Case 1:23-cv-00758-JLH-SRF Document 143-1 Filed 09/11/24 Page 1 of 7 PageID #: 3278
`Case 1:23-cv-00758-JLH-SRF Document 143-1 Filed 09/11/24 Page 1 of 7 PagelD #: 3278
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`EXHIBIT
`EXHIBIT A
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`Case 1:23-cv-00758-JLH-SRF Document 143-1 Filed 09/11/24 Page 2 of 7 PageID #: 3279
`Case 1:23-cv-00758-JLH-SRF Document 143-1 Filed 09/11/24 Page 2 of 7 PagelD #: 3279
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`) )
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`) C.A. No. 23-758-JLH
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`ORCA SECURITY LTD.,
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`Vv.
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`WIZ, INC.,
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`.
`Plaintiff,
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`Defendant.
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`WIZ, INC.’S RESPONSES TO ORCA SECURITY LTD.’S SECOND SET OF
`INTERROGATORIES(NOS.17-22)
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`Pursuant to Rules 26 and 33 of the Federal Rules of Civil Procedure, and the applicable
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`Local Civil Rules of the District of Delaware, Defendant Wiz, Inc. (“Wiz”), by and through its
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`counsel, hereby providesits objections and responsesto the Plaintiff Orca Security Ltd.’s (“Orca’’)
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`SecondSet of Interrogatories (Nos. 17-22) (“Interrogatories”).
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`PRELIMINARY STATEMENT
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`The following responses are made solely for the purpose of, and in relation to, the above-
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`captioned action. Each response is provided subject to all appropriate objections (including,
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`without limitation, objections concerning competency, relevancy, materiality, propriety, and
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`admissibility) that would require the exclusion of any statement contained herein if the statement
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`were made by witness present and testifying in court. All such objections and grounds are
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`therefore reserved and maybe interposedat the timeoftrial.
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`The following responses are based on the facts and information presently known and
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`available to Wiz. The responses refer only to those contentions that have been asserted to date,
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`Case 1:23-cv-00758-JLH-SRF Document 143-1 Filed 09/11/24 Page 3 of 7 PageID #: 3280
`Case 1:23-cv-00758-JLH-SRF Document 143-1 Filed 09/11/24 Page 3 of 7 PagelD #: 3280
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`HIGHLY CONFIDENTIAL — ATTORNEYS’ EYES ONLY
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`based on the facts now known to Wiz. Discovery, investigation, research, and analysis are ongoing
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`in this case and may disclose the existence of additional facts, add meaning to known facts,
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`establish entirely new factual conclusions or legal contentions, or possibly lead to additions,
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`variations, and changesto these responses. Wiz reserves the right to change or supplement these
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`responsesas additional facts are discovered, revealed, recalled, or otherwise ascertained.
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`GENERAL OBJECTIONS
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`Wiz asserts each of the following General Objections and expressly incorporates them into
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`each responseset forth below. By providing a specific response to any Interrogatory, Wiz does
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`not waive or otherwise limit these General Objections. Furthermore, reference to any of these
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`General Objections in any specific response shall not waive or otherwise limit the applicability of
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`all of these General Objections to each and every response.
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`1.
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`Wiz hereby incorporates by reference the general objections set forth in its
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`Objections and Responses to Plaintiff's First Set of Requests for the Production and in its
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`Objections and Responsesto Plaintiff's First Set of Interrogatories, served on March 22, 2024.
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`2.
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`Wiz objects to Plaintiffs definition of the term “Wiz Related Patent(s)” as vague,
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`ambiguous, indefinite, overbroad, unduly burdensome, seeking the production of informationthatis
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`not relevantto the claim or defense of any party, not proportional to the needsof the case, and is not
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`reasonably accessible to Wiz upon reasonable diligence.
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`INSTRUCTIONS
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`1.
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`Wiz hereby incorporates by reference the objections set forth in its Objections and
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`Responsesto Plaintiff's First Set of Requests for the Production and in its Objections and
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`Responsesto Plaintiffs First Set of Interrogatories, served on March 22, 2024.
