Paramount Pictures Corporation v. ReplayTV, Inc., Joint Stipulation ...

12345678910111213141516171819202122232425262728requested the contact information in the first place, Defendants’ offer tocompromise should have been more than sufficient to resolve any remainingdispute. Plaintiffs’ continued demand for additional documents and informationcan only be aimed at driving up costs and imposing unnecessary burden onDefendants.VI.Discovery Relating To Defendants’ Marketing, Promotional andAdvertising ActivitiesA. The Requests At IssueDOCUMENT REQUEST NO. 26Any and all Documents relating to, regarding, referring to, or reflecting anyeffort by You to promote, market, advertise, or sell the ReplayTV 4000 (includingbut not limited to any effort conducted through a trade show, promotional event, ormedia event, or via radio, television, Internet, cable, or other media), including butnot limited to all copies of advertising or Marketing materials and any draftsthereof.RESPONSE TO DOCUMENT REQUEST NO. 26Defendants object on the ground that the demand is overly broad,burdensome and not reasonably calculated to lead to the discovery of admissibleevidence. Defendants object to the extent Plaintiffs seek confidential documents.Defendants object to Plaintiffs’ demand for any drafts of any advertising ormarketing materials on the ground that such drafts are not relevant or necessary todetermination of any issue in dispute. Review and production of any drafts isburdensome, oppressive and not reasonably calculated to lead to the discovery ofadmissible evidence. Defendants object to the extent Plaintiffs seek documents92