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

12345678910111213141516171819202122232425262728DISNEY INTERROGATORY NO. 15Please identify each occasion on which You have submitted the ReplayTV4000, demonstration materials, or other materials describing ReplayTV 4000 or itscapabilities to a third party for competition, review, or evaluation, including forpurposes of any scientific, technological, engineering, or artistic award orrecognition.RESPONSE TO DISNEY INTERROGATORY NO. 15Defendants 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 has submitted the ReplayTV, “ demonstration materials” , or “ othermaterials” for competition, review or evaluation the ReplayTV 4000 is overly broadand unduly burdensome. Defendants further object that the interrogatory, includingbut not limited to the terms “ demonstration materials” or “ other materials” withoutfurther definition, is vague and ambiguous. Defendants further object that Plaintiffsseek confidential information. Confidential information will not be produced untilthe parties have entered into a mutually agreeable protective order.B. Plaintiffs’ Contentions Regarding The Requests At IssueIn these requests (Document Request No. 29 and Disney Interrogatory No.15), Plaintiffs seek a full set of documents relating to Defendants’ submissionsabout the ReplayTV 4000 to various third parties for purposes of technical reviewsor awards. The materials covered by these requests include, for example, allcommunications between Defendants and Macrovision Corporation, and all internaldocuments in Defendants’ files relating to those communications. (Defendants88