PA Advisors, LLC v. Google Inc. et al

Filing 426

Second MOTION in Limine Defendants' Motion in Limine No. 2 by Google Inc., Yahoo! Inc.. (Attachments: #1 Exhibit White Decl., #2 Exhibit 1, #3 Exhibit 2, #4 Exhibit 3, #5 Text of Proposed Order)(Perlson, David)

PA Advisors, LLC v. Google Inc. et al

Doc. 426 Att. 2

Exhibit 1

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YOU to have possession, custody, or control o f that information or category o f information must be identified . h. YOUR obligation to respond to these Interrogatories is continuing and its

responses are to be supplemented to include subsequently acquired information in accordance with the requirements o f Rule 26(e) o f the Federal Rules o f Civil Procedure . INTERROGATORIES I N T E R R O G A T O R Y NO. 1: State whether any PERSON on behalf o f PLAINTIFF has requested or conducted an investigation o f the validity or invalidity (including any PRIOR ART search), enforceability or unenforceability, scope o f claims, infringement or noninfringement , o f the ' 0 6 7 PATENT and i f the answer is anything other than an unqualified negative , for each such investigation identify: each PERSON who requested the investigation and the date o f the request; each PERSON who furnished any DOCUMENTS upon which the investigation was based in whole or in part , and IDENTIFY each such document ; each PERSON who participated in the investigation, prepared or reported the results o f the investigation and IDENTIFY the date o f any such report, whether draft or final; each PERSON who received, read or had access to a draft or final report o f such investigation, or any conclusion set forth therein; and whether any decision was made or action taken by or on behalf o f PLAINTIFF in whole or in part as a result o f such investigation, and describe in detail each such decision and action . INTERROGATORY NO.2: Describe in detail the dates and circumstances of conception and reduction to practice o f each claim o f the '067 PATENT , by identifying any relevant DOCUMENTS , and all PERSONS involved , and f o r each such PERSON , the time period and nature o f that PERSON 'S involvement.

5131912650599.3

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