EXHIBIT B

Case 2:23-cv-00285-JRG-RSP Document 44-3 Filed 03/07/24 Page 1 of 24 PageID #: 568
CT Corporation

Service of Process Notification

02/14/2024

CT Log Number 545759075

Service of Process Transmittal Summary

TO: Ken Murata, Senior Legal Counsel

SAMSUNG ELECTRONICS AMERICA, INC.

85 Challenger Rd Fl 7

Ridgefield Park, NJ 07660-2118

RE: Process Served in Texas

FOR: Samsung Electronics America, Inc.  (Domestic State: NY)

Page 1 of  2

ENCLOSED ARE COPIES OF LEGAL PROCESS RECEIVED BY THE STATUTORY AGENT OF THE ABOVE COMPANY AS FOLLOWS:

 

TITLE OF ACTION: Cobblestone Wireless, LLC vs. Cellco Partnership

CASE #: 223CV00382JRGRSP

NATURE OF ACTION: Subpoena - Business records

PROCESS SERVED ON: C T Corporation System, Dallas, TX

DATE/METHOD OF SERVICE: By Process Server on 02/14/2024 at 11:59

JURISDICTION SERVED: Texas

ACTION ITEMS: SOP Papers with Transmittal, via  UPS Next Day Air , 1ZX212780104141521

Image SOP

Email Notification,  Ken Murata  ken.murata@sea.samsung.com

Email Notification,  Christopher Low  clow@sea.samsung.com

Email Notification,  Alessandra Schneider  alessandra.s@sea.samsung.com

Email Notification,  Richard Rosalez  r.rosalez@sea.samsung.com

Email Notification,  Michael Sharples  m.sharples@sea.samsung.com

Email Notification,  Jordan Flournoy  j.flournoy@sea.samsung.com

Email Notification,  Jae Cha  jw915.cha@sea.samsung.com

Email Notification,  Simone Silva-Arrindell  s.silva-arri@sea.samsung.com

Email Notification,  Brittany McElmury Dietz  b.dietz@sea.samsung.com

Email Notification,  Josue Caballero  j.caballero@sea.samsung.com

Email Notification,  Gabriel Ramos  g.ramos@partner.sea.samsung.com

REGISTERED AGENT CONTACT: C T Corporation System

1999 Bryan Street

Suite 900

Dallas, TX 75201

866-401-8252

LargeCorporationTeam@wolterskluwer.com

The information contained in this Transmittal is provided by CT for quick reference only. It does not constitute a legal opinion,

and should not otherwise be relied on, as to the nature of action, the amount of damages, the answer date, or any other

Case 2:23-cv-00285-JRG-RSP Document 44-3 Filed 03/07/24 Page 2 of 24 PageID #: 569
CT Corporation

Service of Process Notification

02/14/2024

CT Log Number 545759075

Page 2 of  2

information contained in the included documents. The recipient(s) of this form is responsible for reviewing and interpreting the

included documents and taking appropriate action, including consulting with its legal and other advisors as necessary. CT

disclaims all liability for the information contained in this form, including for any omissions or inaccuracies that may be

contained therein.

Case 2:23-cv-00285-JRG-RSP Document 44-3 Filed 03/07/24 Page 3 of 24 PageID #: 570
Date:

Server Name:

PROCESS SERVER DELIVERY DETAILS

Wed, Feb 14, 2024

kim shaw

Wolters Kluwer

Entity Served SAMSUNG ELECTRONICS AMERICA, INC.

Case Number 2:23-cv-00382-JRG-RSP

J urisdiction TX

Inserts

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AO 88B (Rev. 06/09) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action

UNITED STATES DISTRICT COURT

for the

Eastern District of Texas

Cobblestone Wireless, LLC

Plaintiff

V.

Cellco Partnership d/b/a Verizon Wireless

Defendant

Civil Action No. 2:23-cv-00382-JRG-RSP

Consolidated (Lead Case)

(If the action is pending in another district, state where:

SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS

OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION

To: Samsung Electronics America, Inc.

c/o C T Corporation System, 1999 Bryan St., Ste. 900, Dallas, Texas 75201-3136

Pr Production: YOU ARE COMMANDED to produce at the time, date, and place set forth below the following

documents, electronically stored information, or objects, and permit their inspection, copying, testing, or sampling of the

material: See Attachment A.

