Exhibit 2

Putco’s Updated Notice of Deposition of Carjamz Com, Inc.

Case: 3:20-cv-50109 Document #: 57-1 Filed: 01/19/21 Page 1 of 9 PageID #:760
UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

WESTERN DIVISION

PUTCO, INC.,

 Plaintiff,

v.

CARJAMZ COM INC.

 Defendant.

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No. 3:20-cv-50109

District Judge Iain D. Johnston

Magistrate Judge Lisa A. Jensen

UPDATED NOTICE OF DEPOSITION OF CARJAMZ COM, INC.

TO: CarJamz Com, Inc.

% Konrad Sherinian

Depeng Bi

The Law Offices of Korad Sherinian, LLC

1775 Park Street, Suite #200

Naperville, IL 60563

PLEASE TAKE NOTICE that Plaintiff, through its counsel of record will take the 

deposition of Defendant Carjamz Com, Inc., pursuant to Fed. R. Civ. P. 30(b)(6) under oath and

before a Notary Public or other person authorized to administer oaths. The deposition shall take 

on January 21, 2021, beginning at 10:00 a.m., or at such other time and place as agreed to by the 

parties, by remote video conference. The deposition will continue as necessary pursuant to the 

Federal Rules of Civil Procedure. Putco reserves their rights under Federal Rule of Civil Procedure 

30(d) to request additional time if necessary to fairly examine the deponent(s) and/or if other 

circumstances impede, delay, or frustrate the fair examination of the deponent(s).

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Pursuant to Fed. R. Civ. P. 30(b)(6), Defendant is required to designate one or more 

officers, directors, managing agents, or other consenting persons knowledgeable to testify on its 

behalf with respect to the topics in Schedule A.

The deposition shall be recorded stenographically by a person authorized to administer 

oaths and will be electronically recorded.

You are invited to attend.

Respectfully submitted by:

Putco, Inc., Plaintiff,

BY: McKEE, VOORHEES & SEASE, P.L.C.

/s/Glenn Johnson

Glenn Johnson (Iowa Bar No. AT0003856)

Jonathan L. Kennedy (Iowa Bar No. AT0011458)

McKEE, VOORHEES & SEASE, P.L.C.

801 Grand Avenue, Suite 3200

Des Moines, IA 50309-2721

Phone: 515-288-3667

Fax: 515-288-1338

Email: glenn.johnson@ipmvs.com

Email: jonathan.kennedy@ipmvs.com

Email: mvslit@ipmvs.com

and

Marc C. Gravino 

John J. Holevas 

Joel M. Huotari 

Williams McCarthy, LLP 

120 W. State Street 

P.O. Box 219 

Rockford, IL 61105-0219 

mgravino@wilmac.com

jholevas@wilmac.com

jhoutari@wilmac.com

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CERTIFICATE OF SERVICE

I certify that on the 23rd day of December 2020, I caused the foregoing to be served via 

email upon the following:

Copy To:

Konrad Sherinian

Depeng Bi

The Law Offices of Korad Sherinian, LLC

1775 Park Street

Suite #200

Naperville, IL 60563

Phone: (630) 318-2606

Fax: (630) 364-5825

Email: ksherinian@sherinianlaw.net

Email: ebi@sherinianlaw.net

Email: courts@sherinianlaw.net

ATTORNEYS FOR DEFENDANT

/s/Glenn Johnson

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SCHEDULE A

Pursuant to Fed. R. Civ. P. 30(b)(6), Carjamz Com Inc. shall designate and present one or 

more officers, directors, managing agents or other persons who consent to testify on its behalf in 

connection with the topics set forth below. 

DEFINITIONS

1. “Carjamz Com Inc,” “Carjamz Com,” “Carjamz,” “Race Sport,” “You,” and 

“Your” refers to Carjamz Com Inc. and (i) its present and former owners, directors, officers, 

employees, agents, representatives, accountants, investigators, consultants, attorneys, and 

predecessors and successors in interest and any parent, subsidiary, and affiliated entities, (ii) any 

other person or entity acting on its behalf or on whose behalf it has acted; (iii) any other person 

or entity otherwise subject to its control, or which controls or controlled it, or with which it was 

or is under common control; and (iv) any person or entity otherwise in the corporate family of 

any predecessor or successor in interest or any parent, subsidiary, or affiliated entity. 

2. “Patents in Suit” shall refer to U.S. Patent No. 9,243,796 (“the ’796 patent”) and 

U.S. Patent No. 9,995,473 (“the ’473 patent”), and any applications leading to its issuance.

3. “Accused Infringing Products” refers to the manufacture, use, importation, sale 

and/or offer for sale by Defendant of its LED headlight replacement kits, including, but not 

limited to at least one of the following: the “Premier Penetrator Series” H1, H3, H4, H7, H8, H9, 

H11, H13, 9004, 9005, 9006, and 9007 and the“Gen4” H1, H3, H4, H7, H8, H9, H10, H11, H13, 

880, 5202, 9004, 9005, 9006, 9007, and 9012 LED headlight kits.

