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

12345678910111213141516171819202122232425262728DOCUMENT REQUEST NO. 19Any and all Documents relating to, regarding, referring to, or reflecting anyinformation or data collected by means of broadband connection or otherwise, fromor about Persons using, the ReplayTV 4000.RESPONSE TO DOCUMENT REQUEST NO. 19Defendants object that this request is overly broad, burdensome and notreasonably calculated to lead to the discovery of admissible evidence. Defendantsobject to the extent Plaintiffs seek information that is protected by users’ individualright of privacy. Defendant objects to the extent Plaintiffs seek confidentialinformation. Defendants further object to the extent the request seeks documentsprotected by attorney-client privilege or work product doctrine.Subject to and without waiving the general or special objections, Defendantsrespond as follows: Defendants do not collect specific information about individualusers or uses; they do collect some limited technical information on an anonymousbasis about the functioning of the ReplayTV devices. Defendants will producedocuments sufficient to show the type of technical information collected when amutually agreeable protective order has been entered.PARAMOUNT INTERROGATORY NO. 10Please identify each Audiovisual Work viewed, copied, received, distributed,or stored, in whole or in part, by or through the use of any ReplayTV 4000 for anypurpose (including but not limited to the purposes of testing, reviewing, sampling,advertising, promoting, or evaluating the features of the ReplayTV 4000).33