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

12345678910111213141516171819202122232425262728RESPONSE TO DOCUMENT REQUEST NO. 28Defendants object on the ground that demand for “ [a]ny and all Documentsrelating to, regarding, referring to, or reflecting any Communications between Youand any investment analyst, research analyst, securities dealer, or securities brokerregarding You” or any of Your products or services is overly broad, burdensomeand harassing. Defendants further 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. Therefore, Plaintiffs’ request is notreasonably calculated to lead to the discovery of admissible evidence. Defendantsobject to the extent Plaintiffs seek confidential documents. Defendants object to theextent Plaintiffs seek documents protected by attorney-client privilege, workproduct doctrine or any other applicable privilege.DISNEY INTERROGATORY NO. 11Please identify each occasion on which You have described or otherwisepromoted the ReplayTV 4000 to investment analysts, research analysts, securitiesdealers, or securities brokers.RESPONSE TO DISNEY INTERROGATORY NO. 11Defendants object to this interrogatory on the ground that it seeksinformation that is irrelevant to any of the claims or defenses in Plaintiffs’ suit andis not reasonably calculated to lead to the discovery of admissible evidence.Plaintiffs request for identification of “ each occasion” in which anyone at eithercompany “described” or “otherwise promoted” the ReplayTV 4000 is overlybroad, unduly burdensome and oppressive. Defendants also object that the term“ described” without further definition is vague and ambiguous. Defendants objectthat the interrogatory fails to distinguish between incidental mention of the71