Place: Veritext, 600 N. Pearl St. Suite 2230 Dallas, TX 75201

alternatively, remote video conference (or at a mutually

agreeable place) 

Date and Time:

3/4/24 at 9 a.m. CT (or a mutually agreeable time)

0Inspection of Premises: YOU ARE COMMANDED to permit entry onto the designated premises, land, or

other property possessed or controlled by you at the time, date, and location set forth below, so that the requesting party

may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it.

Place: Date and Time:

The provisions of Fed. R. Civ. P. 45(c), relating to your protection as a person subject to a subpoena, and Rule

45 (d) and (e), relating to your duty to respond to this subpoena and the potential consequences of not doing so, are

attached.

Date: 02/13/2024

CLERK OF COURT

OR

/s/ Jonathan Ma

Signature of Clerk or Deputy Clerk Attorney's signature

The name, address, e-mail, and telephone number of the attorney representing (name of party)

Plaintiff Cobblestone' Wireless, LLC , who issues or requests this subpoena, are:

Jonathan Ma, jma@ raklaw.com, 310-826-7474

Russ August & Kabat, 12424 Wilshire Boulevard, 12th Floor, Los Angeles, CA 90025

Case 2:23-cv-00285-JRG-RSP Document 44-3 Filed 03/07/24 Page 5 of 24 PageID #: 572
AO 88B (Rev. 06/09) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action (Page 2)

Civil Action No. 2:23-cv-00382-JRG-RSP

PROOF OF SERVICE

(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)

This subpoena for (name of individual and title, if any)

was received by me on (date)

CI I served the subpoena by delivering a copy to the named person as follows:

CI I returned the subpoena unexecuted because:

on (date) ; or

Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also

tendered to the witness fees for one day's attendance, and the mileage allowed by law, in the amount of

My fees are $

Date:

for travel and $ for services, for a total of $

I declare under penalty of perjury that this information is true.

0.00

Server's signature

Printed name and title

Additional information regarding attempted service, etc:

Server's address

IIMMMINSWINOMI IIWWWWWRIRWM.1111

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AO 88B (Rev. 06/09) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action(Page 3)

Federal Rule of Civil Procedure 45 (c), (d), and (e) (Effective 12/1/07)

(c) Protecting a Person Subject to a Subpoena.

(1) Avoiding Undue Burden or Expense; Sanctions. A party or

attorney responsible for issuing and serving a subpoena must take

reasonable steps to avoid imposing undue burden or expense on a

person subject to the subpoena. The issuing court must enforce this

duty and impose an appropriate sanction — which may include lost

earnings and reasonable attorney's fees — on a party or attorney

who fails to comply.

(2) Command to Produce Materials or Permit Inspection.

(A) Appearance Not Required. A person commanded to produce

documents, electronically stored information, or tangible things, or

to permit the inspection of premises, need not appear in person at the

place of production or inspection unless also commanded to appear

for a deposition, hearing, or trial.

(B) Objections. A person commanded to produce documents or

tangible things or to permit inspection may serve on the party or

attorney designated in the subpoena a written objection to

inspecting, copying, testing or sampling any or all of the materials or

to inspecting the premises — or to producing electronically stored

information in the form or forms requested. The objection must be

served before the earlier of the time specified for compliance or 14

days after the subpoena is served. If an objection is made, the

following rules apply:

(i) At any time, on notice to the commanded person, the serving

party may move the issuing court for an order compelling production

or inspection.

(ii) These acts may be required only as directed in the order, and

the order must protect a person who is neither a party nor a party's

officer from significant expense resulting from compliance.

(3) Quashing or Modifying a Subpoena.

(A) When Required. On timely motion, the issuing court must

quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person who is neither a party nor a party's officer

to travel more than 100 miles from where that person resides, is

employed, or regularly transacts business in person — except that,

subject to Rule 45(c)(3)(B)(iii), the person may be commanded to

attend a trial by traveling from any such place within the state where

the trial is held;

(iii) requires disclosure of privileged or other protected matter, if

no exception or waiver applies; or

(iv) subjects a person to undue burden.

