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

12345678910111213141516171819202122232425262728V. Documents and Information Relating to Review or Evaluation of theReplayTV 4000A. The Requests At IssueDOCUMENT REQUEST NO. 29Any and all Documents relating to, regarding, referring to, or reflecting thesubmission of the ReplayTV 4000, demonstration materials, or other materialsdescribing the ReplayTV 4000 or its capabilities to a third party for competition,review or evaluation, including without limitation for purposes of any scientific,technological, engineering, or artistic award or recognition.RESPONSE TO DOCUMENT REQUEST NO. 29Defendants 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. Plaintiffsfurther object that the request is overly broad, burdensome and harassing.Defendants object that the request, including but not limited to the terms“ demonstration materials” or “ other materials” without further definition, is vagueand ambiguous. Defendants further object that Plaintiffs seek confidentialdocuments. Confidential documents will not be produced until the parties haveentered into a mutually agreeable protective order.Subject to and without waiving the general or specific objections, Defendantswill produce documents sufficient to show the materials provided to third partiesfor competition, review or evaluation, including any scientific, technological,engineering, or artistic award or recognition. Defendants will not produceconfidential documents until a mutually agreeable protective order has beenentered.87