UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF MICHIGAN
`
`Industrial Quick Search, Inc., et al.
`
`Plaint!IJ~,
`
`v.
`
`Case No. 1:13-cv-00770-.JTN
`
`Google, Inc., et al.
`
`Hon . .Janet T. Neff
`
`Defendants.
`
`.JURY TRIAL DEMANDED
`
`PLAINTIFFS' FIRST REQUEST FOR THE
`PRODUCTION OF DOCUMENTS AND THINGS
`TO GOOGLE, INC.
`
`Pursuant to Fed. R. Civ. P. 34, plaintiffs, Industrial Quick Search, Inc. and Michael
`
`Meiresonne, submit these document requests to defendant, Google, Inc. Defendant must answer
`
`these interrogatories under oath within 30 days.
`
`CLAIMS OF PRIVILEGE
`
`If the production of any document is refused on the basis of privilege and/or work
`
`product, the following information is requested with respect to any such document:
`
`( l) the
`
`privilege and/or work product rule of law being relied upon; (2) the date the document was
`
`created; (3) the identity of the person or persons who created the document; (4) the identity of
`
`the present custodian; (5) the addressee(s) and all other recipients of the document; (6) the
`
`subject matter of the document; and (7) the location of the document.
`
`Google Exhibit 1021
`Page 1
`
`
`WESTERN DISTRICT OF MICHIGAN
`
`Industrial Quick Search, Inc., et al.
`
`Plaint!IJ~,
`
`v.
`
`Case No. 1:13-cv-00770-.JTN
`
`Google, Inc., et al.
`
`Hon . .Janet T. Neff
`
`Defendants.
`
`.JURY TRIAL DEMANDED
`
`PLAINTIFFS' FIRST REQUEST FOR THE
`PRODUCTION OF DOCUMENTS AND THINGS
`TO GOOGLE, INC.
`
`Pursuant to Fed. R. Civ. P. 34, plaintiffs, Industrial Quick Search, Inc. and Michael
`
`Meiresonne, submit these document requests to defendant, Google, Inc. Defendant must answer
`
`these interrogatories under oath within 30 days.
`
`CLAIMS OF PRIVILEGE
`
`If the production of any document is refused on the basis of privilege and/or work
`
`product, the following information is requested with respect to any such document:
`
`( l) the
`
`privilege and/or work product rule of law being relied upon; (2) the date the document was
`
`created; (3) the identity of the person or persons who created the document; (4) the identity of
`
`the present custodian; (5) the addressee(s) and all other recipients of the document; (6) the
`
`subject matter of the document; and (7) the location of the document.
`
`Google Exhibit 1021
`Page 1
`
`
`
`INSTRUCTIONS AGAINST UNNECESSARY PRODUCTION
`
`Many of the requests below seek documents ''sufficient to identifY'' or ·'sufficient to
`
`explain'' a particular thing or topic. These requests do not seek ·'all" documents relating to a
`
`particular topic, but only documents sufficient to disclose or describe the requested information.
`
`DEFINITIONS
`
`I. The terms '096 Patent and Patent-In-Suit mean U.S. Patent No.8, 156,096.
`
`2. The term Asserted Claims means claims 16-20 of the '096 Patent.
`
`3. The term Google means Google, Inc., all of Google's predecessors (merged, acquired, or
`
`otherwise), successors, subsidiaries, divisions, departments, affiliates, sister and parent
`
`entities, and all of its present and former officers, directors, agents, representatives,
`
`employees, and other persons acting on its behalf.
`
`4. The term Accused Technology means a web page which displays keyword search results
`
`including web page links corresponding to the search, a descriptive portion corresponding
`
`to at least some of the links, and an area for viewing information related to the links when
`
`a user's cursor is placed over or near the links or the descriptive portion. This term
`
`includes, but is not limited to, Google's Instant Preview and Google Local local search
`
`results feature.
`
`2
`
`Google Exhibit 1021
`Page 2
`
`
`
`DOCUMENT REQUEST NO. l: Documents sufficient to explain the technical operation of
`
`DOCUMENT REQUESTS
`
`the Accused Technology.
`
`RESPONSE
`
`DOCUMENT REQUEST NO. 2: Documents sufficient to explain Google Local as
`
`it
`
`pertains to the Accused Technology.
`
`RESPONSE
`
`DOCUMENT REQUEST NO.3: Documents sufficient to explain why Google provides
`
`local search results for some search terms, but not others.