(B) When Permitted. To protect a person subject to or affected by

a subpoena, the issuing court may, on motion, quash or modify the

subpoena if it requires:

(i) disclosing a trade secret or other confidential research,

development, or commercial information;

(ii) disclosing an unretained expert's opinion or information that

does not describe specific occurrences in dispute and results from

the expert's study that was not requested by a party; or

(iii) a person who is neither a party nor a party's officer to incur

substantial expense to travel more than 100 miles to attend trial.

(C) Specifying Conditions as an Alternative. In the circumstances

described in Rule 45(c)(3)(B), the court may, instead of quashing or

modifying a subpoena, order appearance or production under

specified conditions if the serving party:

(i) shows a substantial need for the testimony or material that

cannot be otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably

compensated.

(d) Duties in Responding to a Subpoena.

(1) Producing Documents or Electronically Stored Information.

These procedures apply to producing documents or electronically

stored information:

(A) Documents. A person responding to a subpoena to produce

documents must produce them as they are kept in the ordinary

course of business or must organize and label them to correspond to

the categories in the demand.

(B) Form for Producing Electronically Stored Information Not

Specified. If a subpoena does not specify a form for producing

electronically stored information, the person responding must

produce it in a form or forms in which it is ordinarily maintained or

in a reasonably usable form or forms.

(C) Electronically Stored Information Produced in Only One

Form. The person responding need not produce the same

electronically stored information in more than one form.

(D) Inaccessible Electronically Stored Information. The person

responding need not provide discovery of electronically stored

information from sources that the person identifies as not reasonably

accessible because of undue burden or cost. On motion to compel

discovery or for a protective order, the person responding must show

that the information is not reasonably accessible because of undue

burden or cost. If that showing is made, the court may nonetheless

order discovery from such sources if the requesting party shows

good cause, considering the limitations of Rule 26(b)(2)(C). The

court may specify conditions for the discovery.

(2) Claiming Privilege or Protection.

(A) Information Withheld. A person withholding subpoenaed

information under a claim that it is privileged or subject to

protection as trial-preparation material must:

(i) expressly make the claim; and

(ii) describe the nature of the withheld documents,

communications, or tangible things in a manner that, without

revealing information itself privileged or protected, will enable the

parties to assess the claim.

(B) Information Produced. If information produced in response to a

subpoena is subject to a claim of privilege or of protection as trialpreparation material, the person making the claim may notify any

party that received the information of the claim and the basis for it.

After being notified, a party must promptly return, sequester, or

destroy the specified information and any copies it has; must not use

or disclose the information until the claim is resolved; must take

reasonable steps to retrieve the information if the party disclosed it

before being notified; and may promptly present the information to

the court under seal for a determination of the claim. The person

who produced the information must preserve the information until

the claim is resolved.

(e) Contempt. The issuing court may hold in contempt a person

who, having been served, fails without adequate excuse to obey the

subpoena. A nonparty's failure to obey must be excused if the

subpoena purports to require the nonparty to attend or produce at a

place outside the limits of Rule 45(c)(3)(A)(ii).

Case 2:23-cv-00285-JRG-RSP Document 44-3 Filed 03/07/24 Page 7 of 24 PageID #: 574
ATTACHMENT A 

DEFINITIONS 

The following definitions and instructions apply to the document requests and deposition topics

set forth in subsequent sections:

1. "You," "your," and "Samsung" mean Samsung Electronics America, Inc., and any

present and former agents, officers, directors, employees, affiliates, investigators, trustees,

consultants, advisors, accountants, attorneys and all other persons or entities acting or purporting

to act on your behalf, and your affiliates, parents, divisions, joint ventures, licensees, franchisees,

assigns, predecessors and successors in interest, and any other legal entities, whether foreign or

domestic, that are owned or controlled by you.

