Case 5:15-cv-02008-EJD Document 85-12 Filed 04/13/16 Page 1 of 11
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`EXHIBIT 10
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`DECLARATION OF MELODY DRUMMOND HANSEN
`IN SUPPORT OF DEFENDANT APPLE INC.’S MOTION
`TO PRECLUDE RELIANCE ON CERTAIN
`INVENTION DATES AND TO STRIKE CERTAIN ALLEGATIONS
`Case No. 5:15-CV-02008-EJD
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`Case 5:15-cv-02008-EJD Document 85-12 Filed 04/13/16 Page 2 of 11
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`Robert F. McCauley (SBN 162056)
`robert.mccauley@finnegan.com
`Jacob A. Schroeder (SBN 264717)
`jacob.schroeder@finnegan.com
`FINNEGAN, HENDERSON, FARABOW,
` GARRETT & DUNNER, LLP
`3300 Hillview Avenue
`Palo Alto, CA 94304-1203
`Telephone:
`(650) 849-6600
`Facsimile:
`(650) 849-6666
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`Gerald F. Ivey (pro hac vice)
`Smith R. Brittingham IV (pro hac vice)
`Elizabeth A. Niemeyer (pro hac vice)
`John M. Williamson (pro hac vice)
`Rajeev Gupta (pro hac vice)
`Aidan C. Skoyles (pro hac vice)
`Cecilia Sanabria (pro hac vice)
`FINNEGAN, HENDERSON, FARABOW,
` GARRETT & DUNNER, LLP
`901 New York Avenue, NW
`Washington, DC 20001-4413
`Telephone:
`(202) 408-4000
`Facsimile:
`(202) 408-4400
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`Stephen E. Kabakoff (pro hac vice)
`FINNEGAN, HENDERSON, FARABOW,
` GARRETT & DUNNER, LLP
`3500 SunTrust Plaza
`303 Peachtree Street, N.E.
`Atlanta, GA 30308-3263
`Telephone:
`(404) 653- 6400
`Facsimile:
`(404) 653-6444
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`Attorneys for Plaintiffs
`OpenTV, Inc., Nagravision S.A., and Nagra France S.A.S.
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`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN JOSE DIVISION
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`OPENTV, INC., NAGRAVISION S.A., and
`NAGRA FRANCE S.A.S.
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`APPLE INC.,
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`v.
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`Plaintiffs,
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`Defendant.
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`CASE NO. 5:15-cv-02008-EJD (NMC)
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`PLAINTIFFS’ RESPONSES AND
`OBJECTIONS TO DEFENDANT
`APPLE INC.’S FIRST SET OF
`REQUESTS FOR THE PRODUCTION
`OF DOCUMENTS AND THINGS
`(NOS. 1-153)
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`PLAINTIFFS’ RESPONSES TO
`APPLE’S FIRST SET OF REQUESTS FOR PRODUCTION (1-153)
`Case No. 5:15-cv-02008-EJD (NMC)
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`Case 5:15-cv-02008-EJD Document 85-12 Filed 04/13/16 Page 3 of 11
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`PROPOUNDING PARTY: Defendant Apple Inc.
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`RESPONDING PARTY: Plaintiffs OpenTV, Inc., Nagravision S.A., and Nagra France S.A.S.
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`SET NO.:
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`One (Nos. 1-153)
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`Pursuant to Rule 34 of the Federal Rules of Civil Procedure, Plaintiffs OpenTV, Inc.,
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`Nagravision S.A., and Nagra France S.A.S. (collectively, “OpenTV” or “Plaintiffs”) hereby respond
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`and object to the First Set of Requests for the Production of Documents and Things propounded by
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`defendant Apple Inc. (“Apple”) as follows:
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`GENERAL OBJECTIONS
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`1.
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`Plaintiffs object to the definition of “OpenTV” as overly broad, unduly burdensome,
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`and seeking information that is not within OpenTV, Inc.’s possession, custody, or control. Plaintiffs
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`will respond only on behalf of OpenTV, Inc. for requests directed at OpenTV, Inc.
