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

12345678910111213141516171819202122232425262728Subject to and without waiving the general or specific objections, Defendantrespond as follows: See Response to Request No. 9.DOCUMENT REQUEST NO. 11Any 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 AutoSkip Feature.RESPONSE TO DOCUMENT REQUEST NO. 11Defendants object on the ground that this request is duplicative of RequestNo. 9. Defendants 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 AutoSkip feature isoverly broad, burdensome, and harassing. Plaintiffs’ request is also oppressive andnot reasonably calculated to lead to the discovery of admissible evidence.Defendants object on the ground that Plaintiffs seek confidential documents.Defendants object to the extent Plaintiffs seek documents protected by attorneyclientprivilege, work product doctrine or any other applicable privilege.Subject to and without waiving the general or specific objections, Defendantsrespond as follows: See Response to Request No. 9.DOCUMENT REQUEST NO. 12Any 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 Search and RecordFeatures.11