`Case 1:19-cv-11586-FDS Document 319-7 Filed 02/23/22 Page1of5
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`EXHIBIT 7
`EXHIBIT 7
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`Case 1:19-cv-11586-FDS Document 319-7 Filed 02/23/22 Page 2 of 5
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`UNITED STATES DISTRICT COURT
`DISTRICT OF MASSACHUSETTS
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`Plaintiff,
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`v.
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`PHILIPS NORTH AMERICA LLC,
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`FITBIT, INC.
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`Defendant.
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`C.A. No. 1:19-cv-11586-IT
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`PHILIPS NORTH AMERICA LLC’S SECOND SET OF
`INTERROGATORIES TO FITBIT, INC. (Nos. 9-11)
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`Pursuant to Rules 33 of the Federal Rules of Civil Procedure, Plaintiff Philips North
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`America LLC (“Philips”) serves the following interrogatories to be answered separately and in
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`writing under oath by Defendant Fitbit, Inc. (“Fitbit”) within thirty (30) days of service,
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`supplemented thereafter as required by Rule 26(e), in accordance with the Federal Rules of Civil
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`Procedure, the Local Rules, and the definitions and instructions below.
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`INSTRUCTIONS AND DEFINITIONS
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`1. Philips incorporates by reference, as if fully set forth herein, the Instructions and
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`Definitions stated in its First Set of Interrogatories (Nos. 1-8), which were served on January 10,
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`2020.
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`Case 1:19-cv-11586-FDS Document 319-7 Filed 02/23/22 Page 3 of 5
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`Interrogatory No. 9:
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`INTERROGATORIES
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`Identify the total number of users that have logged into the Fitbit App using their Fitbit
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`account from a mobile device from the years 2013 through 2020 and, if available, provide a
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`breakdown of such total number of users per year and identification of the Fitbit activity tracker
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`products being used by those users, as well as an explanation of the records relied on to make
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`any determination as to said total number of users.
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`Interrogatory No.10:
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`Identify the total number of users that have utilized the “voice cues” feature of the
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`accused the Accused Products (as demonstrated in PNA-FB0000905) from 2015 through 2018
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`and, if available, provide a breakdown of such total number of users per year and an
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`identification of the Fitbit activity tracker products being used by those users, as well as an
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`explanation of the records relied on to make any determination as to said total number of users.
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`To the extent device-specific information is available, Philips would agree to limit this
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`interrogatory to the Ionic and Surge products.
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`Interrogatory No. 11:
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`Identify the Fitbit individuals who communicated with Mr. Brian Sagi of Cerian
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`Technology Ventures, LLC on or about the years 2013 through 2015, with regard to any patents
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`on which Mr. Roger Quy was an inventor, including U.S. Patent No. 8,277,377 (’377), and
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`explain the substance of those communication, including whether the ’377 patent was identified
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`in those communications.
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`Case 1:19-cv-11586-FDS Document 319-7 Filed 02/23/22 Page 4 of 5
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`Dated: September 2, 2020
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` Respectfully Submitted,
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` /s/ Ruben J. Rodrigues
`Lucas I. Silva (BBO 673,935)
`Ruben J. Rodrigues (BBO 676,573)
`John W. Custer (BBO 705,258)
`FOLEY & LARDNER LLP
`111 Huntington Avenue
`Suite 2500
`Boston, MA 02199-7610
`Phone: (617) 342-4000
`Fax: (617) 342-4001
`lsilva@foley.com
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`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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`Counsel for Plaintiff
` Philips North America LLC
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`Case 1:19-cv-11586-FDS Document 319-7 Filed 02/23/22 Page 5 of 5
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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 September 2, 2020 on counsel for Defendant via electronic mail.
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`/s/ Ruben J. Rodrigues
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`4
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