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

12345678910111213141516171819202122232425262728RESPONSE TO DOCUMENT REQUEST NO. 6Defendants object on the ground that the demand is overly broad,burdensome and not reasonably calculated to lead to the discovery of admissibleevidence. Defendants object on the ground that Plaintiffs seek confidentialdocuments. Defendants object to the extent Plaintiffs seek documents protected byattorney-client privilege, work product doctrine or any other applicable privilege.Subject to and without waiving the general or specific objections, Defendantsrespond as follows: Defendants will produce documents sufficient to showDefendants’ efforts to design, format or structure the ReplayTV 4000 to limit orprevent the copying, sending, or receipt of copyright protected programming for theReplayTV 4000. Defendants will not produce confidential documents until amutually agreeable protective order has been entered.DOCUMENT REQUEST NO. 9Any and all Documents relating to, regarding, or referring to thedevelopment, technical design, conceptual design, testing (including but not limitedto beta-testing), use, function, operation, or content of the ReplayTV 4000 or anyactual or proposed hardware, software, connection, facility, Internet or otherservice, feature, or function included in or used with, or considered for inclusion inor use with, the ReplayTV 4000.RESPONSE TO DOCUMENT REQUEST NO. 9Defendants object on the ground that demand for “ [a]ny and all Documentsrelating to, regarding, or referring to the development, technical design, conceptualdesign, testing. . .use, function, operation, or content” of the ReplayTV 4000 and itshardware, software and every other aspect of the product is overly broad,burdensome, and harassing. Plaintiffs’ request is also oppressive and not9