Case 1:23-cv-00758-JLH-SRF Document 168-9 Filed 10/10/24 Page 1 of 5 PageID #: 4378
`Case 1:23-cv-00758-JLH-SRF Document 168-9 Filed 10/10/24 Page 1 of 5 PagelD #: 4378
`
`EXHIBIT 8
`
` EXHIBIT 8
`
`
`Case 1:23-cv-00758-JLH-SRF Document 168-9 Filed 10/10/24 Page 1 of 5 PagelD #: 4378
`
`EXHIBIT 8
`
` EXHIBIT 8
`
`
`
`Case 1:23-cv-00758-JLH-SRF Document 168-9 Filed 10/10/24 Page 2 of 5 PageID #: 4379
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`Plaintiff/Counter-Defendant,
`
`Defendant/Counter-Plaintiff.
`
`
`
`
`C.A. No. 23-758-JLH
`
`
`
`
`)))))))))
`
`ORCA SECURITY LTD.,
`
`
`
`v.
`
`WIZ, INC.,
`
`
`
`DEFENDANT AND COUNTER-PLAINTIFF WIZ’S THIRD SET OF REQUESTS FOR
`PRODUCTION OF DOCUMENTS AND THINGS (NOS. 74-149)
`
`Pursuant to Federal Rules of Civil Procedure Rules 26 and 34, Defendant and Counter-
`
`Plaintiff Wiz, Inc. (“Wiz”) requests that Plaintiff and Counter-Defendant Orca Security, Ltd.
`
`(“Orca” or “Plaintiff”) produce Documents and Things responsive to the following requests (the
`
`“Requests”) in accordance with the agreed upon scheduling order. Wiz requests that Orca make
`
`any production of documents in connection with these Requests at the office of Wilson Sonsini
`
`Goodrich & Rosati, One Market Plaza, Spear Tower, Suite 3300, San Francisco, CA 94105, or at
`
`such time and place as the parties may agree upon.
`
`DEFINITIONS
`
`The words and phrases used in these Requests shall have the meanings ascribed to them
`
`under the Federal Rules of Civil Procedure and the Local Rules of the United States District Court
`
`for the District of Delaware. In addition, the following terms shall have the meanings set forth
`
`below whenever used in any Request:
`
`1. “Orca,” “You,” “Your,” and/or “Plaintiff” mean Orca Security Ltd., and any and
`
`all of its present or former subsidiaries, parents, affiliates, divisions, successors, predecessors,
`
`agents, employees, representatives, directors, officers, trustees, attorneys, or any other person or
`
`entity acting in whole or in part in concert with any of the foregoing.
`
`1
`
`
`
`Case 1:23-cv-00758-JLH-SRF Document 168-9 Filed 10/10/24 Page 3 of 5 PageID #: 4380
`
`
`
`(iii) all photocopies shall be stapled or clipped as the originals; and (iv) each page shall be given a
`
`discrete production number.
`
`9. None of the Definitions or Requests set forth above shall be construed as an
`
`admission of the existence of evidence, to the relevance or admissibility of any evidence, or to the
`
`truth or accuracy of any statement or characterization in the Definition or Request.
`
`10. If you do not agree with any definition of the terms provided herein, you must
`
`provide a reasonable, alternative definition for that term, consistent with industry custom and
`
`usage.
`
`11. These Requests shall be deemed continuing, and Plaintiff shall be obligated to
`
`change, supplement, and amend its answers to the extent required by the Federal Rules of Civil
`
`Procedure.
`
`THIRD SET OF REQUESTS FOR PRODUCTION
`
`REQUEST FOR PRODUCTION NO. 74
`
`All documents that identify each designation you use (including the external and internal
`
`product, program, or development project names) for each Orca Accused Functionality made,
`
`used, sold, imported, and/or offered for sale.
`
`REQUEST FOR PRODUCTION NO. 75
`
`All documents (including but not limited to schematics, diagrams, technical descriptions,
`
`specifications, API documentation, developer manuals, user guides, operating instructions, and/or
`
`source code) which refer, relate to, or describe, in whole or in part, the nature, functionality, design,
`
`structure and/or operation of each version of each Orca Accused Functionality.
`
`REQUEST FOR PRODUCTION NO. 76
`
`All documents relating to your patent licensing policies, practices, and procedures.
`
`
`
`10
`
`
`
`Case 1:23-cv-00758-JLH-SRF Document 168-9 Filed 10/10/24 Page 4 of 5 PageID #: 4381
`
`
`
`2024, including but not limited to, documents related to the design and development and operation
`
`of the AI Security Posture Management capabilities and the AI-Security Dashboard.
`
`REQUEST FOR PRODUCTION NO. 147
`
`All Documents, Communications, and Things related to Orca’s decision to introduce
`
`Integration with Oracle Cloud Infrastructure in February 2023, including but not limited to,
`
`documents related to the design and development and operation of the Integration with Oracle
`
`Cloud Infrastructure.
`
`REQUEST FOR PRODUCTION NO. 148
`
`All Documents, Communications, and Things related to Orca’s decision to introduce
`
`Integration with Alibaba Cloud in November 2022, including but not limited to, documents related
`
`to the design and development and operation of the Integration with Alibaba Cloud.
`
`REQUEST FOR PRODUCTION NO. 149
`
`All Documents, Communications, and Things related to Orca’s decision to publish a blog
`
`post related to Log4Shell vulnerability in December 2021, including but not limited to, all versions,
`
`including any drafts, of the blog post, identification of contributors to the blog post, and any
`
`materials consulted or relied upon in drafting the blog post.
`
`
`OF COUNSEL:
`
`Jordan R. Jaffe
`Lisa Zang
`Catherine Lacy
`Callie Davidson
`Alex Miller
`WILSON SONSINI GOODRICH & ROSATI, P.C.
`One Market Plaza
`Spear Tower, Suite 3300
`San Francisco, CA 94105
`(415) 947-2000
`
`
`
`
`
`
`
`/s/ Kelly E. Farnan
`Frederick L. Cottrell, III (#2555)
`Kelly E. Farnan (#4395)
`Christine D. Haynes (#4697)
`RICHARDS, LAYTON & FINGER, P.A.
`One Rodney Square
`920 N. King Street
`Wilmington, DE 19801
`(302) 651-7700
`cottrell@rlf.com
`farnan@rlf.com
`haynes@rlf.com
`
`Counsel for Defendant Wiz, Inc.
`
`22
`
`
`
`Case 1:23-cv-00758-JLH-SRF Document 168-9 Filed 10/10/24 Page 5 of 5 PageID #: 4382
`
`
`
`Praatika Prasad
`WILSON SONSINI GOODRICH & ROSATI, P.C.
`1301 Avenue of the Americas, 40th Floor
`New York, NY 10019-6022
`(212) 999-5800
`
`
`Dated: July 11, 2024
`
`
`23
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