TOPICS

1. Race Sport’s knowledge of the Patents in Suit.

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2. All information relating to any joint defense agreement or third-party funding of 

court costs, attorneys’ fees, and/or defense costs incurred by Defendant in Putco, Inc. v. Carjamz 

Com Inc., Case No. 3:20-cv-50109 (N.D. Illinois).

3. Race Sport’s decision to cease its sale and offer for sale of the Accused Infringing 

Products on March 3, 2016.

4. Race Sport’s decision to resume its sale and offer for sale of the Accused Infringing 

Products after March 3, 2016.

5. All information related to market share, loss and potential loss of market share by 

Putco, and other alleged and/or potential harm to Putco by Race Sport’s offer and sale of Accused 

Infringing Products.

6. All information related to Race Sport’s disregard and/or indifference to the Patentsat-Issue and reason(s) underlying its determination continue to sell Accused Infringing Products

after Putco’s notice of 2016 and notice as set forth in the Complaint underlying this litigation.

7. Race Sport’s knowledge of LED headlight kits, including, but not limited to: LED 

headlight kits having solid metal heat sinks, LED headlight kits with flexible heat sinks, and dates 

Race Sport acquired said knowledge.

8. Communications and information regarding the Declaration of Lei Zhi Biao dated 

June 6, 2020.

9. Race Sport’s document retention policies, document search, and production related 

to the present action.

10. Race Sport’s knowledge, communications, and relationship with Lanseko 

Electronic Technology Co., its agents, officers, employees, former officers, and/or former 

employees.

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11. Race Sport’s knowledge, communications, and relationship with Unipower 

International Group Limited, its agents, officers, employees, former officers, and/or former 

employees.

12. Race Sport’s use of the Gen4 mark, and knowledge of the use by third-parties of 

the use of the Gen4 mark, further including Race Sport’s Trademark Reg. No. 4,863,274.

13. Race Sport’s current and historic activities and knowledge regarding the Gen4 

product research and development activities, testing, prototypes, and decision to seek patent 

protection in the United States.

14. U.S. Patent No. 10,801,714.

15. The quantity sold, gross sales in dollars, the net sales in dollars, any discounts or 

allowances, the costs of goods sold, the price of goods sold, the gross profit margins, and any other 

direct or indirect costs generally allocated to sales of the Accused Infringing Products.

16. All information related to the first public disclosure, first use, first sale, first offer 

for sale, or any other distribution, disclosure or commercialization of the Accused Infringing 

Products.

17. Race Sport’s current and historic marketing efforts made in connection with the 

Accused Infringing Products, including print ads, on-line marketing and sales, and other marketing 

modes.

18. Race Sport’s current and historic sourcing, manufacturing, assembly, and/or

distribution of the Accused Infringing Products and LED headlight kits with a solid metal heat 

sink.

19. All information relating to dealers authorized to distribute LED headlight kits on 

behalf of Race Sport.

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20. All information relating to any agreements, contracts, licenses, and/or assignments 

regarding the Patents in Suit or any patents of similar subject matter to the Patents in Suit.

21. Race Sport’s activities at, and knowledge and information acquired from or 

regarding the public disclosures at the 2014 SEMA Show, including, but not limited to: Race 

Sport’s knowledge of Putco’s disclosure of products which embody one or more claims of the 

Patents-in-Suit.

22. Race Sport’s quality control/assurance policies, procedures and standards related to 

the Accused Infringing Products, including review of all dimensional, non-dimensional and other 

criteria, evaluations of effectivity of quality procedures, modifications to the quality 

procedures/criteria, accept/reject methodology, and rework criteria, procedures, and processes.

23. Current and historic information related to Race Sport’s inventory location and total 

units of the Accused Infringing Products.

24. All information related to Race Sport’s knowledge and understanding of the market 

in which the Accused Infringing Products compete or have competed.

25. Race Sport’s management and organization structure, including, but not limited to, 

the identification of names, titles, and job responsibilities of any person, company, or business 

interest involved in business activities which concern the Accused Infringing Products, regardless 

of whether those business activities are here in the United States or abroad.

26. The factual bases for Race Sport’s contentions that it does not, and never has, 

directly or indirectly infringed any claims of the Patents in Suit.

27. The factual bases for Race Sport’s contentions that the claims of the Patents in Suit 

are invalid.

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28. The factual bases for Race Sport’s affirmative defense that Putco’s claims are 

barred by the equitable doctrines of waiver, estoppel, and/or acquiescence.

29. The factual bases to Race Sport’s responses to discovery, including responses to 

Interrogatories and Document Requests and documents gathered and produced in response thereto.

30. All information related to Race Sport’s claim of prior invention as to the patents in 

suit.

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