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

12345678910111213141516171819202122232425262728oppressive 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, Defendant,respond as follows: See Response to Request No. 9.DOCUMENT REQUEST NO. 14Any 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 any Programming Guide orother on-screen menu intended for use with the ReplayTV 4000.RESPONSE TO DOCUMENT REQUEST NO. 14Defendants object on the ground that this request is duplicative of RequestNo. 9. Defendants object on the ground that demand for “ [a]ny and all Document,relating to, regarding, or referring to the development, technical design, conceptualdesign, testing. . .use, function, operation, or content” of the programming guidefeature is overly broad, burdensome, and harassing. Plaintiffs’ request is alsooppressive and not reasonably calculated to lead to the discovery of admissibleevidence. Defendants object that the phrase “ other on-screen menu” is vague,ambiguous and unintelligible. Defendants interpret this request as seekingdocuments regarding the programming guide for the ReplayTV 4000 and limit theirresponse accordingly. Defendants further object on the ground that Plaintiffs seekconfidential documents. Defendants object to the extent Plaintiffs seek documentsprotected by attorney-client privilege, work product doctrine or any other applicableprivilege.13