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

12345678910111213141516171819202122232425262728solicitation, proposal, or plan for advertising on the Programming Guide or anyother on screen menu” 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 confidential documents. Defendants object to the extent Plaintiffs seekdocuments protected by attorney-client privilege, work product doctrine or anyother applicable privilege.DOCUMENT REQUEST NO. 16Any and all Documents relating to, regarding, referring to, or reflecting anyrevenue, compensation, or financial benefit that Defendant has received oranticipates receiving in the future in connection with the ReplayTV 4000, includingbut not limited to sales of advertising space, licensing opportunities, or obtainingpublic or private financing.RESPONSE TO DOCUMENT REQUEST NO. 16Defendants object that the demand for “ [a]ny and all documents relating to,regarding, referring to, or reflecting any revenue, compensation, or financial benefitthat defendant has received or anticipates receiving in the future in connection withthe replaytv 4000” is overly broad, burdensome, and harassing. Plaintiffs’ requestis also oppressive and not reasonably calculated to lead to the discovery ofadmissible evidence, and extends beyond the features challenged in this action.Defendants object that plaintiffs seek documents that are not relevant or necessaryto determination of any of the issues underlying plaintiffs’ suit for injunctive anddeclaratory relief. Defendants object to the extent plaintiffs seek confidential69