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`Case 1:23-cv-00758-JLH-SRF Document 143-1 Filed 09/11/24 Page 4 of 7 PageID #: 3281
`Case 1:23-cv-00758-JLH-SRF Document 143-1 Filed 09/11/24 Page 4 of 7 PagelD #: 3281
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`HIGHLY CONFIDENTIAL — ATTORNEYS’ EYES ONLY
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`SPECIFIC OBJECTIONS AND RESPONSES TO INTERROGATORIES
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`INTERROGATORYNO.17:
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`For each Wiz Asserted Claim of each Wiz Asserted Patent, describe in detail the alleged
`invention of the claimed subject matter, including by specifically identifying and describing
`when, where, and how each alleged invention, including each limitation of every Wiz Asserted
`Claim, wasfirst conceived; when, where, and how eachalleged invention, including each limitation
`of every Wiz Asserted Claim, was reducedto practice; all Person(s), including but not limited to the
`Wiz Named Inventors, who contributed to the conception and reduction to practice of each alleged
`invention, as well as the contributions each Person identified made to each alleged invention; the
`Date(s) and circumstances of each Person(s)’, including but not limited to the Wiz NamedInventors’,
`involvementin the prosecution of each Wiz Asserted Patent, including but not limited to the Wiz
`NamedInventor’s contributions to said prosecution and/or the subject matter claimed therein; the
`three Person(s) most knowledgeable about the conception and reduction to practice of each alleged
`invention; and all Documents and Things supporting or refuting any contention that Wiz, the Wiz
`Named Inventors, or any other Person(s) identified in response to this Interrogatory are, in fact,
`responsible for the alleged invention, conception, and reduction to practice of the claimed subject
`matter of the Asserted Claims.
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`RESPONSE TO INTERROGATORYNO.17:
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`Wiz incorporatesall its general objections and reservations of rights as if specifically set
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`forth herein. Wiz specifically objects to this Interrogatory to the extent it seeks information that
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`is not relevant to the claim or defense of any party andis not proportional to the needs ofthe case.
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`Wiz objects to this Interrogatory as overly broad, unduly burdensome, and not proportional to the
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`needs of the case as to its request for information regarding the “when, where, and how each
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`alleged invention, including each limitation of every Wiz Asserted Claim, was first conceived
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`[and] when, where, and how each alleged invention, including each limitation of every Wiz
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`Asserted Claim, was reduced to practice” as each of the Wiz Asserted Patents are subject to the
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`America Invents Act (AIA). Wiz objects to this Interrogatory as compound and comprising
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`multiple Interrogatories. Wiz objects to this Interrogatory as vague, ambiguous, and unduly
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`burdensomeat least as to the phrases “most knowledgeable” as used in this Interrogatory. Wiz
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`objectsto this Interrogatory to the extentit seeks confidential information belongingto third parties
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`3
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`Case 1:23-cv-00758-JLH-SRF Document 143-1 Filed 09/11/24 Page 5 of 7 PageID #: 3282
`Case 1:23-cv-00758-JLH-SRF Document 143-1 Filed 09/11/24 Page 5 of 7 PagelD #: 3282
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`HIGHLY CONFIDENTIAL — ATTORNEYS’ EYES ONLY
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`or otherwise subject to third-party confidentiality obligations. Wiz objects to this Interrogatory to
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`the extent it seeks information protected from disclosure by the attorney-client privilege and/or
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`work-product doctrine, or any other applicable privilege or protection. Wiz objects to this
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`Interrogatory to the extent it seeks expert discovery prior to the scheduled time to exchange said
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`information under the Scheduling Order.
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`Subject to and without waiving the foregoing objections, Wiz respondsas follows:
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`REDACTED
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`All of the Wiz Asserted Patents are post-AIA patents. The Wiz Asserted Patents, and the
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`related provisional(s) and/or parent application(s) to which each Wiz Asserted Patent claims
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`priority, as well as the applications that issued as each Wiz Asserted Patent, are evidence of the
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`claimed subject matter, conception, reduction to practice and inventor contributions.
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`Wiz is engaged in an ongoing investigation of facts pertaining to this issue and expressly
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`reservethe right to revise, clarify, and/or supplementits answerto this Interrogatory.
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`Case 1:23-cv-00758-JLH-SRF Document 143-1 Filed 09/11/24 Page 6 of 7 PageID #: 3283
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`/s/ Christine D. Haynes
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`Counsel for Defendant Wiz, Inc.
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`Case 1:23-cv-00758-JLH-SRF Document 143-1 Filed 09/11/24 Page 7 of 7 PageID #: 3284
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`/s/ Christine D. Haynes
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