Case 5:18-md-02834-BLF Document 503-1 Filed 08/23/19 Page 1 of 47
`Case 5:18—md-02834-BLF Document 503-1 Filed 08/23/19 Page 1 of 47
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`EXHIBIT 1
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`EXHIBIT 1
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`Case 5:18-md-02834-BLF Document 503-1 Filed 08/23/19 Page 2 of 47
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`J. DAVID HADDEN (CSB No. 176148)
`dhadden@fenwick.com
`SAINA S. SHAMILOV (CSB No. 215636)
`sshamilov@fenwick.com
`TODD R. GREGORIAN (CSB No. 236096)
`tgregorian@fenwick.com
`PHILLIP J. HAACK (CSB No. 262060)
`phaack@fenwick.com
`RAVI R. RANGANATH (CSB No. 272981)
`rranganath@fenwick.com
`SHANNON E. TURNER (CSB No. 310121)
`sturner@fenwick.com
`CHIEH TUNG (CSB No. 318963)
`ctung@fenwick.com
`FENWICK & WEST LLP
`Silicon Valley Center
`801 California Street
`Mountain View, CA 94041
`Telephone:
`650.988.8500
`Facsimile:
`650.938.5200
`
`Counsel for Defendant
`TWITCH INTERACTIVE, INC.
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`
`IN RE PERSONALWEB TECHNOLOGIES, LLC,
`ET AL., PATENT LITIGATION
`
`PERSONALWEB TECHNOLOGIES, LLC and
`LEVEL 3 COMMUNICATIONS, LLC,
`Plaintiffs,
`
`
`
` Case No. 5:18-md-02834-BLF
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`Case No. 5:18-cv-05619-BLF
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`DEFENDANT TWITCH
`INTERACTIVE, INC.’S
`RESPONSES AND OBJECTIONS TO
`PERSONALWEB TECHNOLOGIES,
`INC.’S FIRST SET OF REQUESTS
`FOR PRODUCTION
`
`v.
`TWITCH INTERACTIVE, INC.,
`Defendant.
`
`PROPOUNDING PARTY:
`RESPONDING PARTY:
`SET NUMBER:
`
`
`PERSONALWEB TECHNOLOGIES, INC.
`TWITCH INTERACTIVE, INC.
`ONE (1-34)
`
`TWITCH’S RESPONSES AND OBJECTIONS TO
`FIRST SET OF REQUESTS FOR PRODUCTION
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`Case 5:18-md-02834-BLF Document 503-1 Filed 08/23/19 Page 3 of 47
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`Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure, Twitch Interactive,
`Inc. (hereafter, “Twitch”), by and through their counsel, hereby responds to Plaintiffs, of Personal
`Web Technologies, LLC (“PersonalWeb”), First Set of Requests for Production (Nos. 1-34) as
`follows:
`
`GENERAL OBJECTIONS
`The following general objections are stated with respect to each and every document request
`whether or not specifically identified in response thereto. To the extent any of these general
`objections are not raised in any particular response, Twitch does not waive those objections.
`1.
`Twitch objects to each and every definition and request as overly broad, unduly
`burdensome, and not proportional to the needs of the case because they are not limited to a specific
`geographic area. Twitch will only provide discovery with respect to the United States.
`2. Twitch objects to the definitions of “You,” “Your,” or “Twitch” because it seeks to
`broaden the scope of allowable discovery and seeks information that is not within the possession,
`custody, or control of Twitch, but is in the possession of third-parties and non-parties to this lawsuit.
`Twitch further objects to the definition of these terms to the extent it includes Twitch’s attorneys
`and patent agents and seeks privileged and attorney-work product information. Twitch will interpret
`these terms as referring to Twitch Interactive, Inc. only.
`3.
`Twitch objects to the definition of “Fingerprint” as vague and ambiguous, overly
`broad, unduly burdensome, and not proportional to the needs of the case, as it does not identify the
`item or feature with specificity. Twitch will interpret this term as a Ruby on Rails fingerprint or a
`similar value that is calculated via a hash algorithm and that renders the name of a file dependent
`on the contents of the file.
`5.
`Twitch objects to the definition of “Meeting” as overly broad and unduly
`burdensome, vague and ambiguous, not proportional to the needs of this case, and failing to
`describe the information sought with reasonable particularity.