`
`RESPONSE
`
`DOCUMENT REQUEST NO. 4: Documents sufficient to identifY when Google first began
`
`using the Accused Technology. If different versions or releases for the Accused Technology
`
`exist, include in your production documents sufficient to identify when each feature was first
`
`used commercially.
`
`RESPONSE
`
`3
`
`Google Exhibit 1021
`Page 3
`
`
`
`DOCUMENT REQUEST NO. 5: Documents sufficient to explain why Google removed
`
`Instant Preview.
`
`RESPONSE
`
`DOCUMENT REQUEST NO.6: Documents sufficient to explain why Google added
`
`Google LocaL
`
`RESPONSE
`
`DOCUMENT REQUEST NO.7: All documents supporting the statement in Google' s 2010
`
`!OK Report that "Instant Preview
`s'' are among "some recent notable enhancements to search"
`
`
`
`review the ad" was among the "improvements in [Google's] and that ''providing an option to p
`
`
`
`ased traffic." ability to ultimately monetize incre
`
`RESPONSE
`
`DOCUMENT REQUEST NO. 8: All agreements between Google and third parties, including
`
`but not limited to A VG, pertaining
`
`to a web search having the Instant Preview feature similar to
`
`A VG Technologies USA, illustrat
`ed in ~~ 31-33 of the First Amended Complaint, and for each
`
`ionship began.
`entity, the date the contractual relat
`
`RESPONSE
`
`4
`
`Google Exhibit 1021
`Page 4
`
`
`
`DOCUMENT REQUEST NO. 9: The complete file history pertaining
`
`to
`
`International
`
`Application No. PCT/US 2011/050 627 titled "Search Result Previews" filed on September 7,
`
`2011, and any related patent or pate nt application.
`
`RESPONSE
`
`DOCUMENT REQUEST NO. 10: The complete file history pertaining to United States Patent
`
`Publication No. 2013/0275422 title d "Search Results Preview"' tiled on May 31, 20 II, and any
`
`related patent or patent application.
`
`RESPONSE
`
`DOCUMENT REQUEST NO. 11: All documents filed with the Securities and Exchange
`
`Commission that mention or discuss the Accused Technology.
`
`RESPONSE
`
`DOCUMENT REQUEST NO. 12: All documents referring or relating to the plaintiffs, and any
`
`patent or patent application naming Michael Meiresonne as an inventor.
`
`RESPONSE
`
`DOCUMENT REQUEST NO. 13:
`
`All business case documents pertaining to the Accused
`
`Technology which include technical
`
`information regarding the Accused Technology.
`5
`
`Google Exhibit 1021
`Page 5
`
`
`
`RESPONSE
`
`DOCUMENT REQUEST NO. 14: All opm10ns of counsel referring or relating to
`
`the
`
`plaintiffs, and any patent or patent application naming Michael Meiresonne as an inventor.
`
`RESPONSE
`
`Dated: November 15,2013
`
`BROOKS KUSHMAN P.C.
`
`Bar No. P36399)
`Thomas A. Lewr
`JohnS. LeRoy (MI Bar No. P61964)
`William G. Abbatt (MI Bar No. P34094)
`Mark A. Jotanovic (MI Bar No. P73752)
`I 000 Town Center, 22nd Floor
`Southfield, Michigan 48075-1238
`Tel: (248) 358-4400- Fax (248) 358-3351
`Email:=~=~======
`
`Attorneysfor Plaintiffs
`
`6
`
`Google Exhibit 1021
`Page 6
`
`
`
`CERTIFICATE OF SERVICE
`
`I certify that I served:
`
`PLAINTIFFS' FIRST REQUEST FOR THE PRODUCTION OF
`DOCUMENTS AND THINGS TO GOOGLE, INC.
`
`-.1L.
`
`delivering (via email)
`
`..JL
`
`mailing (via First-Class mail)
`
`a copy to:
`
`Matthew L. Vicari (P44049)
`Joseph J. Gavin (P69529)
`MILLER JOHNSON
`250 Monroe Avenue, N.W., Suite 800
`PO Box 306
`Grand Rapids, Michigan 49501-0306
`
`Krista S. Schwartz (IL 6238053)
`Tharan Gregory Lanier
`JONES DAY
`77 West Wacker
`Chicago, IL 60601.1692
`
`Attorneysfor Google, Inc.
`
`7
`
`Google Exhibit 1021
`Page 7
`
`
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