John P. Costello. Esq. SBN 161511)
`COSTELLO LAW C RPORATION
`2267 Lava Rid e Court, Suite 210
`Roseville, CA 5661
`Telephone: 916 441-2234
`Facsrmile: 916 441—4254
`Jcostello@coste lolawcorp.com
`
`Attorneys for Defendants
`American Die and Rollformin , Inc.; and
`Artes1an Home Products, Inc. ba Valor
`Gutter Guard
`
`UNITED STATES DISTRICT COURT
`
`FOR THE EASTERN DISTRICT OF CALIFORNIA
`
`GUTTERGLOVE INC., a California
`Corporation,
`
`Plaintiff,
`
`VS.
`
`AMERICAN DIE AND
`
`ROLLFORMING
`
`INC., a California Corporation; and
`ARTESIAN HOME PRODUCTS,
`INC., a California Corporation, dba
`“Valor Gutter Guard”
`
`Defendants.
`
`
`
`Case No. 2: l6-CV~O2408-WHO
`
`DEFENDANT AND
`
`COUNTERCLAIMANT ARTESIAN
`
`HOME PRODUCTS, INC.’S, FIRST
`
`SUPPLEMENTAL RESPONSES TO
`
`PLAINTIFF AND
`
`COUNTERDEFENDANT
`
`GUTTERGLOVE, INCJS COMMON
`
`INTERROGATORIES SET ONE
`
`(HIGHLY CONFIDENTIAL)
`
`Action Filed: October 7, 2016
`
`Judge: Honorable William H. Orrick III
`
`
`
`#UJN
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`DEFENDANT ARTESIAN HOME PRODUCTS, INC.’S FIRST SUPPLEMENTAL RESPONSES TO PLAINTIFF
`GUTTERGLOVE, INC.’S COMMON INTERROGATORIES SET ONE
`|PR2018—00031
`Petitioners Ex. 1118 p. 1
`CASE NO. 2:16-CV-02408-WHO
`
`IPR2018-00031
`Petitioners Ex. 1118 p. 1
`
`

`

`N
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`PROPOUNDING
`,
`PARTY(IES)-
`
`PLAINTIFF AND
`
`‘
`, COUNTERDEFENDANT
`GUTTERGLOVE, INC. ("PLAINTIFF")
`
`RESPONDING PARTY(IES): DEFENDANT AND COUNTERCLAIMANT
`ARTESIAN HOME PRODUCTS, INC.
`(“DEFENDANT”)
`
`SET NO.:
`
`One (1)
`
`Pursuant to the provisions of Rule 26 and 33 of the Federal Rules of Civil
`
`Procedure, Defendant Artesian Home Products, Inc. (“Defendant” or “Responding
`
`Party”) hereby submits its responses to Plaintiff Gutterglove Inc’s (“Plaintiff”)
`Common Interrogatories, Set No. One. Defendant expressly reserves the right to
`
`make changes to these responses if it appears that omissions or errors have been made
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`or that further or more accurate information is available.
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`These responses state the knowledge, information, and belief of Defendant as of
`
`the date of these responses. Defendant is presently engaged in its own investigation
`
`and discovery. As of the date of preparation of these responses, Defendant has not
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`had the benefit of additional information which can be obtained through discovery.
`Defendant does not represent nor intend to represent that these responses
`
`contain all information relevant to the subject matter of the Interrogatories. Further
`
`investigation is likely to lead to additional information relevant to the subject matter
`
`of the Interrogatories. As a result, Defendant hereby reserves the right to amend or
`
`supplement these responses at any time and/or to use any subsequently acquired
`
`information at trial, any other hearing, and/or for any other purpose.
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`Moreover, Defendant notes that its responses may be based upon hearsay or
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`other forms of information which are not necessarily reliable or admissible into
`
`evidence and, as a result, Defendant hereby provides notice that it does not intend to
`
`
`
`DEFENDANT ARTESIAN HOME PRODUCTS, INC.’S FIRST SUPPLIEMENTAL RESPONSES‘TO PLAINTIFF
`GUTTERGLOVE, INC.’S COMMON INTERROGATORIES SET ONE
`CASE NO. 2:16-CV~02408—WHO
`
`|PR2018—00031
`
`2
`
`Petitioners Ex. 1118 p. 2
`
`IPR2018-00031
`Petitioners Ex. 1118 p. 2
`
`

