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

12345678910111213141516171819202122232425262728reasonably calculated to lead to the discovery of admissible evidence. Defendantsobject to the extent that the request embodies numerous technologies, whichPlaintiffs do not challenge in this action, including the mute button, remote channelchanger, fast forward, and other techniques for omitting or skipping commercialsother than Auto-Skip. Defendants object on the ground that Plaintiffs seekconfidential documents. Confidential documents will not be produced until theparties have entered into a mutually agreeable protective order. Defendants objectto the extent Plaintiffs seek documents protected by attorney-client privilege, workproduct doctrine or any other applicable privilege.Subject to and without waiving the general or specific objections, Defendantsrespond as follows: Defendants will produce documents sufficient to showagreements or discussions regarding the licensing or conveyance of Auto SkipDefendants have not licensed any technology that permits a user to sendAudiovisual Works to others by any means and therefore do not have anydocuments responsive to that portion of the request. Defendants will not produceconfidential documents until a mutually agreeable protective order has beenentered.DOCUMENT REQUEST NO. 8Any and all Documents relating to, regarding, referring to, or reflecting anycontract, agreement, offer, invitation, solicitation, proposal, or plan for advertisingon the Programming Guide or any other on screen menu designed or intended foruse with the ReplayTV 4000.RESPONSE TO DOCUMENT REQUEST NO. 8Defendants object that demand for “ [a]ny and all Documents relating to,regarding, referring to, or reflecting any contract, agreement, offer, invitation,68