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

12345678910111213141516171819202122232425262728viewing of copyright protected programming, including, without limitation,programming containing Macrovision or any other similar protection, whetherdigital or analog.RESPONSE TO DOCUMENT REQUEST NO. 20Defendants object on the ground that the demand is overly broad,burdensome and not reasonably calculated to lead to the discovery of admissibleevidence. Defendants object to the extent 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 special objections, Defendantrespond as follows: Defendants will produce documents sufficient to show theability of the ReplayTV 4000 to limit or prevent the copying, sending, or receipt ofcopyright protected programming. Defendants will not produce confidentialdocuments until a mutually agreeable protective order has been entered.B. Plaintiffs’ Contentions Regarding the Requests At IssueThese requests seek documents about the actual or potential capabilities ofthe ReplayTV 4000 -- the product at the heart of this case. Plaintiffs seek alldocuments relating to the actual or proposed features or functions of the ReplayTV4000 (Request No. 4); all documents relating to the development, design, andtesting of the ReplayTV 4000 as a whole (Request Nos. 9 and 15), and relating toindividual features such as Send Show, AutoSkip, and PC Connectivity (RequestNos. 10-14); and all documents relating to the design decisions made byDefendants about whether and how to encourage -- or to prevent -- their customersfrom copying or distributing copyrighted programming with the ReplayTV 4000(Request Nos. 5-6, 20).15