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

12345678910111213141516171819202122232425262728generating “ advertising” for the ReplayTV 4000. This ignores the seven otherpeople principally involved in marketing as well as all other persons who reporteddirectly or indirectly to those identified. Plaintiffs also overlook the fact that theyhave requested all documents about sales.Moreover, Plaintiffs have not agreed to limit Defendants’ production tomerely persons principally involved. Plaintiffs’ request is drafted so broadly that itreaches everything in any file or hard drive of any person in sales, marketing, orpublic relations. Obtaining all these materials from anyone who assisted in theseareas over several years and reviewing and processing the documents, is a realexpense and imposition on a resource-constrained company with no correspondingbenefit.Defendants respectfully request that this Court deny Plaintiffs’ motion tocompel on Request No. 26, or at most, limit Defendants’ obligation to produce tothose employees principally involved in marketing activities at SONICblue and/orReplayTV.VII. Documents Relating to Efforts by Defendants to Obtain Licenses ForAudiovisual WorksA. The Requests At IssueDOCUMENT REQUEST NO. 25Any and all Documents relating to, regarding, referring to, or reflecting anylicense agreement that You have entered into, attempted to enter into, or consideredentering into, with respect to any Audiovisual Works or content for use inconnection with any of Your products or services.97