2. The term "AT&T," means AT&T Services, Inc., AT&T Mobility LLC, and AT&T

Corp., individually, and collectively, including (i) all of their current and past officers, directors,

agents, employees, consultants, attorneys, and others acting or purporting to act on behalf of it,

and (ii) all of their predecessors, subsidiaries, parents, affiliates, and successors.

3. The term "T-Mobile," means T-Mobile USA, Inc., including (i) all of its current

and past officers, directors, agents, employees, consultants, attorneys, and others acting or

purporting to act on behalf of it, and (ii) all of its predecessors, subsidiaries, parents, affiliates, and

successors.

4. The term "Verizon," means Cellco Partnership d/b/a Verizon Wireless, including

(i) all of its current and past officers, directors, agents, employees, consultants, attorneys, and

others acting or purporting to act on behalf of it, and (ii) all of its predecessors, subsidiaries,

parents, affiliates, and successors.

1

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5. The term "Ericsson," means Ericsson Inc., including (i) all of its current and past

officers, directors, agents, employees, consultants, attorneys, and others acting or purporting to act

on behalf of it, and (ii) all of its predecessors, subsidiaries, parents, affiliates, and successors.

6. The term "Nokia," means Nokia of America Corporation, including (i) all of its

current and past officers, directors, agents, employees, consultants, attorneys, and others acting or

purporting to act on behalf of it, and (ii) all of its predecessors, subsidiaries, parents, affiliates, and

successors.

7. The term "Defendant Group," means the group of commonly accused Defendants

identified in a single complaint, i.e., the AT&T Defendant Group is AT&T Corp., AT&T Mobility

LLC, and AT&T Services, Inc., including each of its members individually and collectively..

Should any parties intervene, the intervening party will constitute its own Defendant Group

("Intervenor Group").

8. The term "Intervenor Group," means the group of Intervenors identified in a single

complaint, i.e., the Ericsson Intervenor Group is Ericsson Inc., including each of its members

individually and collectively.

9. The term "document" includes "originals" and "duplicates" and has the same

meaning as the term "writings and recordings" and "photographs" as defined in Rules 1001(1) and

(2) of the Federal Rules of Evidence, whether or not claimed to be privileged against discovery on

any ground, and specifically including, but not limited to, correspondence, agreements, and

communications; dealer-customer, inter-company and intra-company communications; studies,

surveys, reports, analyses or projections; announcements, declarations, notices, releases and

publicity; telegrams; notes and memoranda; summaries; minutes and records of telephone

conversations, meetings and conferences including lists of persons attending meetings or

2

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conferences; summaries and records of personal conversations or interviews; financial records

including bills, receipts, ledgers, invoices, bank statements and canceled checks; books, manuals,

and publications; telexes or cables prepared, drafted, received or sent; calendars or diaries; charts,

plans, sketches and drawings; photographs, reports, and/or summaries of investigations and/or

surveys; opinions, notes and reports of consultants; opinions of counsel; reports and summaries of

negotiations; any other reports or summaries; agreements, contracts, memoranda of understanding,

letters of intent, licenses and assignments; brochures, pamphlets, catalogs, catalog sheets,

advertisements (including promotional materials), fliers, announcements, posters, signs, story

boards, and scripts, audio and video recordings of radio and television commercials; circulars and

trade letters; information contained in any medium now known or hereafter devised including

without limitation information contained on computer tape, card, disc or program or information

taking the form of or implemented as computer code or source code; and any other paper, writing

or physical thing which contains the requested information. Any document that contains any

comment, notation, addition, deletion, insertion or marking of any kind, which is not part of

another document, is a separate document.

10. The terms "original" and "duplicate" are defined in Rules 1001(3) and (4) of the

Federal Rules of Evidence, as follows: "Original" means the writing itself or any counterpart

intended to have the same effect by a person executing or issuing it. An "original" of a photograph

includes the negative or any print therefrom. If data is stored in a computer or similar device, any

printout or other output readable by sight, shown to reflect the data accurately, is an "original." A

"duplicate" is a counterpart produced by the same impression as the original, or from the same

matrix, or by means of photographs, including enlargements and miniatures, or by mechanical or

3

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electronic re-recording, or by chemical reproduction, or by other equivalent techniques, that

accurately reproduces the original.

