UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`Case No. 6:19-cv-00236-ADA
`
`SOLAS OLED LTD.,
`
`Plaintiff,
`
`v.
`
`LG DISPLAY CO., LTD., a Korean
`corporation
`LG ELECTRONICS, INC., a Korean
`corporation
`and SONY CORPORATION, a
`Japanese corporation,
`
`Defendants.
`
`PLAINTIFF SOLAS OLED LTD.’S RESPONSES AND OBJECTIONS TO
`DEFENDANTS’ FIRST SET OF INTERROGATORIES (NOS. 1-17)
`
`Pursuant to Rules 26 and 33 of the Federal Rules of Civil Procedure, Plaintiff Solas OLED
`
`Ltd. (“Solas”) hereby objects and responds to Defendants LG Display Co., Ltd, LG Electronics, Inc
`
`and Sony Corporation’s (collectively “Defendants”) First Set of Interrogatories as follows:
`
`I.
`
`PRELIMINARY STATEMENT
`
`Discovery in this matter is still ongoing. Solas is presently pursuing its investigation and
`
`analysis of the facts and law relating to this case and has not completed such investigation or
`
`preparation for trial. Therefore, these responses and objections, while based on diligent factual
`
`exploration by Solas and its counsel, reflect only Solas’s current state of knowledge, understanding
`
`and belief with regard to the matters about which inquiry has been made. Solas anticipates that,
`
`LG Display Co., Ltd.
`Exhibit 1030
`LG Display v. Solas
`IPR2020-01055
`
`Ex. 1030-001
`
`
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`Case No. 6:19-cv-00236-ADA
`
`SOLAS OLED LTD.,
`
`Plaintiff,
`
`v.
`
`LG DISPLAY CO., LTD., a Korean
`corporation
`LG ELECTRONICS, INC., a Korean
`corporation
`and SONY CORPORATION, a
`Japanese corporation,
`
`Defendants.
`
`PLAINTIFF SOLAS OLED LTD.’S RESPONSES AND OBJECTIONS TO
`DEFENDANTS’ FIRST SET OF INTERROGATORIES (NOS. 1-17)
`
`Pursuant to Rules 26 and 33 of the Federal Rules of Civil Procedure, Plaintiff Solas OLED
`
`Ltd. (“Solas”) hereby objects and responds to Defendants LG Display Co., Ltd, LG Electronics, Inc
`
`and Sony Corporation’s (collectively “Defendants”) First Set of Interrogatories as follows:
`
`I.
`
`PRELIMINARY STATEMENT
`
`Discovery in this matter is still ongoing. Solas is presently pursuing its investigation and
`
`analysis of the facts and law relating to this case and has not completed such investigation or
`
`preparation for trial. Therefore, these responses and objections, while based on diligent factual
`
`exploration by Solas and its counsel, reflect only Solas’s current state of knowledge, understanding
`
`and belief with regard to the matters about which inquiry has been made. Solas anticipates that,
`
`LG Display Co., Ltd.
`Exhibit 1030
`LG Display v. Solas
`IPR2020-01055
`
`Ex. 1030-001
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`(irrelevant pages omitted)
`
`Ex. 1030-002
`
`
`
`extent that it seeks information protected by the attorney-client privilege, the work product
`
`doctrine, or any other applicable privilege.
`
`Subject to and without waiving its specific or general objections, Solas responds as follows:
`
`Pursuant to Federal Rule of Civil Procedure 33(d), Solas has produced or will produce
`
`documents from which information responsive to this interrogatory may be determined.
`
`Solas’s investigation is ongoing; Solas reserves the right to modify or supplement this
`
`response should additional information become available.
`
`INTERROGATORY NO. 14:
`
`For each Asserted Claim of each Asserted Patent, describe whether you assert the claim is
`
`valid, and for each claim you assert is valid: (a) describe in detail each and every basis for your
`
`contention of validity; (b) with respect to each prior art reference, or combination of prior art
`
`references, identified by Defendants as a basis for invalidity under 35 U.S.C. § 102 or § 103,
`
`describe in detail each and every basis on which you contest such assertion of invalidity, including
`
`but not limited to which, if any, limitation of each claim you assert is not disclosed by that prior
`
`art reference or combination of prior art references, and describe in detail the complete basis for
`
`any disagreement you have with the analysis set forth by Defendants; (c) with respect to 35 U.S.C.§
`
`112, describe in detail each and every basis for your contention that the requirements of 35 U.S.C.§
`
`112 are satisfied, including describe in detail the complete basis for any disagreement you have
`
`with § 112 analysis set forth by Defendants; (d) identify all Documents you assert support your
`
`assertions of validity; and (e) identify the three (3) Persons most knowledgeable about the factual
`
`bases for your assertions.