`

`waive and hereby specifically reserves the right to object to the introduction into
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`evidence of the Interrogatories and/or the responses thereto at any trial, hearing,
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`and/or for any other purpose.
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`Defendant hereby responds to the Interrogatories, Set No. One, from Plaintiff as
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`said forth below.
`
`GENERAL OBJECTIONS
`
`Responding Party objects to the interrogatories propounded on the following
`
`grounds, which objections are incorporated into each and every specific response set
`
`forth below:
`
`1.
`
`Responding Party objects to each interrogatory to the extent that it seeks
`
`production of information protected by the attorney client privilege or attorney work
`
`product rule.
`
`2.
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`Responding Party objects to each interrogatory to the extent that it seeks
`
`to expand upon the obligation of the responding party under any applicable Federal
`
`rule, rule of Court or local rule.
`
`3.
`
`Responding Party has not completed its investigation of facts related to
`
`this case, has not completed discovery, and has not completed preparation for trial.
`
`Thus, Responding Party's responses at this stage are made only on the basis of such
`
`information as is currently known to it and reasonably available. These responses do
`
`not purport to constitute a final statement of all of Responding Party's knowledge
`
`regarding a particular subject and are made without prejudice to Responding Party's
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`right to introduce additional evidence at the time of trial or to supplement these
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`responses, as appropriate, upon completion of discovery and trial preparation, or
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`\DOO\}O\
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`DEFENDANT ARTESIAN HOME PRODUCTS, INC.’S FIRST SUPPLIEMENTAL RESPONSES TO PLATNTIFF
`GUTTERGLOVE, INC.’S COMMON INTERROGATORIES SET ONE
`CASE NO. 2: 16-CV-02408-WHO
`
`|PR201 8-00031
`
`3
`
`Petitioners Ex. 1118 p. 3
`
`IPR2018-00031
`Petitioners Ex. 1118 p. 3
`
`

`

`l\)
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`RESPONSE TO INTERROGATORIES
`
`INTERROGATORY NO.1:
`
`For each ACCUSED INSTRUMENTALITY, state the dates between which
`
`each was conceived, developed, completed, used, made, sold, offered for sale,
`
`and/or implemented by YOU.
`
`RESPONSE TO INTERROGATORY NO. 1
`
`Defendant replies as follows for the Accused Instrumentalities alleged in the
`
`complaint and in Plaintiff s infringement contentions:
`
`Date of Conception —
`
`Not applicable
`
`Dates of development/prototyping — Not Applicable
`
`Date provisional patent application filed — Not Applicable
`
`Date made — Not Applicable
`
`Date first offered for sale — October 2013
`
`Date first sold — November 2013
`
`Date utility patent application filed — Not Applicable
`
`SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 1:
`
`Due to the broad scope of Plaintiff’ s discovery demand in defining “Accused
`
`Instrumentalities” Defendant has chosen to give details on all five of its products here
`
`(Valor, Bolt, Arrow, Diamond and Superior), Defendant notes that Plaintiff” s
`
`
`
`DEFENDANT ARTESIAN HOME PRODUCTS, INC.’S FIRST SUPPLIEMENTAL RESPONSES TO PLAINTIFF
`GUTTERGLOVE, INC.’S COMMON INTERROGATORIES SET ONE
`CASE NO. 2:16-CV—02408-WHO
`
`|PR201 8-00031
`
`4
`
`Petitioners Ex. 1118 p. 4
`
`IPR2018-00031
`Petitioners Ex. 1118 p. 4
`
`