`2.
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`OpenTV objects to the definition of “Nagravision” as overly broad, unduly
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`burdensome, and seeking information that is not within Nagravision S.A.’s possession, custody, or
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`control. Plaintiffs will respond only on behalf of Nagravision S.A. for requests directed at
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`Nagravision S.A.
`3.
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`OpenTV objects to the definition of “Nagra France” as overly broad, unduly
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`burdensome, and seeking information that is not within Nagra France S.A.S.’s possession, custody,
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`or control. Plaintiffs will respond only on behalf of Nagra France S.A.S. for requests directed at
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`Nagra France S.A.S.
`4.
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`OpenTV objects to the definition of “The Kudelski Group” as overly broad, unduly
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`burdensome, and seeking information that is not within Plaintiffs’ possession, custody, or control.
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`Plaintiffs will respond on behalf of OpenTV, Inc., Nagravision S.A., and Nagra France S.A.S. for
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`requests directed at The Kudelski Group.
`5.
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`OpenTV objects to the definition of “you,” “your,” and “Plaintiffs” as overly broad
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`and unduly burdensome, and seeking information that is not within Plaintiffs’ possession, custody,
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`or control. Plaintiffs will respond on behalf of OpenTV, Inc., Nagravision S.A., and Nagra France
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`1
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`PLAINTIFFS’ RESPONSES TO
`APPLE’S FIRST SET OF REQUESTS FOR PRODUCTION (1-153)
`Case No. 5:15-cv-02008-EJD (NMC)
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`Case 5:15-cv-02008-EJD Document 85-12 Filed 04/13/16 Page 4 of 11
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`S.A.S. for requests directed at “you,” “your,” and “Plaintiffs.” Plaintiffs are expressly not responding
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`on behalf of any entity that is not a party to this litigation.
`6.
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`OpenTV objects to all definitions, instructions, and document requests to the extent
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`they seek to impose obligations upon OpenTV that are broader than or inconsistent with the Federal
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`Rules of Civil Procedure and the Local Rules or court orders of the Northern District of California.
`7.
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`OpenTV objects to all definitions, instructions, and document requests to the extent
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`they seek the disclosure of information protected by the attorney-client privilege, attorney work
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`product doctrine, or any other applicable privilege or protection, as provided by any applicable law
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`(sometimes referred to collectively herein as “privileged” information). OpenTV does not intend to
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`produce such privileged or protected documents or information. OpenTV’s inadvertent disclosure of
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`any such documents or information is not to be deemed a waiver of any objection, privilege, or
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`protection, and OpenTV expressly reserves the right to object to the introduction during motion
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`practice, at trial, or any other use of such information that may be disclosed. In addition, OpenTV
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`objects to each request and all other definitions and instructions to the extent they seek and/or
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`require OpenTV to produce a privilege log for documents or information covered by work product
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`protection if such documents or information were created after April 9, 2014, as agreed upon by the
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`parties in the Joint Case Management Statement. See Dkt. No. 57. OpenTV additionally objects to
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`the extent these requests seek a log of privileged communications beyond the requirements of
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`Federal Rule of Civil Procedure 26.
`8.
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`OpenTV objects to all definitions, instructions, and document requests to the extent
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`they are vague, overly broad, unduly burdensome, exceed the boundaries of discoverable
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`information, or fail to describe the information sought with the required reasonable particularity.
`9.
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`OpenTV objects to the definitions, instructions, and document requests to the extent
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`they are overly broad and unduly burdensome and do not include any reasonable limitation as to
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`time.
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`10.
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`OpenTV objects to the definitions, instructions, and document requests to the extent
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`they seek information unbounded as to time and geographic location, in particular to the extent they
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`seeks extraterritorial information.
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`2
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`PLAINTIFFS’ RESPONSES TO
`APPLE’S FIRST SET OF REQUESTS FOR PRODUCTION (1-153)
`Case No. 5:15-cv-02008-EJD (NMC)
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`Case 5:15-cv-02008-EJD Document 85-12 Filed 04/13/16 Page 5 of 11
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`11.
