Free Response to Motion - District Court of Delaware - Delaware

°8”°4”2°°4 ldaiée WS4-ev-0041 s-sua Document 133-2 Filed 08/19/2005 Page 1 erdm
UNITED STATES INTERNATIONAL TRADE COMMISSION
WASHINGTON, }).C. 20436
Before The Honorable Sidney Harris
Administrative Law J udge
In the Matter of
Certain Disc Drives, Components Tliereoi and Ima NO' 337`TA_5l6
Products Containing Same
COMPLAINANTS FIRST SET OF DOCUMENT
REQUESTS QNOS. 1~·65] TO RESPONDENT CORNICE, INC.
Pursuant to the United States International Trade Cormnissionfs Rules of Practice and
Procedure, 37 C.F.R. §§ 2l(}.27 and 2lO.30, Complainant Seagate Technology LLC {"Seagate?)
hereby requests Respondent Cornice, Inc. {"Comice’i) to produce, permit inspection and copying
(with convenient access to duplicating equipment), or otherwise cause to be reproduced, each of
the following documents and things within the possession, custody or control of Respondent,
designated and organized bythe paragraphs and subparagraphs hereof to which they correspond,
within the time prescribed bythe rules of the Administrative Law Judge and ofthe Commission
at the offices of FISH & RICHARDSON P.C., 1425 K Street, NW., Washington, D.C. 20005.
DEFINITIONS
l. “Complainant" or "Seagate" means Seagate Technology LLC, individually and
collectively, including without limitation all of its corporate locations, and all predecessors,
subsidiaries, parents, and affiliates, and all past or present directors, officers, agents,
representatives, employees, consultants, attorneys, entities actiri in joineventure or partnership
relationships with Seagate and others acting on behalf of Seagate.
2. °‘Respondent," "Comice," "yon" or "your" means Comice, Inc., including without
limitation all of your corporate locations, and all predecessors, subsidiaries, parents, and

°*"°t’·"*°°‘* ease i"?64-ev-0041s-SLF1 Document 133-2 Filed 08/19/2005 Page 2 er@""
REQUEST NO. 7:
Documents sufiieient to show the quantity, by month or quarter and in total, the sales
prices, and the rettutos of each ofthe accused products made, sold or offered for sale by or for
Cornice.
REQUEST N O. 8:
All documents referring or relating to investments in Cornice and/or its products,
including but not limited to any investments rnade by Cornice’s founders (Kevin Magenis and
Curt Bruner), its management team (Magenis, Mike Wingert, Bruner, §IeiTE1berson, and Scott
Holt), Texas Instruments, CIBC Capital Partners, Nokia Venture Partners, VantagePoint Venture
Partners, BA Venture Partners, and GIC Special Investments Pte. Ltd.
REQUEST N0. 9:
All documents, including without limitation drawings, prototypes, notes, notebooks,
workbooks, proj ect reports, correspondence, memoranda, test results, schematics, engineering
specifications, CAD tiles, and simukation tiles in both hardcopy and electronic format that refer
or relate to the structure, function, design, research, development, testing, or simulation of any
accused product.
REQUEST NO. 10:
All documents that refer or relate to any modification, improvement, change, or any
proposed modification, improvement, or change, in any accused product, including attempts to
design or redesign products to avoid infringement of the ’i59, ’46l, ’506, ’754, ’054, ’845, and
*606 patents.
8

Case 1:04-cv-00418-SLR

Document 133-2

Filed 08/19/2005

Page 1 of 2

Case 1:04-cv-00418-SLR

Document 133-2

Filed 08/19/2005

Page 2 of 2