1 1. The term "correspondence" refers to and includes each and every communication,

letter, copy of a letter, telegram, e-mail, text message, record or notation, or any conversation,

inter-office memorandum or any other similar writing.

12. The terms "relate," "relates to," "related to," or "relating to" shall mean all

documents and things having any logical or factual connection, directly or indirectly, with the

matter discussed and shall mean any one or more of the following: evidencing, referring to,

discussing, describing, concerning, mentioning, reflecting, depicting, summarizing, involving,

regarding, embodying, containing, pertaining to, arising out of or is in connection with.

13. The term "evidence" means testimony, writings, material objects, or other things

presented to the senses that could be offered to prove the existence or nonexistence of a fact.

14. The terms "person" or "persons" mean and include natural persons, corporations,

companies, limited liability companies, partnerships, limited partnerships, associations,

organizations, joint ventures, groups, government bodies or agencies, legal entities or any other

cognizable entities.

15. The term "communication" means any oral or written transmission of information

between persons, including but not limited to, meetings, discussion, conversations, telephone calls,

memoranda, letters, telecopies, telexes, conferences or seminars.

16. The term "Asserted Patent" or "patent-in-suit" means U.S. Patent Nos. 7,924,802

(the '802 Patent").

4

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17. The term "802 Accused Products" refers to (a) all of your cellular base stations

that support 3GPP carrier aggregation and (b) all user equipment that is used on your cellular

network and that supports 3GPP carrier aggregation, in each case including but not limited to

those products identified by Plaintiff as those alleged to infringe any one or more of the Asserted

Patents, including those described in the Complaint or identified in Plaintiff's operative

infringement contentions (inclusive of any subsequent amendments or supplements thereto)

served in this case, that you currently make, use, sell, offer for sale, import into the United States,

sell for importation within the United States, and/or sell after importation into the United States or

that you have made, used, sold, offered for sale, imported into the United States, sold for

importation within the United States, and/or sold after importation into the United States, and

similar products, since June 16, 2017.

18. The term "Relevant Component" refers to all systems, sub-systems, components,

devices, features, software, applications, services, versions, releases, apparatuses, methods,

processes, and similar that comprise and/or are used by any product that relate to any claimed

inventions of any of the patent-in-suit, including but not limited to 3GPP carrier

aggregation.

19. The term "Asserted Claims" refers to the claims the Accused Products are accused

of infringing in the operative infringement contentions (inclusive of any subsequent amendments

or supplements thereto). Asserted Claim refers individually to one of the Asserted Claims.

20. When referring to a person, "identify" means give, to the extent known, the

person's full name, present or last known address, and when referring to a natural person,

additionally, the present or last known place of employment. One you identify a person in

5

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accordance with this paragraph, only the name of that person need be listed in response to

subsequent discovery requesting the identification of that person.

26. When referring to documents, "to identify" means to provide, to the extent known,

the: (i) type of document; (ii) general subject matter; (iii) date of the document; (iv) location(s)

where documents is stored; and (v) author(s), addressee(s) and recipient(s).

27. The term "concerning" means relating to, referring to, describing, evidencing, or

constituting.

28. The terms "all" and "each" when used individually shall be construed as both all

and each.

29. The term "including" means "including but not limited to."

30. The term "affiliate" means any corporation or entity related through corporate

ownership of stock such as a parent, subsidiary or sister company, or through common directors,

officers, and employees, either at the present time or at any time in the past.

31. The term "products" refers to, without limitation, all products, components,

methods, functionalities, processes, and/or services that are or were under development or planned

to be developed.

32. Any word written in the singular shall be construed as plural or vice versa in order

to bring within the scope of the topic all responses that otherwise might be construed to be outside

its scope.

33. If you find the meaning of any term in these topics or document requests unclear,

then you shall construe the term so as to render responsive any information, document, thing, or

communication that might otherwise be rendered non-responsive.

6

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34. In the event you refuse to fully respond to a deposition topic or document request

because it is overly broad or unduly burdensome, you shall at least respond to that portion of the

request that is unobjectionable and specifically identify that portion of the request that is allegedly

objectionable.

