com Dashboard, the operation and functionality of the Fitbit App or
`Fitbit.com Dashboard, including but not limited to:
`
`a. The transfer of data between each of the Accused Products and the
`Fitbit App or website including the identity of the data transferred,
`the frequency that said data is transferred, the form in which said
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`Case 1:19-cv-11586-FDS Document 319-1 Filed 02/23/22 Page 12 of 18
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`data is transferred, the medium(s) used in the transfer of said data,
`and the authentication of said data.
`b. The transfer of data between the Fitbit App or Fitbit.com
`Dashboard and Fitbit’s servers including the identity of the data
`transferred, the frequency of said data transfers, the form in which
`said data is transferred, the medium(s) used in the transfer of said
`data, and the authentication of said data.
`c. The calculations of any outputs that are displayed on the Accused
`Devices, the Fitbit App, or Fitbit.com Dashboard including the
`inputs used in such calculations and the location where such
`calculations take place, including but not limited to the following
`outputs:
`i. Distance
`ii. Location and/or route displayed on a map
`iii. Calories burned
`iv. Average Pace
`v. Split Pace
`vi. Speed
`vii. Heart rate
`viii. Active Minutes
`ix. Cardio Fitness Level
`x. Cardio Fitness Score
`xi. Minutes in Heart Rate Zones
`xii. Sleep Stages
`xiii. Sleep Score
`d. The pairing of the Fitbit App with the Accused Products.
`e. How the Fitbit App is downloaded to users’ devices such as
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`Case 1:19-cv-11586-FDS Document 319-1 Filed 02/23/22 Page 13 of 18
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`phones or tablets.
`f. Login features for accounts on the Fitbit App or Fitbit.com
`Dashboard.
`g. The user interface on the Fitbit App.
`h. The Exercise Sharing feature of the Fitbit App. See, e.g., PNA-
`FB0000132
`i. The sharing of maps and/or routes on the Fitbit App. See, e.g.,
`PNA-FB0000909.
`j. The calculation and display of the comparison of data between
`different users. See, e.g., Philips L.R. 16.6(d)(1) Disclosures, First
`Supplemental Ex. 1, at 24-27, 30-35
`k. The “Fitbit Coach” feature. See PNA-FB0002449; PNA-
`FB0002459.
`l. The display of advertising messages on the Fitbit App and/or the
`Fitbit.com Dashboard.
`24. For each Accused Product that includes GPS functionality, the
`functionality of the “Voice Cues” feature. See PNA-FB0000905.
`25. The method and functionality of how the Fitbit Ionic is paired with
`Bluetooth headphones, speakers or other audio devices. See PNA-FB0000204.
`26. For each Accused Product that includes GPS functionality, the
`functionality of the “Auto-Pause” feature. See PNA-FB0000188; PNA-
`FB0002454-2455.
`27. For each Accused Product that includes GPS functionality, the
`functionality of the “Run Detect” feature. See PNA-FB0000188.
`28. For each Accused Product that includes GPS functionality, the
`functionality of the “SmartTrack” feature. See PNA-FB0002365.
`
`
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`29. Your receipt of the October 10, 2016 letter from Elias Schilowitz
`addressed to Fitbit, Inc. and Mr. Park specifically (produced as PNA-FB0003515-
`17), which identified each of the Asserted Patents, including any actions You took
`in response to receiving the letter.
`30. Your receipt of the March 23, 2017 letter from Elias Schilowitz
`addressed to Fitbit, Inc. and Mr. Park specifically (produced as PNA-FB0003498-
`501), which enclosed the October 10, 2016 letter (produces as PNA-FB0003515-
`17), which identified each of the Asserted Patents, including any actions You took
`in response to receiving the letter.
` 31. Your receipt of the April 13, 2017 letter from Elias Schilowitz
`addressed to Fitbit, Inc. and Mr. Park specifically (produced as PNA-FB0003502-
`509), which enclosed the October 10, 2016 letter (produced as PNA-FB0003515-
`17) and the March 23, 2017 letter (produced as PNA-FB0003498-501), which
`identified each of the Asserted Patents, including any actions You took in response
`to receiving the letter.