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`OpenTV objects to the definitions, instructions, and document requests to the extent
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`they seek information that is irrelevant, immaterial, not related to any claim or defense, and/or not
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`reasonably calculated to lead to the discovery of admissible evidence, including to the extent they
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`seek information directed to claims that are not at issue in this litigation.
`12.
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`OpenTV objects to the definitions, instructions, and document requests to the extent
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`they seek information that is irrelevant, immaterial, not related to any claim or defense, and/or not
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`reasonably calculated to lead to the discovery of admissible evidence, including to the extent they
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`seek information directed to entities that are not parties to this litigation.
`13.
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`OpenTV objects to all definitions, instructions, and document requests to the extent
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`the burden or expense of the proposed discovery outweighs their likely benefit, given the needs of
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`the case, the amount in controversy, the parties’ resources, the importance of the issues at stake in
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`the litigation, and the importance of the proposed discovery in resolving the issues.
`14.
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`OpenTV objects to all definitions, instructions, and document requests to the extent
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`they seek production of documents that contain confidential financial, proprietary, trade secret, or
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`other confidential or competitively sensitive business information relating to OpenTV or any third
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`party. OpenTV reserves the right to object that certain documents or things are so confidential and
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`sensitive that they will not be produced even pursuant to a protective order.
`15.
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`OpenTV objects to all definitions, instructions, and document requests to the extent
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`they seek to impose upon OpenTV an obligation to investigate or discover information, materials, or
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`documents from third parties or services that are more or equally accessible to Apple. OpenTV will
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`not produce documents in the custody or control of any other persons or non-parties that are not in
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`the possession, custody, or control of OpenTV.
`16.
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`OpenTV objects to all definitions, instructions, and document requests to the extent
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`they seek information that is beyond the scope of this litigation, is not relevant, or that falls outside
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`the parameters of discoverable information under Federal Rule of Civil Procedure 26.
`17.
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`OpenTV objects to each request to the extent it seeks information contrary to the
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`provisions of the Stipulation and Order Regarding Discovery of Electronically Stored Information
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`for Patent Litigation, Dkt. No. 65.
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`3
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`PLAINTIFFS’ RESPONSES TO
`APPLE’S FIRST SET OF REQUESTS FOR PRODUCTION (1-153)
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`Case 5:15-cv-02008-EJD Document 85-12 Filed 04/13/16 Page 6 of 11
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`18.
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`OpenTV objects to the definition of “document” in Definition No. 13 to the extent it
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`encompasses documents that are inaccessible or would require considerable time and expense for
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`OpenTV to procure while not being reasonably calculated to lead to discovery of admissible
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`evidence for the issues in this case.
`19.
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`OpenTV has not yet completed its investigation, collection of information, discovery,
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`and analysis relating to this action. The following responses are based on information known and
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`available to OpenTV at this time. OpenTV reserves the right to modify, change, or supplement its
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`responses and to produce additional evidence at trial.
`20.
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`OpenTV’s agreement to furnish information in response to defendant’s document
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`requests shall not be deemed as an admission regarding the relevance of the requested documents or
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`information, nor is it intended to waive any right to object to the admissibility of such at any time,
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`including during motion practice or at trial. OpenTV’s agreement to furnish information is not an
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`admission that such information exists or existed, but is only an agreement to produce such
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`information if it is located after a reasonable search.
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`RESPONSES AND OBJECTIONS
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`REQUEST FOR PRODUCTION NO. 1:
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`All documents and things that relate to any of the OpenTV Asserted Patents or Related
`Patents.