DOCUMENTS 

REQUEST NO.!:

Documents sufficient to identify and describe each of Your cellular base stations that

supports 3GPP carrier aggregation, including but not limited including at least eachbase stations'

name, location, manufacturer(s), internal and external model(s), part(s), andversionnumber(s),

development names, proj ect names, marketing and brand names, andany otherde signation or

nomenclature used by You to identify the cellularbase station, and including planned variations,

that You currently make, use, sell, offer for sale, import into the United States, sell for

importation within the United States, and/or sell after importation into the United States or that

you have made, used, sold, offered for sale, imported into the United States, sold for importation

within the United States, and/or sold after importation into the United States, and similar

products, in relation to AT&T, T-Mobile, and/or Verizon since June 16, 2017.

REQUEST NO. 2:

Documents sufficient to identify and describe each user equipment device made, used, sold,

offered for sale, imported by You into the United States, sold for importation within with the

United States, and/or sold after importation into the United States, in relation to AT&T, TMobile, and/or Verizon, since June 16, 2017, which supports LTE or 5G NR carrier aggregation,

including at

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least each product's name, internal and external model, part, and version number(s), development

names, project names, marketing and brand names, and any other designation or

nomenclature used by You to identify the user equipment device, and including planned

variations.

REQUEST NO. 3:

For each cellular base station and/or user equipment device in relation to Request Nos.

1 and/or 2, Documents sufficient to identify and describe each Relevant Component,

including at least each Relevant Component's name, internal and external model, part, and

version number(s), development names, project names, marketing and brand names, and

any other designation or nomenclature used by You to identify the component, including

the identity of each baseband processor and the identity of the specific firmware version

loaded on each baseband processor (e.g., in the case of Qualcomm baseband processors, the

Build ID sufficient to allow Qualcomm to identify corresponding source code), and including

planned variations.

REQUEST NO. 4:

Technical documents relating to each of the Accused Products sufficient to show design,

engineering, development, manufacturing, operation and use.

REQUEST NO. 5:

Technical documents relating to each Relevant Component of the Accused Products

sufficient to show design, engineering, development, manufacturing, operation and use.

REQUEST NO. 6:

Technical documents relating to the Accused Products and/or Relevant Component and

LTE or 5G carrier aggregation sufficient to show design, engineering, development,

manufacturing, operation and use.

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REQUEST NO. 8:

Documents relating to the Accused Products and/or Relevant Components' compliance or

non-compliance with 3GPP and/or LTE standards, including without limitation development

testing and compliance testing.

REQUEST NO. 9:

Documents sufficient to show implementation specific

functionalities of the Relevant Components regarding LTE or 5G carrier aggregation.

REQUEST NO. 10

Your participation with any standards bodies relating to LTE

or 5G carrier aggregation.

REQUEST NO. 11:

Source code (e.g., C, C++, Java, Hardware Design Language (HDL), Verilog HDL,

VHDL, Assembly, etc., including without limitation all types of code or files that implement,

prepare for, design, or result in. any software, firmware, hardware, or other functionalities,

including functionalities of integrated circuits, processors, chips, chipsets, systems, or

computers) relating to the Relevant Components of each of the Accused Products sufficient to

show design, engineering, development, manufacturing, operation and use.

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REQUEST NO. 12:

Documents sufficient to show the arrangement, assembly, and connection of the

Relevant Components in each accused product, including for example schematics, diagrams,

flowcharts, specifications, source code, design documents, engineering documents, testing

documents, data sheets, and other technical documentation for each Accused Product.

REQUEST NO. 13:

End-user documentation for each Accused Product as sold in the United States,

including but not limited to user manuals, product manuals, instruction manuals, service

manuals, and installation instructions.

REQUEST NO. 14:

Documents sufficient to show the naming conventions used in Your model

numbers, including the format and meaning of internal and external model numbers, or other

identifiers, of the Accused Products.

REQUEST NO. 15:

All documents relating to agreements, contracts, or licenses involving LTE or 5G carrier

aggregation capabilities in the Accused Products and/or Relevant Components, including, but not

limited to, any agreement, contract, or license concerning the design, development, manufacture,

assembly, sale, distribution, importation, and/or service of any of the Accused Products or

components thereof.

