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

12345678910111213141516171819202122232425262728RESPONSE TO DOCUMENT REQUEST NO. 25Defendants object on the ground that the request is overly broad in that itseeks documents relating to certain license agreements for any of ReplayTV orSONICblue’ s products or services. Defendants further object that none of theinformation demanded is relevant to the claims or defenses in Plaintiffs’ suit and isnot reasonably calculated to lead to the discovery of admissible evidence.Subject to and without waiving the general or specific objections, Defendantsrespond as follows: Defendants have not entered into any license agreements foraudiovisual works or content for use in connection with the ReplayTV 4000 andtherefore do not have documents responsive to this request in their possession,custody or control.DISNEY INTERROGATORY NO. 17Please identify any license agreement that You have entered into with respectto any Audiovisual Works or content (including for each such license agreement thename of each party to the agreement, the date of the agreement, the term of theagreement, and the scope of the agreement) for use in connection with any of Yourproducts or services.RESPONSE TO DISNEY INTERROGATORY NO. 17Defendants object on the ground that the interrogatory is overly broad in thatit seeks information relating to any of ReplayTV or SONICblue’ s products orservices. Defendants further object that none of the information demanded isrelevant to the claims or defenses in Plaintiffs’ suit and is not reasonably calculatedto lead to the discovery of admissible evidence.98