`RESPONSE:
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`OpenTV objects to this request to the extent it seeks information protected from disclosure
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`by the attorney-client privilege, the work product doctrine, and/or any other applicable privilege or
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`protection from discovery. OpenTV further objects to this request as overly broad and unduly
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`burdensome in seeking “[a]ll documents and things” and information about “Related Patents”; to the
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`extent OpenTV agrees to produce responsive documents, it will produce documents that are located
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`after a reasonable search and that are not protected by privilege, the attorney work product doctrine,
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`or any other available privilege or protection. OpenTV further objects to this request as vague,
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`overly broad, and unduly burdensome to the extent it seeks information that is irrelevant, immaterial,
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`not related to any claim or defense, and/or not reasonably calculated to lead to the discovery of
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`PLAINTIFFS’ RESPONSES TO
`APPLE’S FIRST SET OF REQUESTS FOR PRODUCTION (1-153)
`Case No. 5:15-cv-02008-EJD (NMC)
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`Case 5:15-cv-02008-EJD Document 85-12 Filed 04/13/16 Page 7 of 11
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`RESPONSE:
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`OpenTV objects to this request to the extent it seeks information protected from disclosure
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`by the attorney-client privilege, the work product doctrine, and/or any other applicable privilege or
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`protection from discovery. OpenTV further objects to this request as overly broad and unduly
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`burdensome in seeking “[a]ll documents and things that relate to the alleged inventions” and
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`information about “Related Patents”; to the extent OpenTV agrees to produce responsive documents,
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`it will produce documents that are located after a reasonable search and that are not protected by
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`privilege, the attorney work product doctrine, or any other available privilege or protection. OpenTV
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`further objects to this request to the extent it seeks information that is irrelevant, immaterial, not
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`related to any claim or defense, and/or not reasonably calculated to lead to the discovery of
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`admissible evidence. OpenTV further objects to this request to the extent it seeks materials that are
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`not within OpenTV’s possession, custody, or control. OpenTV also objects to this request as
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`cumulative and redundant to other requests, including, but not limited to, Request for Production No.
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`1.
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`Subject to the foregoing general and specific objections, OpenTV will perform a reasonable
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`search of its files and produce relevant, responsive, non-privileged documents, to the extent they
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`exist.
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`REQUEST FOR PRODUCTION NO. 5:
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`All documents and things that relate to the conception, reduction to practice, research,
`development, design, or any related diligence of the alleged inventions claimed in the OpenTV
`Asserted Patents or Related Patents, including any document referring to or purporting to support
`a conception date for any claimed invention before the filing date of any Asserted Patent or
`Related Patent.
`RESPONSE:
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`OpenTV objects to this request to the extent it seeks information protected from disclosure
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`by the attorney-client privilege, the work product doctrine, and/or any other applicable privilege or
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`protection from discovery. OpenTV further objects to this request as overly broad and unduly
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`burdensome in seeking “[a]ll documents and things”, “any document referring to or purporting to
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`support a conception date”, and information about “Related Patents”; to the extent OpenTV agrees to
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`produce responsive documents, it will produce documents that are located after a reasonable search
`PLAINTIFFS’ RESPONSES TO
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`APPLE’S FIRST SET OF REQUESTS FOR PRODUCTION (1-153)
`Case No. 5:15-cv-02008-EJD (NMC)
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`Case 5:15-cv-02008-EJD Document 85-12 Filed 04/13/16 Page 8 of 11
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`and that are not protected by privilege, the attorney work product doctrine, or any other available
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`privilege or protection. OpenTV further objects to this request to the extent it seeks information that
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`is irrelevant, immaterial, not related to any claim or defense, and/or not reasonably calculated to lead
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`to the discovery of admissible evidence. OpenTV further objects to this request to the extent it seeks
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`materials that are not within OpenTV’s possession, custody, or control. OpenTV also objects to this
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`request as cumulative and redundant to other requests, including, but not limited to, Request for
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`Production Nos. 1 and 4.
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`Subject to the foregoing general and specific objections, OpenTV will perform a reasonable
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`search of its files and produce relevant, responsive, non-privileged documents, to the extent they
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`exist.
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`REQUEST FOR PRODUCTION NO. 6:
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`All documents and things that identify the persons involved in the conception, reduction
`to practice, research, development, design, or any related diligence of the alleged inventions
`claimed in the OpenTV Asserted Patents or Related Patents.
