Free Subpoena Returned Executed - District Court of Delaware - Delaware


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Date: December 31, 1969
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State: Delaware
Category: District Court of Delaware
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Case 1 :04-cv-00360-JJF Document 78-2 Filed O1/24/2006 Page 1 of 2
Attachment A to Subpoena to Affinion Group, Inc.,
cio National Registered Agents, inc.,
160 Greentree Drive, Suite l0l, Dover, DE 19904
DEFENITIONS AND INSTRUCTIONS
The following definitions are applicable to terms used in this Request:
A. "The '870 patent" shalt mean U.S. Patent No. 5,774,870 entitled "Fnlly Integrated,
On—Line interactive Frequency and Award Redemption ?rogram."
B. "The '4§2 patent" shall mean U.S. Patent No. 6,009,412 entitled "Fuily integrated,
Online Interactive Frequency and Award Redemption Prograrn."
C. "The '0i2 patent" siiall mean U.S. Patent No. 6,5'78,0l2 entitled "Fully irrtegratetl,
On—i.ine Interactive Frequency and Award Redemption Prograin."
D. "AGII, Inc." includes the Company and any predecessor, successor, division,
parent, subsidiary, related company or affiliate and all present or former officers, directors,
agents, representatives, employees, and attorneys acting on behalf ofAGH, inc.
E. The term "person" refers to natural p ersous, o rganizations, firms, c orporations,
and other legal entities, and the acts "ot" a person are defined to include the acts of directors,
officers, owners, members, employees, agents, or attorneys acting on thc pcrsoifs behalf
F. The term "docurnent" has the meaning prescribed in Rule 34, Fed. R. Civ. P., and
includes the original and every nonddentical copy or reproduction in the possession, custody, or
control of plaintiff or known to plaintiff even though not actually in the possession of plaintiff.
The terrn "document" includes computer files stored in electronic form, including without
limitation e~mail, as well as other data compilations.
G. The terms "and" and "or" shall be construed conjunctively and disjtrnctively so as
to have the broadest possible meaning.
H. Where appropriate, the singular form of a word shall be interpreted in the plural,
and vice versa, to have the broadest possible meaning.
L. "Patents" shall mean the '870, '4l2 and '012 patents.

Case 1 :04-cv-00360-JJF Document 78-2 Filed O1/24/2006 Page 2 of 2
PRODUCTION REQUESTS
i. All documents reviewed during due diiigence for or prepared in connection with
that certain acquisition by Aftinion Group, Inc., of the assets of the Cendant Marketing Division
of Cendant Corp. that refer, relate to, or evidence the value of '870, *412, and ‘0i2 patents,
inciuding but not limited to value for acquisition purposes, tor transler pricing purposes, and tor
depreciation and arnortization purposes.
2. Ali documents reviewed during due diligence for or prepared in connection with
that certain acquisition by Aftinion Group, inc. ofthe assets of the Cendant Marketing Division
of Cendant Corp. that refer, reiate to or evidence the infringement, invaiidity, or enforceability of
the ’870, '412 and '0l2 patents.
3. All documents reviewed during due diligence for or prepared in connection with
that certain acquisition by AE`i`ir1ion Group, inc. of the assets of the Cendant Marketing Division
of tire Cendant Corp. that refer, relate to or evidence any license, granted prior to October 17,
2005 for the '870, '4i2, and '0l2 patents, including but not iirnited to the tenns thereof and the
vaiue thereof.
4. All documents reviewed during due diiigence for or prepared in connection with
that certain acquisition by Afiinion Group, Inc. of the assets of the Cendant Marketing Division
of CedantCo1·p. that refer, relate to or evidence any license granted on or after C}ctoberl7, 2005
for the *870, '4l2, and '0i2 patents the terrns thereof, and the value thereoti

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