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REQUEST NO. 16:

All documents related to Your relationship between You and any

Defendants or Intervenors, including but not limited to all agreements, all

communications relating to such agreements, including relating to indemnification.

REQUEST NO. 17:

All Documents and Things in your possession, custody, or control relating to Plaintiff, the

Asserted Patents, or the named inventors of the Asserted Patents.

REQUEST NO. 18:

Your advertising and marketing of any Relevant Component sold by You

to each Defendant Group.

REQUEST NO. 20:

The number of each Accused Product and/or Relevant Component sold to AT&T,

T-Mobile, and/or Verizon since the issuance of the Asserted Patents.

REQUEST NO. 21:

Price, costs, revenues, and profits that You obtain or charge to AT&T, T-Mobile, and/or

Verizon for any Accused Product and/or Relevant Component, including Your gross sales price

for the Accused Product and/or Relevant Component, Your costs of goods sold (including Your

manufacturing costs, sales costs, and all other costs of goods sold).

REQUEST NO. 22:

Your efforts to obtain certifications for the LTE or 5G carrier aggregation fimctionalities

of the Relevant Components.

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DEPOSITION TOPICS 

DEPOSITION TOPIC NO.!:

Your cellular base stations that support LTE or 5G carrier aggregation, including

but not limited including at least each base stations' name, location, manufacturer(s),

internal and external model(s), part(s), and version number(s), development names,

project names, marketing and brand names, and any other designation or nomenclature

used by You to identify the cellular base station, and including planned variations, that

You currently make, use, sell, offer for sale, import into the United States, sell for importation

within the United States, and/or sell after importation into the United States or that you have

made, used, sold, offered for sale, imported into the United States, sold for importation within

the United States, and/or sold after importation into the United States, and similar

products, in relation to AT&T, T-Mobile, and/or Verizon since June 16, 2017.

Case 2:23-cv-00285-JRG-RSP Document 44-3 Filed 03/07/24 Page 19 of 24 PageID #: 586
DEPOSITION TOPIC NO. 2:

Each user equipment device made, used, sold, offered for sale, imported by You into the

United States, sold for importation within with the United States, and/or sold after importation into

the United States, in relation to AT&T, T-Mobile, and/or Verizon, since December 16,

2016, which supports LTE or 5G carrier aggregation, including at least each product's name,

internal and external model, part, and version number(s), development names, project names,

marketing and brand names, and any other designation or nomenclature used by You

to identify the user equipment device, and including planned variations.

DEPOSITION TOPIC NO. 3:

Each cellular product made, used, sold, offered for sale, imported by You into the United

States, sold for importation within with the United States, and/or sold after importation into the

United States, in relation to AT&T, T-Mobile, and/or Verizon, since December 16, 2016,

which includes an Android operating system and supports LTE or 5G carrier aggregation,

including at least each product's name, internal and external model, part, and version number(s),

development names, project names, marketing and brand names, and any other designation

or nomenclature used by Respondent to identify the cellular product, and including planned

variations.

DEPOSITION TOPIC NO. 4:

For each cellular base station and/or user equipment device in relation to Deposition

Topic Nos. 1 and/or 2, each Relevant Component, including at least each Relevant Component's

name, internal and external model, part, and version number(s), development names, project

names, marketing and brand names, and any other designation or nomenclature used by You to

identify the component, including the identity of each baseband processor and the identity of the

specific firmware version loaded on each baseband processor (e.g., in the case of Qualcomm

baseband

Case 2:23-cv-00285-JRG-RSP Document 44-3 Filed 03/07/24 Page 20 of 24 PageID #: 587
processors, the Build ID sufficient to allow Qualconun to identify corresponding source code) and

including planned variations.

DEPOSITION TOPIC NO. 5:

The design, engineering, development, manufacturing, operation and use of each Accused

Product.

DEPOSITION TOPIC NO. 6:

The design, engineering, development, manufacturing, operation and use of each Relevant

Component of the Accused Products.