`RESPONSE:
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`OpenTV objects to this request to the extent it seeks information protected from disclosure
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`by the attorney-client privilege, the work product doctrine, and/or any other applicable privilege or
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`protection from discovery. OpenTV further objects to this request as overly broad and unduly
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`burdensome in seeking “[a]ll documents and things that identify the persons involved” and
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`information about “Related Patents”; to the extent OpenTV agrees to produce responsive documents,
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`it will produce documents that are located after a reasonable search and that are not protected by
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`privilege, the attorney work product doctrine, or any other available privilege or protection. OpenTV
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`further objects to this request to the extent it seeks information that is irrelevant, immaterial, not
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`related to any claim or defense, and/or not reasonably calculated to lead to the discovery of
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`admissible evidence. OpenTV further objects to this request to the extent it seeks materials that are
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`not within OpenTV’s possession, custody, or control. OpenTV also objects to this request as
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`cumulative and redundant to other requests, including, but not limited to, Request for Production
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`Nos. 1, 4, and 5.
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`8
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`PLAINTIFFS’ RESPONSES TO
`APPLE’S FIRST SET OF REQUESTS FOR PRODUCTION (1-153)
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`Case 5:15-cv-02008-EJD Document 85-12 Filed 04/13/16 Page 9 of 11
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`Subject to the foregoing general and specific objections, OpenTV will perform a reasonable
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`search of its files and produce relevant, responsive, non-privileged documents, to the extent they
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`exist.
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`REQUEST FOR PRODUCTION NO. 7:
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`All documents and things that constitute, refer to, or relate to any notes or notebooks of
`the persons involved in the conception, reduction to practice, research, development, design, or
`any related diligence of the alleged inventions claimed in the OpenTV Asserted Patents or
`Related Patents.
`RESPONSE:
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`OpenTV objects to this request to the extent it seeks information protected from disclosure
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`by the attorney-client privilege, the work product doctrine, and/or any other applicable privilege or
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`protection from discovery. OpenTV further objects to this request as overly broad and unduly
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`burdensome in seeking “[a]ll documents and things that . . . relate to any notes or notebooks of the
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`persons involved” and information about “Related Patents”; to the extent OpenTV agrees to produce
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`responsive documents, it will produce documents that are located after a reasonable search and that
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`are not protected by privilege, the attorney work product doctrine, or any other available privilege or
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`protection. OpenTV further objects to this request to the extent it seeks information that is irrelevant,
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`immaterial, not related to any claim or defense, and/or not reasonably calculated to lead to the
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`discovery of admissible evidence. OpenTV objects to this request as cumulative and redundant to
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`other requests. OpenTV further objects to this request to the extent it seeks materials that are not
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`within OpenTV’s possession, custody, or control. OpenTV also objects to this request as cumulative
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`and redundant to other requests, including, but not limited to, Request for Production Nos. 1, and 4-
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`6.
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`Subject to the foregoing general and specific objections, OpenTV will perform a reasonable
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`search of its files and produce relevant, responsive, non-privileged documents, to the extent they
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`exist.
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`REQUEST FOR PRODUCTION NO. 8:
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`All documents and things that identify the dates when development of the alleged
`inventions claimed in each of the OpenTV Asserted Patents or Related Patents first began,
`including documents sufficient to determine such dates.
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`9
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`PLAINTIFFS’ RESPONSES TO
`APPLE’S FIRST SET OF REQUESTS FOR PRODUCTION (1-153)
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`Case 5:15-cv-02008-EJD Document 85-12 Filed 04/13/16 Page 10 of 11
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`RESPONSE:
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`OpenTV objects to this request to the extent it seeks information protected from disclosure
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`by the attorney-client privilege, the work product doctrine, and/or any other applicable privilege or
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`protection from discovery. OpenTV further objects to this request as overly broad and unduly
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`burdensome in seeking “[a]ll documents and things that identify the dates” and information about
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`“Related Patents”; to the extent OpenTV agrees to produce responsive documents, it will produce
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`documents that are located after a reasonable search and that are not protected by privilege, the
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`attorney work product doctrine, or any other available privilege or protection. OpenTV further
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`objects to this request to the extent it seeks information that is irrelevant, immaterial, not related to
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`any claim or defense, and/or not reasonably calculated to lead to the discovery of admissible
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`evidence. OpenTV further objects to this request to the extent it seeks materials that are not within
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`OpenTV’s possession, custody, or control. OpenTV also objects to this request as cumulative and
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`redundant to other requests, including, but not limited to, Production Nos. 1, and 4-7.
