Exhibit 1 

Case 5:17-cv-00220-LHK Document 682-1 Filed 04/12/18 Page 1 of 8
CASE NO. 5:17-CV-00220

DEFENDANT QUALCOMM INCORPORATED’S SECOND SET OF INTERROGATORIES

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CRAVATH, SWAINE & MOORE LLP 

Gary A. Bornstein (pro hac vice) 

Yonatan Even (pro hac vice) 

825 Eighth Avenue 

New York, New York 10019-7475 

Telephone: (212) 474-1000 

Facsimile: (212) 474-3700 

KEKER, VAN NEST & PETERS LLP 

Robert A. Van Nest (SBN 84065) 

Asim M. Bhansali (SBN 194925) 

Eugene M. Paige (SBN 202849) 

633 Battery Street 

San Francisco, CA 94111-1809 

Telephone: (415) 391-5400 

Facsimile: (415) 397-7188 

Attorneys for Defendant, 

QUALCOMM INCORPORATED 

MORGAN, LEWIS & BOCKIUS LLP 

Richard S. Taffet (pro hac vice) 

101 Park Avenue 

New York, New York 10178-0060 

Telephone: (212) 309-6000 

Facsimile: (212) 309-6001 

MORGAN, LEWIS & BOCKIUS LLP 

Willard K. Tom (pro hac vice) 

1111 Pennsylvania Avenue NW 

Washington, DC 20004-2541 

Telephone: (202) 739-3000 

Facsimile: (202) 739 3001 

MORGAN, LEWIS & BOCKIUS LLP 

Donn P. Pickett (SBN 72257) 

Geoffrey T. Holtz (SBN 191370) 

One Market, Spear Street Tower 

San Francisco, CA 94105-1596 

Telephone: (415) 442-1000 

Facsimile: (415) 442-1001 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN JOSE DIVISION 

FEDERAL TRADE COMMISSION 

Plaintiff, 

v. 

QUALCOMM INCORPORATED, a 

Delaware corporation, 

Defendant. 

No. 5:17-CV-00220-LHK 

DEFENDANT QUALCOMM 

INCORPORATED’S SECOND SET 

OF INTERROGATORIES 

 

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Pursuant to Federal Rules of Civil Procedure 26 and 33, Defendant Qualcomm 

Incorporated hereby requests that Plaintiff answer the following interrogatories. 

INSTRUCTIONS 

1. A party’s full or abbreviated name or a pronoun referring to a party means the 

party and, where applicable, its officers, directors, employees, partners, corporate parent, 

subsidiaries or affiliates. This definition is not intended to impose a discovery obligation on any 

person who is not a party to the litigation. 

2. The wording of any interrogatory does not constitute an admission of what the 

facts or evidence will ultimately show. 

3. The following rules of construction shall apply to all interrogatories: 

a) The use of a verb in any tense shall be construed as the use of that verb in 

all other tenses; 

b) the use of a word in its singular form shall be deemed to include within its 

use the plural form; 

c) the connectives “and” and “or” shall be construed either disjunctively or 

conjunctively, whichever makes the interrogatory, definition, or 

instruction more inclusive; 

d) the terms “any,” and “each” shall be construed to encompass “all”; 

e) the term “including” means “including but not limited to”; and,

f) the use of the word “the” shall not be construed as limiting the scope of 

any interrogatory. 

4. These interrogatories are to be considered continuing in nature, and Plaintiff must 

promptly furnish supplemental responses if any additional responsive information is discovered 

or created after Plaintiff’s responses are tendered, or if any of Plaintiff’s responses are 

subsequently determined to be incorrect, incomplete, or misleading in any respect. 

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DEFINITIONS 

Notwithstanding any definition below, each word, term, or phrase used in these 

interrogatories is intended to have the broadest meaning permitted under the Federal Rules of 

Civil Procedure. 

A. The term “Apple” refers to Apple, Inc., with its principal place of business in 

Cupertino, California, United States, and its predecessors, successors, assigns and present and/or 

former affiliates and subsidiaries and any of its respective officers, directors, employees, agents, 

attorneys, representatives, or any other person acting or purporting to act on its behalf. 