`

`complaint and infringement contentions only asserts four of the products as the
`
`“Accused Instrumentalities” (Valor, Arrow, Bolt, Diamond); therefore, Defendants
`
`reserve their right to object to the introduction into this case of any products not
`
`included in the complaint and infringement contentions. Defendants also object to the
`
`term “implemented” as being vague and unintelligible. With the previous objections
`
`incorporated into this response, Defendant responds as follows:
`
`For Valor:
`
`Date of Conception — Not applicable
`
`Dates of development/prototyping —— Not Applicable ‘
`
`Date provisional patent application filed ~Not Applicable
`
`Date made — Not Applicable
`
`Date first offered for sale __ October 2013
`
`Date first sold — November 2013
`
`Date utility patent application filed —— Not Applicable
`
`For Bolt:
`
`Date of Conception -
`
`‘ Not applicable
`
`Dates of development/prototyping — Not Applicable
`
`Date provisional patent application filed — Not Applicable
`
`Date made — Not Applicable
`
`Date first offered for sale —— November 2014
`
`
`DEFENDANT ARTESIAN HOME PRODUCTS, INC.’S FIRST SUPPLIEMENTAL RESPONSES TO PLAINTIFF
`GUTTERGLOVE, TNC.’S COMMON INTERROGATORIES SET ONE
`CASE NO. 2: l 6-CV—02408—WHO
`
`5
`
`|PR201 8-00031
`
`Petitioners Ex. 1118 p. 5
`
`\OOO\]O‘\
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`IPR2018-00031
`Petitioners Ex. 1118 p. 5
`
`

`

`Date first sold ~— December 2014
`
`Date utility patent application filed -— Not Applicable
`
`For Arrow:
`
`Date of Conception —
`
`Not applicable
`
`Dates of development/prototyping — Not Applicable
`
`Date provisional patent application filed — Not Applicable
`
`Date made — Not Applicable
`
`Date first offered for sale — October 2015
`
`Date first sold — October 2015
`
`Date utility patent application filed — Not Applicable
`
`For Diamond:
`
`Date of Conception —
`
`Not applicable
`
`Dates of development/prototyping — Not Applicable
`
`Date provisional patent application filed ~ Not Applicable
`
`Date made — Not Applicable
`
`Date first offered for sale ~— January 2016
`
`Date first sold ~ January 2016
`
`Date utility patent application filed —— Not Applicable
`
`“For Superior:
`
`Date of Conception — Not applicable
`
`
`
`DEFENDANT ARTESIAN HOME PRODUCTS, INC.’S FIRST SUPPLIEMENTAL RESPONSES TO PLAINTIFF
`GUTTERGLOVE, INC.’S COIVIMON INTERROGATORIES SET ONE
`CASE NO. 2:16-CV-02408-WHO
`
`|PR2018—00031
`
`Petitioners Ex. 1118 p. 6
`
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`IPR2018-00031
`Petitioners Ex. 1118 p. 6
`
`

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`Dates of development/prototyping — Not Applicable
`
`Date provisional patent application filed — Not Applicable
`
`Date made — Not Applicable
`
`Date first offered for sale — March 2016
`
`Date first sold — March 2016
`
`Date utility patent application filed — Not Applicable
`
`INTERROGATORY NO.2:
`
`IDENTIFY every product, service, system, and method of or from a third party
`
`(including the identity of each such third-party) that YOU have used in
`
`RELATION TO the design, development, implementation, testing, management,
`
`and operation of the ACCUSED INSTRUMENTALITIES.
`
`RESPONSE TO INTERROGATORY NO. 2
`
`Not applicable as to Defendant Artesian Home Products, Inc.
`
`SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 2:
`
`Due to the broad scope of Plaintiff’ s discovery demand in defining “Accused
`
`Instrumentalities” Defendant has chosen to give details on all five of its products here
`
`(Valor, Bolt, Arrow, Diamond and Superior), Defendant notes that Plaintiff s
`
`complaint and infringement contentions only asserts four of the products as the
`
`“Accused lnstrumentalities” (Valor, Arrow, Bolt, Diamond); therefore, Defendants
`
`reserve their right to object to the introduction into this case of any products not
`
`
`
`DEFENDANT ARTESIAN HOME PRODUCTS, INC.’S FIRST SUPPLIEMENTAL RESPONSES TO PLAINTIFF
`GUTTERGLOVE, INC.’S COMMON INTERROGATORIES SET ONE
`CASE NO. 2: 16-CV-02408-WHO
`
`|PR201 8-00031
`
`7
`
`Petitioners Ex. 1118 p. 7
`
`IPR2018-00031
`Petitioners Ex. 1118 p. 7
`
`