`32. Your earliest notice of the ’007 patent.
`33. Your earliest notice of the ’233 patent.
`34. Your earliest notice of the ’377 patent.
`35. The gathering and production of documents, things and any other
`information responsive to any discovery request propounded by Philips in this
`Action.
`36. Any agreements or conversations between and/or among Fitbit and/or
`any third party regarding this Action or any litigation with Philips.
`37. Fitbit’s document retention, management, and/or destruction policies.
`38. All activities undertaken by or for Fitbit to preserve, locate, identify,
`collect, and produce discoverable documents (including tangible things,
`electronically stored data and information) relevant to this Action.
`
`
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`39. All documents destroyed, lost or otherwise no longer available, that
`relate to the ’007 Patent, including the current or former existence of said
`documents.
` All documents destroyed, lost or otherwise no longer available, that
`40.
`relate to the ’233 Patent, including the current or former existence of said
`documents.
` All documents destroyed, lost or otherwise no longer available, that
`41.
`relate to the ’377 Patent, including the current or former existence of said
`documents.
`42. All factual bases for Your contention, if any, that any relief sought by
`Philips for infringement of the Asserted Patents is barred in whole or in part by
`virtue of waiver and/or estoppel.
`43. All factual bases for Your contention, if any, that one or more of the
`Asserted Patents is unenforceable to the extent that the alleged inventors did not
`invent the claimed inventions or to the extent that the actual inventors are not
`named as inventors.
`44. The relevant market(s) for each Accused Product, including a
`description of the market, the competitors, and the market share of those
`competitors.
`45. All marketing and advertising of each Accused Product.
`46. All factual bases for Your contention, if any, that any relief sought by
`Philips is barred in whole or in part by any alleged license and/or covenant not to
`sue granted under the Asserted patents and/or by patent exhaustion.
`47. All factual bases for Your contentions that any Asserted Patent is
`invalid due to anticipation, obviousness, lack of written description, lack of
`enablement, indefiniteness, and/or being directed to unpatentable subject matter.
`
`
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`48. All factual bases for Your contention, if any, that any Asserted Patent
`is unenforceable due to inequitable conduct.
`49. All written opinions of counsel regarding the Asserted Patents and all
`communications relating to said opinions.
`50. The scope and content of prior art to the Asserted Patents.
`51. The relationship between Philips and Fitbit, including
`communications between Philips and Fitbit with regard to the Asserted Patents.
`52. Any alleged non-infringing alternatives to the Asserted Patents,
`including the identity of each alternative, the time period during which each
`alternative was available, the time and cost to develop, design, and manufacture
`each alternative, and any differences between each alternative and the Accused
`Products.
`53. The factual basis for any contention by Fitbit that its infringement of
`the Asserted Patents, if proven, is in good faith and not willful.
`54. The identity and terms of any patent license to which Fitbit is a party.
`55. Price trends, sales trends, market growth (or contraction), barriers to
`entry, and elasticity relating to the Accused Products.
`56. All surveys, market research, market analyses, market evaluations,
`and forecasts concerning or related to the Accused Products.
`57. Communications with Fitbit’s customers regarding the Accused
`Products, including instructions, training, and any other communications regarding
`the deployments and operation of the Accused Products.
`58. The marketing and sales of products or services sold as accessories to,
`in conjunction with, at the same time as, or otherwise relating to the sales
`identified above, including for all such accessory products or services the numbers
`for each of the metrics requested above, the manner by which each of these
`numbers was calculated, the methodology employed in such calculation, and the
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`documents reviewed, relied upon, or prepared in connection with calculating such
`numbers.
`59. Fitbit’s financial statements.
`
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a true and correct copy of the above document was
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`served on August 24, 2020 on counsel for Defendant via electronic mail.
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`By: /s/ John W. Custer
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