`
`Ex. 1030-003
`
`
`
`RESPONSE TO INTERROGATORY NO. 14:
`
`Solas objects to this interrogatory on the grounds that it is overbroad and unduly
`
`burdensome. Solas objects to this interrogatory on the grounds that it is impermissibly compound.
`
`Solas further objects to this interrogatory to the extent that it seeks information protected by the
`
`attorney-client privilege, the work product doctrine, or any other applicable privilege. Solas further
`
`objects that this interrogatory seeks contentions upon matters which Defendants carry the burden
`
`of proof. Solas further objects to this request because it prematurely seeks disclosure of expert
`
`opinion.
`
`Subject to and without waiving its specific or general objections, Solas responds as follows.
`
`Solas asserts that each of the Asserted Claims is valid. The Asserted Patents are entitled to a
`
`presumption of validity and Defendants have failed to rebut that presumption. An expert opinion
`
`on validity would be premature at this point at least because Defendants have not yet served their
`
`expert reports detailing their theories as to the alleged invalidity of the Asserted Claims.
`
`Defendants carry the burden of proof to show by clear and convincing evidence that the Asserted
`
`Claims are invalid, and Solas is not required to respond to theories that have not yet been fully
`
`propounded by Defendants. Should Defendants serve expert reports setting forth their theories
`
`alleging that the Asserted Claims are invalid, Solas will serve a rebuttal expert report concerning
`
`validity, on December 4, 2020, in accordance with the Court’s Scheduling Order (Dkt. No. 59),
`
`and Solas directs Defendants to that expert report.
`
`Solas’s investigation is ongoing; Solas reserves the right to modify or supplement this
`
`response should additional information become available.
`
`Ex. 1030-004
`
`
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`(irrelevant pages omitted)
`
`Ex. 1030-005
`
`
`
`
`
`
`
`Dated: June 29, 2020
`
`Respectfully submitted,
`
`
`
`
`
`
`
`/s/ Reza Mirzaie
`Marc Fenster
`CA State Bar No. 181067
`Reza Mirzaie
`CA State Bar No. 246953
`Neil A. Rubin
`CA State Bar No. 250761
`RUSS AUGUST & KABAT
`12424 Wilshire Boulevard, 12th Floor
`Los Angeles, CA 90025
`Telephone: 310-826-7474
`Email: mfenster@raklaw.com
`Email: rmirzaie@raklaw.com
`Email: nrubin@raklaw.com
`
`Sean A. Luner
`CA State Bar No. 165443
`Gregory S. Dovel
`CA State Bar No. 135387
`Jonas B. Jacobson
`CA State Bar No. 269912
`DOVEL & LUNER, LLP
`201 Santa Monica Blvd., Suite 600
`Santa Monica, CA 90401
`Telephone: 310-656-7066
`Email: sean@dovel.com
`Email: greg@dovel.com
`Email: jonas@dovel.com
`
`1
`
`Ex. 1030-006
`
`
`
`T. John Ward, Jr.
`TX State Bar No. 00794818
`Claire Abernathy Henry
`TX State Bar No. 24053063
`Andrea L. Fair
`TX State Bar No. 24078488
`WARD, SMITH & HILL, PLLC
`PO Box 1231
`Longview, Texas 75606
`Telephone: 903-757-6400
`Email: jw@wsfirm.com
`Email: claire@wsfirm.com
`Email: andrea@wsfirm.com
`
`ATTORNEYS FOR PLAINTIFF,
`SOLAS OLED LTD.
`
`
`
`2
`
`Ex. 1030-007
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that on June 29, 2020, all counsel of record who are deemed to
`
`have consented to electronic service are being served with a copy of this document via electronic
`
` /s/ Reza Mirzaie
` Reza Mirzaie
`
`
`
`mail.
`
`
`
`
`
`Ex. 1030-008
`
`
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