`

`WM
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`included in the complaint and infringement contentions. Defendants also objects to
`
`the terms “implementation, management or operation” as being vague, overly broad,
`
`and unintelligible. With the previous objections incorporated into this response,
`
`Defendant responds as follows:
`
`Artesian is a sales and marketing entity for the Accused Instrumentalities and did
`
`not engage in any “design, development, and testing”; these activities were the purview
`
`of Defendant ADR, which is a design and engineering company for numerous products.
`
`As to the activities of “implementation, management, or operation” Artesian provides
`
`sales and marketing for the Valor, Bolt, Arrow, Diamond, and Superior products.
`
`INTERROGATORY NO. 3:
`
`Separately for each product, service, system, and method identified in
`
`response to Interrogatories Nos. 1 and 2, IDENTIFY every PERSON or entity that
`
`participated, in ANY capacity, in the design, development, testing, or
`
`implementation of each product, service, system, and method.
`
`RESPONSE TO INTERROGATORY NO. 3
`
`Design, development, testing or implementation were carried out by Defendant,
`
`Artesian Home Products, Inc. Persons at Artesian Home Products, Inc. who were
`
`involved were Chris Tatasciore, Slate Bryer and Lawrence Dumm. John Q. Adams
`
`provided sales and marketing for the Accused Instrumentalities through the now defunct
`
`company, Quincy Home Products, Inc.; (years 2013-2014). Defendant Artesian Home
`
`
`
`DEFENDANT ARTESIAN HOME PRODUCTS, INC.’S FIRST SUPPLIEMENTAL RESPONSES TO PLAINTIFF
`GUTTERGLOVE, INC.’S COMMON INTERROGATORIES SET ONE
`CASE NO. 2:16—CV—02408-WHO
`
`|PR2018-00031
`
`8
`
`Petitioners Ex. 1118 p. 8
`
`IPR2018-00031
`Petitioners Ex. 1118 p. 8
`
`

`

`Products, Inc. provided marketing expertise as far as implementing the Accused
`
`Instrumentalities’ introduction to the marketplace for years 2015- Present. Bill Lasell at
`
`Artesian is charged with marketing and sales for the Accused Instrumentalities.
`
`SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 3:
`
`Defendant objects to the term “implementation” as being vague, overly broad,
`
`and unintelligible. With the previous objection incorporated into this response,
`
`Defendant responds as follows:
`
`Defendant would like to correct and clarify, its former response in that design,
`
`development and testing were carried out by Defendant, American Die and Rollforming,
`
`Inc., not Artesian Home Products, Inc. Persons at American Die and Rollforming. who
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`were involved in the design, development and testing were Chris Tatasciore, Slate Bryer
`
`and Lawrence Dumm.
`
`Defendant would like to correct and clarify further that Quincy Home Products
`
`provided sales and marketing activities for the Accused Instrumentalities from years 2013
`
`to March 2015. After this time, sales and marketing was transferred to Artesian Home
`
`Products, Inc.
`
`INTERROGATORY N 0.4:
`
`Separately for each PERSON or entity identified in YOUR response to
`
`Interrogatory No. 3, provide a description of each PERSON or entity's involvement
`
`in the design, development, testing, or implementation of each product, service,
`
`
`
`
`
`DEFENDANT ARTESIAN HOME PRODUCTS, INC.’S FIRST SUPPLIEMENTAL RESPONSES TO PLAINTIFF
`GUTTERGLOVE, INC.’S COMMON INTERROGATORIES SET ONE
`CASE NO. 2: l 6-CV—02408-WHO
`
`|PR201 8-00031
`
`9
`
`Petitioners Ex. 1118 p. 9
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`IPR2018-00031
`Petitioners Ex. 1118 p. 9
`
`