B. The term “Baseband Processor” means any component that, when embedded 

within or connected to a Cellular Device, is capable of performing modulation and/or 

demodulation functions in connection with any portion of any wireless cellular communications 

transmission. 

C. The term “Cellular Communications Standard” means any wireless air interface 

standard that can be used in a wireless wide area communications network and that has been 

developed or adopted by a Standard-Setting Organization. 

D. The term “Cellular Device” means any device capable of implementing, without 

any additional equipment or components being attached or connected thereto, wireless 

communications transmissions in accordance with any Cellular Communications Standard. 

Examples of Cellular Devices include, without limitation, cellular phones and cellular-enabled 

tablets. 

E. The term “Complaint” means the Federal Trade Commission’s Complaint for 

Equitable Relief, filed January 17, 2017, in the Action, and any subsequent amendments or 

alterations thereto. 

F. The terms “FTC”, “You”, or “Your” mean the United States Federal Trade 

Commission, including its employees, agents, attorneys, consultants, representatives, and all 

other persons acting or purporting to act on its behalf. 

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G. The term “License” means authorization by a Patent holder to practice a claimed 

invention in whole or in part, including but not limited to covenants not to assert or to delay the 

assertion of any Patent. 

H. The term “Patent” means any patent issued in any jurisdiction. 

I. The term “Qualcomm” refers to Qualcomm Incorporated with its principal place 

of business in San Diego, California, United States, and its predecessors, successors, assigns and 

present and/or former affiliates and subsidiaries, and any of its respective officers, directors, 

employees, agents, attorneys, representatives, or any other person acting or purporting to act on 

its behalf. 

J. The term “Standard-Setting Organization” or “SSO” means any organization, 

group, joint venture, or consortium that develops standards for the design, performance, or other 

characteristics of cellular products or other technologies, including but not limited to the 

following organizations and their Related Persons: the 3rd Generation Partnership 

Project(“3GPP”); the Third Generation Partnership Project 2 (“3GPP2”); the American National 

Standards Institute (“ANSI”); the Association of Radio Industries and Businesses (“ARIB”); the 

Alliance for Telecommunications Industry Solutions (“ATIS”); the China Communications 

Standards Association (“CCSA”); the European Telecommunications Standards Institute 

(“ETSI”); the Institute of Electrical and Electronics Engineers, Inc., and the Institute of Electrical 

and Electronics Engineers Standards Association (“IEEE”); the International Telecommunication 

Unit’s Telecommunication Standardization Sector including the World Telecommunication 

Standardization Assembly and the Telecommunication Standardization Advisory Group (“ITU”); 

the Telecommunications Industry Association; the Telecommunications Standards Development 

Society, India (“TSDSI”); the Telecommunications Technology Association (“TTA”); and the 

Telecommunication Technology Committee (“TTC”); and each of their respective boards, 

societies, technical committees, special committees, including user groups, working groups, task 

groups, sponsor ballot or balloting groups, projects, councils, subcommittees, directors, officers, 

trustees, employees, attorneys, agents, consultants, representatives, predecessors, successors, 

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divisions, subsidiaries, affiliates, partnerships, and joint ventures, and the directors, officers, 

trustees, employees, attorneys, agents, consultants and representatives of its predecessors, 

successors, divisions, subsidiaries, affiliates, partnerships, and joint venture. 

 

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Eugene M. Paige 

KEKER, VAN NEST & PETERS LLP 

633 Battery Street 

San Francisco, CA 94111-1809 

Telephone: (415) 391-5400 

Facsimile: (415) 397-7188 

rvannest@kvn.com 

abhansali@kvn.com 

epaige@kvn.com 

Richard S. Taffet 

MORGAN, LEWIS & BOCKIUS LLP 

101 Park Avenue 

New York, NY 10178-0060 

Telephone: (212) 309-6000 

Willard K. Tom 

MORGAN LEWIS & BOCKIUS LLP 

1111 Pennsylvania Ave., N.W. 

Washington, D.C. 20004 

Telephone: (202) 739-3001 

Donn P. Pickett 

Geoffrey T. Holtz 

MORGAN, LEWIS & BOCKIUS LLP 

One Market, Spear Street Tower 

San Francisco, CA 94105-1596 

Telephone: (415) 442-1000 

Attorneys for Qualcomm Incorporated

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