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`Subject to the foregoing general and specific objections, OpenTV will perform a reasonable
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`search of its files and produce relevant, responsive, non-privileged documents, to the extent they
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`exist.
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`REQUEST FOR PRODUCTION NO. 9:
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`All documents and things that relate to any litigation, administrative proceeding, dispute,
`or negotiation in the United States or any foreign country relating to the OpenTV Asserted
`Patents or Related Patents, including all documents filed or lodged with the court, written
`discovery documents, testimony (including deposition transcripts, trial transcripts, hearing
`transcripts, declaration and affidavits), claim charts, expert reports, settlement agreements, and
`prior art received or produced by you.
`RESPONSE:
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`OpenTV objects to this request to the extent it seeks information protected from disclosure
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`by the attorney-client privilege, the work product doctrine, and/or any other applicable privilege or
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`protection from discovery. OpenTV further objects to this request as overly broad and unduly
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`burdensome in seeking “[a]ll documents and things” and information about “Related Patents”; to the
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`extent OpenTV agrees to produce responsive documents, it will produce documents that are located
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`after a reasonable search and that are not protected by privilege, the attorney work product doctrine,
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`PLAINTIFFS’ RESPONSES TO
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`Case No. 5:15-cv-02008-EJD (NMC)
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`Case 5:15-cv-02008-EJD Document 85-12 Filed 04/13/16 Page 11 of 11
`
`FINNEGAN, HENDERSON, FARABOW,
` GARRETT & DUNNER, LLP
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`
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`
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`By: /s/ Robert McCauley
`
`
`Robert F. McCauley (SBN 162056)
`robert.mccauley@finnegan.com
`Jacob A. Schroeder (SBN 264717)
`jacob.schroeder@finnegan.com
`FINNEGAN, HENDERSON, FARABOW,
` GARRETT & DUNNER, LLP
`3300 Hillview Avenue
`Palo Alto, CA 94304-1203
`Telephone:
`(650) 849-6600
`Facsimile:
`(650) 849-6666
`
`Gerald F. Ivey (pro hac vice)
`Smith R. Brittingham IV (pro hac vice)
`Elizabeth A. Niemeyer (pro hac vice)
`John M. Williamson (pro hac vice)
`Rajeev Gupta (pro hac vice)
`Aidan C. Skoyles (pro hac vice)
`Cecilia Sanabria (pro hac vice)
`FINNEGAN, HENDERSON, FARABOW,
` GARRETT & DUNNER, LLP
`901 New York Avenue, NW
`Washington, DC 20001-4413
`Telephone:
`(202) 408-4000
`Facsimile:
`(202) 408-4400
`
`Stephen E. Kabakoff (pro hac vice)
`FINNEGAN, HENDERSON, FARABOW,
` GARRETT & DUNNER, LLP
`3500 SunTrust Plaza
`303 Peachtree Street, N.E.
`Atlanta, GA 30308-3263
`Telephone:
`(404) 653- 6400
`Facsimile:
`(404) 653-6444
`
`Attorneys for Plaintiffs
`OpenTV, Inc., Nagravision S.A., and Nagra France
`S.A.S.
`
`104
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`PLAINTIFFS’ RESPONSES TO
`APPLE’S FIRST SET OF REQUESTS FOR PRODUCTION (1-153)
`Case No. 5:15-cv-02008-EJD (NMC)
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`Dated: December 23, 2015
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