`

`system, and method.
`
`RESPONSE TO INTERROGATORY NO. 4
`
`For the Accused Instrumentalities identified in the complaint and infringement
`
`contentions:
`
`
`Person
`
`Involvement
`
`Chris Tatasciore
`
`conception, development, testing, implementation, production
`
`Slate Bryer
`
`conception, development, testing, implementation, production
`
`Larry Dumm
`
`conception, development, testing, implementation, production
`
`John Q. Adams, IV
`
`Sales and Sales Marketing support through Quincy Home
`
`Products, Inc.
`
`Bill Lasell
`
`Brand Marketing support and sales through Artesian Home
`
`Products, Inc
`
`SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 4:
`
`Defendants object to the term “implementation” as being vague and
`
`unintelligible. With the previous objection incorporated into this response, Defendant
`
`responds as follows:
`
`For each product, service, system or method, each person’s involvement is as
`
`follows:
`
`
`Person
`
`Involvement
`
`
`DEFENDANT ARTESIAN HOME PRODUCTS, INC.’S FIRST SUPPLIEMENTAL RESPONSES TO PLAINTIFF
`
`GUTTERGLOVE, INC.’S COMMON INTERROGATORIES SET ONE
`CASE NO. 2:16-CV-02408—WHO
`
`10
`
`|PR201 8-00031
`
`Petitioners Ex. 1118 p. 10
`
`.5;
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`NONU:
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`IPR2018-00031
`Petitioners Ex. 1118 p. 10
`
`

`

`Chris Tatasciore
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`design, conception, development, testing, implementation,
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`production through Defendant ADR.
`
`Slate Bryer
`
`design, conception, development, testing, implementation,
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`production through Defendant ADR.
`
`Larry Dumm
`
`design, conception, development, testing, implementation,
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`production through Defendant ADR.
`
`John Q. Adams, IV
`
`Sales and Sales Marketing support through Quincy Home
`
`Products, Inc.
`
`Bill Lasell
`
`Brand Marketing support and sales through Artesian Home
`
`Products, Inc. from March 2015 to present; non—paid consultant to
`
`Quincy Home Products, July—August 2013.
`
`Ryan Humphries Contract Graphic Artist supplying electronic media
`
`implementation services.
`
`INTERROGATORY NO.5:
`
`IDENTIFY all COMIVIUNICATIONS between YOU and ANY third—party
`
`regarding this ACTION or the patents—in— suit.
`
`RESPONSE TO INTERROGATORY NO. 5
`
`Objection to the extent that any communication is covered under attorney—client
`
`privilege or attorney work product doctrine.
`
`
`
`DEFENDANT ARTESIAN HOME PRODUCTS, INC.’S FIRST SUPPLIEMENTAL RESPONSES TO PLAINTIFF
`GUTTERGLOVE, INC.’S COMMON INTERROGATORIES SET ONE
`CASE NO. 2: 16-CV—02408-WHO
`
`|PR201 8-00031
`
`11
`
`Petitioners Ex. 1118 p. 11
`
`00\IO\Ul-¥>
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`IPR2018-00031
`Petitioners Ex. 1118 p. 11
`
`

`

`Communications between Defendant and any third parties regarding this action or
`
`the patents in suit include:
`
`
`
`28
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`DEFENDANT ARTESIAN HOME PRODUCTS, INCFS FIRST SUPPLIEMENTAL RESPONSES TO PLAINTIFF
`GUTTERGLOVE, INC.’S COMMON INTERROGATORIES SET ONE
`CASE NO. 2:16—CV—02408-WHO
`
`|PR2018—00031
`
`12
`
`Petitioners Ex. 1118 p. 12
`
`IPR2018-00031
`Petitioners Ex. 1118 p. 12
`
`

`

`1
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`SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 5:
`
`Pursuant to the protective order in this case, Defendant designates all responses to
`
`Interrogatory No. 5 as Highly Confidential. Defendant adds flirther information and
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`
`
`clarification as follows:
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`DEFENDANT ARTESIAN HOME PRODUCTS, INC.’S FIRST SUPPLIEMENTAL RESPONSES TO PLAINTIFF
`GUTTERGLOVE, INC.’S COMMON INTERROGATORIES SET ONE
`CASE NO. 2:16-CV-02408-WHO
`
`|PR201 8-00031
`
`13
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`Petitioners Ex. 1118 p. 13
`
`IPR2018-00031
`Petitioners Ex. 1118 p. 13
`
`

