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

12345678910111213141516171819202122232425262728promoting, or evaluating the features or functions of the ReplayTV 4000), or as theresult of an ordinary commercial sale.RESPONSE TO DOCUMENT REQUEST NO. 17Defendants object that demand for “ [a]ny and all Documents” relating to theidentity of any person who has been provided access to or use of the ReplayTV4000 “ for any purpose” is overly broad, burdensome, and harassing. Plaintiffs’request is also oppressive and not reasonably calculated to lead to the discovery ofadmissible evidence. Defendants object that Plaintiffs seek documents that are notrelevant or necessary to determination of any of the issues underlying Plaintiffs’suit for injunctive and declaratory relief. Defendants object to the extent Plaintiffsseek information protected by a third party’ s individual right of privacy.Defendants object to the extent Plaintiffs seek confidential documents. Defendantsobject to the extent Plaintiffs seek documents protected by attorney-client privilege,work product doctrine or any other applicable privilege.DOCUMENT REQUEST NO. 31Any and all Documents relating to, regarding, referring to, or reflecting anyorder for purchase of a ReplayTV 4000 that You have received, or any sale of aReplayTV 4000 that You have made.RESPONSE TO DOCUMENT REQUEST NO. 31Defendants object to this request on the ground that it seeks documents thatare irrelevant to any of the claims or defenses in Plaintiffs’ suit and are notreasonably calculated to lead to the discovery of admissible evidence. Even if thesedocuments were relevant (which they are not), Plaintiffs’ demand for “ [a]ny and allDocuments relating to, regarding, referring to, or reflecting any order for purchase60