DEPOSITION TOPIC NO. 7:

The design, engineering, development, manufacturing, operation and use of each Accused

Products and/or Relevant Component in relation to LTE or 5G carrier aggregation.

DEPOSITION TOPIC NO. 8:

Any implementation-specific functionalities of the Relevant Components regarding LTE

or 5G carrier aggregation.

DEPOSITION TOPIC NO. 9:

Your participation with any standards bodies relating to LTE or 5G carrier aggregation.

DEPOSITION TOPIC NO. lb:

Source code (e.g., C, C++, Java, Hardware Design Language (HDL), Verilog HDL,

VHDL, Assembly, etc., including without limitation all types of code or files that implement,

prepare for, design, or result in any software, firmware, hardware, or other functionalities,

including functionalities of integrated circuits, processors, chips, chipsets, systems, or

computers) relating to the Relevant Components of each of the Accused Products sufficient to

show design, engineering, development, manufacturing, operation and use.

Case 2:23-cv-00285-JRG-RSP Document 44-3 Filed 03/07/24 Page 21 of 24 PageID #: 588
DEPOSITION TOPIC NO. 11:

The arrangement, assembly, and connection of the Relevant Components in each

accused product, including for example schematics, diagrams, flowcharts, specifications,

source code, design information, engineering information, testing information, data sheets, and

other technical documentation for each Accused Product.

DEPOSITION TOPIC NO. 12:

End-user information for each Accused Product as sold in the United States, including but

not limited to user manuals, product manuals, instruction manuals, service

manuals, and installation instructions.

DEPOSITION TOPIC NO. 13:

The naming conventions used in Your model numbers, including the format and

meaning of internal and external model numbers, or other identifiers, of the Accused Products.

DEPOSITION TOPIC NO. 14:

Agreements, contracts, or licenses involving the LTE or 5G carrier aggregation in

the Accused Products and/or Relevant Components, including, but not limited to, any

agreement, contract, or license concerning the design, development, manufacture, assembly, sale,

distribution, importation, and/or service of any of the Accused Products or components thereof.

Case 2:23-cv-00285-JRG-RSP Document 44-3 Filed 03/07/24 Page 22 of 24 PageID #: 589
DEPOSITION TOPIC NO. 15:

Your relationship between You and any Defendants or Intervenors, including but

not limited to all agreements, all communications relating to such agreements, including

relating to indemnification.

DEPOSITION TOPIC NO. 16:

Your knowledge of Plaintiff, the Asserted Patents, or the named inventors of the

Asserted Patents.

DEPOSITION TOPIC NO. 17:

Your advertising and marketing of any Relevant Component sold by You to

each Defendant Group.

DEPOSITION TOPIC NO. 18:

Your knowledge of the Accused Products and/or Relevant Components' compliance

or non-compliance with the LTE or 5G standards, including without limitation

development testing and compliance testing.

DEPOSITION TOPIC NO. 19:

The number of each Accused Product and/or Relevant Component sold to AT&T,

T-Mobile, and/or Verizon since the issuance of the Asserted Patents.

DEPOSITION TOPIC NO. 20:

Price, costs, revenues, and profits that You obtain or charge to AT&T, T-Mobile, and/

or Verizon for any Accused Product and/or Relevant Component, including Your gross sales

price

19

Case 2:23-cv-00285-JRG-RSP Document 44-3 Filed 03/07/24 Page 23 of 24 PageID #: 590
for the Accused Product and/or Relevant Component, Your costs of goods sold (including Your

manufacturing costs, sales costs, and all other costs of goods sold).

DEPOSITION TOPIC NO. 21:

Your efforts to obtain certifications for the LTE or 5G carrier aggregation

functionalities of the Relevant Components.

DEPOSITION TOPIC NO. 22:

All Documents and Things produced by You in response to the Document Subpoenas.

DEPOSITION TOPIC NO. 23:

All Documents and Things provided by You to any Defendants in connection with

the Cobblestone Litigation.

20

Case 2:23-cv-00285-JRG-RSP Document 44-3 Filed 03/07/24 Page 24 of 24 PageID #: 591