`

`
`
`INTERROGATORY No.6:
`
`Separately for each product, service, system, and method identified in
`
`response to Interrogatories Nos. 1 and 2 (including but not limited to the
`
`ACCUSED INSTRUMENTALITIES), describe with specificity all revenues YOU
`
`derived for each such product, service, system, and method identified, including a
`
`breakdown of gross profits, net profits, material costs to manufacture, marketing
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`costs, research and development costs, costs associated with third-party contractors,
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`distribution costs, and ANY other component impacting YOUR ability to
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`specifically ascertain a comprehensive revenue determination.
`
`RESPONSE TO INTERROGATORY NO. 6
`
`The information provided in response to this interrogatory is to be considered
`
`Confidential under the protective order governing this lawsuit.
`
`1) For the Accused Instrumentalities alleged in the complaint and infringement
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`contentions, the Defendant breaks down the following category totals for years
`
`2013-2016:
`
`
`
`
`DEFENDANT ARTESIAN HOME PRODUCTS, INC.’S FIRST SUPPLIEMENTAL RESPONSES TO PLAINTIFF
`GUTTERGLOVE, INC.’S COMMON INTERROGATORIES SET ONE
`CASE NO. 2: 16-CV-02408—WHO
`
`|PR201 8-00031
`
`14
`
`Petitioners Ex. 1118 p. 14
`
`4
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`IPR2018-00031
`Petitioners Ex. 1118 p. 14
`
`

`

`N
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`SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 6:
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`The information provided in response to this interrogatory is to be considered
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`Highly Confidential under the protective order governing this lawsuit.
`
`Due to the broad scope of Plaintiff s discovery demand in defining “Accused
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`lnstrumentalities” Defendant has chosen to give details on all five of its products here
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`(Valor, Bolt, Arrow, Diamond and Superior), Defendant notes that Plaintiff’s
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`complaint and infringement contentions only asserts four of the products as the
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`“Accused Instrumentalities” (Valor, Arrow, Bolt, Diamond); therefore, Defendants
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`reserve their right to object to the introduction into this case of any products not
`
`
`DEFENDANT ARTESIAN HOME PRODUCTS, INC.’S FIRST SUPPLIEMENTAL RESPONSES TO PLAINTIFF
`GUTTERGLOVE, lNC.’S COMMON INTERROGATORIES SET ONE
`CASE NO. 2:16—CV—02408-WHO
`
`15
`
`|PR201 8-00031
`
`Petitioners Ex. 1118 p. 15
`
`IPR2018-00031
`Petitioners Ex. 1118 p. 15
`
`

`

`1
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`included in the complaint and infringement contentions. With the previous objections
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`incorporated into this response, Defendant responds as follows:
`
`bl.»
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`\OOO\]O\
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`DEFENDANT ARTESIAN HOME PRODUCTS, INC.’S FIRST SUPPLIEMENTAL RESPONSES TO PLAINTIFF
`GUTTERGLOVE, INC.’S COMMON INTERROGATORIES SET ONE
`CASE NO. 2:16-CV—02408—WHO
`
`.
`
`l6
`
`|PR2018—00031
`
`Petitioners Ex. 1118 p. 16
`
`IPR2018-00031
`Petitioners Ex. 1118 p. 16
`
`

`

`Artesian (Al-1P) Product Sales and Cost Matrix, Jan 2013 thru May 2017
`
`Brand
`Year
`Gross Sales
`Cost of Goods
`Commissions & Bonus
`Product Rebates
`Telephone
`Advertsing
`Office Supplies
`Ravel
`Meals
`Training
`Salaries
`
`Brand
`Year
`Gross Sales
`Cost of Goods
`Commissions 8: Bonus
`Product Rebates
`Telephone
`Advertising
`Office Supplies
`Travel
`Meals
`Training
`Salaries
`
`Valor Gutter Guards
`2013
`2014
`2015
`
`2016
`
`2017
`
`Arrow Gutter Guards
`
`Bolt Gutter Guards
`2013
`2014
`
`2015
`
`’
`2016
`
`2017
`
`3
`‘
`
`
`
`
`Diamond Gutter Guards
`2013
`2014
`2015
`
`2015
`
`2017 2013‘ 2914
`
`2015
`
`2016‘
`
`2017
`
`Artesian Totals all Brands
`2013
`2014
`2015
`
`2016‘
`
`2017
`
`Note: Bolt sales staned apmox inlm 2015
`Arrow5355 started approx. in Oct 2015
`Diamond 8. Supperior 5315 started approx in Jan. 2016
`
`DATED:
`
`\ July 14, 2017
`
`By:
`
`/s/ John P. Costello
`
`John P. Costello. Esq. (gBN 161511)
`COSTELLO LAW C RPORATION
`2267 Lava Rid e Court, Suite 210
`Roseville, CA 5661
`Telephone: 916 441—2234
`FaCSImfle: 916 441-4254
`Jcostello@coste lolawcorp.com
`
`Attorney for Defendants: AMERICAN
`DIE AND ROLLFORMING, INC and
`
`ARTESIAN HOME PRODUCTS, INC.
`
`
`
`DEFENDANT ARTESIAN HOME PRODUCTS, INC.’S FIRST SUPPLIEMENTAL RESPONSES TO PLAINTIFF
`GUTTERGLOVE, INC.’S COMMON INTERROGATORIES SET ONE
`CASE NO. 2: 16-CV-O2408-WHO
`
`17
`
`|PR2018—00031
`
`Petitioners Ex. 1118 p. 17
`
`OO\]O\
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`\D
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`IPR2018-00031
`Petitioners Ex. 1118 p. 17
`
`

