Free Subpoena Returned Executed - District Court of Delaware - Delaware

Case 1 :04-cv-00360-JJF Document 76-2 Filed O1/24/2006 Page 1 of 2
Attachment A to Sabpoena to Artinion Group Holdings, Inc.
cio National Registered Agents, Inc.
160 Greentree Drive, Suite ltll, Dover, DE 19904
DEFINITIONS AND ll\lSTRUCTiC}NS
The following definitions are applicable to terms used in this Request:
A. "Tlie *870 patent" shall mean U.S. Patent: No. 5,“!74,870 entitled "Fully Integrated,
On~·Line Interactive Frequency and Award Redemption Program?
B. "Tlte '¢ll2 patent" shall mean U.S. Patent Nu. 6,009,412 entitled "Fully Integrated,
On~Line Interactive Frequency and Award Redemption Prograrn.*’
C. "Tlic '0l2 patcnt“ shall mean U.S. Patent No. 6,578,012 entitled "Fully Integrated,
On-Line Interactive Frequency and Award Redemption Prograinf
D. "Aftinion Group Holdings, lnc." 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 of Aflinion
Group Holdings, Inc.
E. The term "person" refers to n aturai p ersons, 0 rganizations, firms, c orporations,
and other legal entities, and the acts "of" a person are defined to include the acts of directors,
officers, owners, members, employees, agents, or attorneys acting on the person‘s behalf.
F, The term "document" has the meaning prescribed in Rule 34, Fed. R. Civ. P., and
includes the original and every nonpidentical copy or reproduction inthe possession, custody, or
control of plaintiff or known to plaintiff even though not actually in the possession of plaintiff.
The term "document" includes computer files stored in electronic forrn, including without
limitation e-mail, as well as other data compilations.
G. The terms "and" and "or" shall he construed conjunctively and disjunctively so as
to have the broadest possible meaning.
H. Where appropriate, the Singular {own ot` a word shall be interpreteti in the plural,
and vice versa, to have the broadest possible meaning.
L. "Patents" shall mean the ‘870, 'él2 and '012 patents.

Case 1 :04-cv-00360-JJF Document 76-2 Filed O1/24/2006 Page 2 of 2
PRODUCTION REQUESTS
1. Atl documents reviewed during due diligence for or prepared in connection with
that certain acquisition by Aftinion Group Holdings, Inc. of the assets ofthe Cendant Marketing
Bivision o t` Cendant Corp. that refer, relate to, or evidence the value of *370, *112, and ‘0t2
patents, inctading but not iiinited to value for acquisition, transfer pricing, and for depreciation
and amortization purposes.
2. All documents reviewed during due diligence for or prepared in connection with
that certain acquisition by Afiinion Group Holdings, inc. ofthe assets of the Cendant Marketing
Division of Cendant Corp. that refer, relate to or evidence the infringement, invalidity, or
enforceability of the 'STO, ‘4i2 and ‘0l2 patents.
3. Ali documents reviewed during due diligence for or prepared in connection with
that certain acquisition by Affinion Group Hoidiiigs, Inc. uf the assets of the Cendant Marketing
Division ofthe 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 limited to the terms
thereof and the value thereof.
4. All documents reviewed during due diligence for or prepared in connection with
that certain acquisition by Affinion Group Holdings, Inc. of thc assets of the Cendant Marketing
Division of Cedant Corp. that refer, relate to or evidence any license granted on or njifer
Ctctolierl'7, 2005 for the '870, '4i2, and '0l2 patents the terrns thereof, and the value thereof,

Case 1:04-cv-00360-JJF

Document 76-2

Filed 01/24/2006

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Case 1:04-cv-00360-JJF

Document 76-2

Filed 01/24/2006

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