`

`PROOF OF ELECTRONIC SERVICE
`
`I am over the age of 18 and not a party to this action. My business address is:
`
`Costello Law Corporation
`2267 Lava Ridge Court, Suite 210
`Roseville, CA 95661
`
`My electronic service address is: ruma@costellolawcorp.com.
`
`I electronically served the following documents:
`
`DEFENDANT AND COUNTERCLAIMANT AMERICAN
`DIE AND ROLLFORMING, INC.’S, FIRST SUPPLEMENTALRESPONSES TO
`PLAINTIFF AND
`
`COUNTERDEFENDANTGUTTERGLOVE, INC.'S COMMON
`
`INTERROGATORIES SET ONE
`
`I electronically served the documents as follows:
`
`Jacob Song, Esq.
`Electronic serv1ce address of person served: Jacob.song@kutakrock.com
`
`‘
`Sean P. Connolly, Esq., Pro Hac Vice
`Electronic service address of person served: sean.connolly@kutakrock.com
`
`.
`Jason S. Jackson, Esq., Pro Hac Vice
`Electronic serv1ce address of person served: Jason.1ackson@kutakrock.com
`
`Kateaka .Andreyvs
`Electronic serv1ce address of person served: Kateaka.andrewngkutakrockcom
`
`Coleen DeLoa .
`Electronic serv1ce address of person served: coleen.deloa@kutal<rock.com
`
`Mary Clark
`Electronic Service address of person served: mary.clark@kutakrock.com
`
`
`DEFENDANT ARTESIAN HOME PRODUCTS, INC.’S FIRST SUPPLIEMENTAL RESPONSES TO PLAINTIFF
`GUTTERGLOVE, INC.’S COMMON INTERROGATORIES SET ONE
`2
`CASE NO. 2: 16-CV—02408—WHO
`
`18
`
`|PR201 8-00031
`
`Petitioners Ex. 1118 p. 18
`
`I
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`IPR2018-00031
`Petitioners Ex. 1118 p. 18
`
`

`

`1
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`2
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`.|>.
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`\OOG\)O\UI
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`Pursuant
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`to F.R.CiV.P.5, on July 14, 2017,
`
`the documents listed were served
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`electronically on the persons and in the manner described.
`
`I declare under penalty of perjury that I am employed in the office of a member of the
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`bar of this Court at Whose direction this service was made and that the foregoing is
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`true and correct.
`
`Executed on July 14, 2017, at RoseVille, California.
`
`/s/Ruma Costello
`
`Ruma Costello
`
`
`DEFENDANT ARTESIAN HOME PRODUCTS, INC.’S FIRST SUPPLIEMENTAL RESPONSES TO PLAINTIFF
`GUTTERGLOVE, INC.’S COMMON INTERROGATORIES SET ONE
`CASE NO. 2: 16-CV-02408-WHO
`
`|PR201 8-00031
`
`19
`
`Petitioners Ex. 1118 p. 19
`
`IPR2018-00031
`Petitioners Ex. 1118 p. 19
`
`