`6.
`Twitch objects to the definition of “Identify” and “Identity” as overly broad and
`unduly burdensome, vague and ambiguous, not proportional to the needs of this case, and failing
`to describe the information sought with reasonable particularity. Twitch will interpret these terms
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`TWITCH’S RESPONSES AND OBJECTIONS TO
`FIRST SET OF REQUESTS FOR PRODUCTION
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`as “List the person, entity, or document” and “the name, term, or number referring to the person,
`entity, or document,” respectively.
`7.
`Twitch objects to the definition of “Document” as overly broad and unduly
`burdensome, vague and ambiguous, not proportional to the needs of this case, and failing to
`describe the information sought with reasonable particularity. Twitch will not search for documents
`that are not within its possession, custody, or control.
`8.
`Twitch objects to the definition of “Thing” as overly broad and unduly burdensome,
`vague and ambiguous, not proportional to the needs of this case, and failing to describe the
`information sought with reasonable particularity.
`9.
`Twitch objects to the definition of “Cache-Busting” as vague, ambiguous, overly
`broad, unduly burdensome, and not proportional to the needs of the case as it does not identify the
`item or feature with specificity, and PersonalWeb does not explain what is meant by “valid”
`content.
`
`10.
`Twitch objects to these requests and definitions to the extent that they seek to impose
`duties beyond those required by the Federal Rules of Civil Procedure and the Local Rules of this
`district. Twitch’s responses shall be made only in accordance with the applicable rule(s).
`11.
`Twitch objects to these requests to the extent that they seek information equally
`available to PersonalWeb in the public domain or that is already in the possession, custody, or
`control of PersonalWeb.
`12.
`Twitch objects to these requests to the extent that they seek information that is in
`the possession, custody, or control of parties over whom Twitch has no control.
`13.
`Twitch objects to each and every instruction, definition, and request to the extent
`that it seeks the disclosure of information protected by the attorney-client privilege, the attorney
`work-product doctrine, or any other applicable privilege, immunity, or protection, as provided by
`any applicable law. Twitch does not intend to disclose such privileged or protected information.
`Twitch’s inadvertent disclosure of any such information should not be deemed a waiver of any
`privilege, immunity, or protection, and Twitch expressly reserves the right to object to the
`introduction at trial or to any other use of such information that may be inadvertently disclosed.
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`TWITCH’S RESPONSES AND OBJECTIONS TO
`FIRST SET OF REQUESTS FOR PRODUCTION
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`Twitch objects to discovery of attorney-client privileged communications after the filing of this
`lawsuit and to discovery of work-product materials generated after the filing of this lawsuit.
`14.
`Twitch objects to these requests to the extent they seek information concerning
`Amazon CloudFront. CloudFront is not accused in PersonalWeb’s counterclaim against
`Amazon.com, Inc. or Amazon Web Services, Inc. (collectively “Amazon”) or in any of the
`complaints against Amazon’s customers, including Twitch; it is accordingly outside the scope of
`discovery in this case. Moreover, PersonalWeb does not have standing to bring claims against
`CloudFront. (See Reply in Support of Motion of Amazon.com, Inc.’s and Amazon Web Services,
`Inc. for Summary Judgment Claims and Defenses Under the Claim Preclusion and Kessler Doctrine
`(Dkt. No. 350) (“Reply”) at 8-10.) To the extent Twitch provides discovery on CloudFront, it does
`so explicitly without waiver of this objection.
`15.
`Twitch objects to these requests to the extent they seek information concerning
`Amazon Simple Storage System (S3). PersonalWeb’s infringement claims against Amazon and its
`customers, including Twitch, are barred by the doctrine of claim preclusion and the Supreme
`Court’s decision in Kessler v. Eldred, 206 U.S. 285 (1907). (See Order Granting in Part and
`Denying in Part Amazon’s Motion for Summary Judgment dated March 13, 2019 (“Summary
`Judgment Order”).) As such, any discovery concerning S3 is outside the scope of discovery in this
`case. To the extent Twitch provides discovery on S3, it does so explicitly without waiver of this
`objection.
`Twitch objects to these requests to the extent they purport to include email. Email
`16.
`production is not required in patent cases, and any request for email is unduly burdensome and not
`proportional to the needs of the case. See, e.g., Court’s [Model] Stipulation & Order Re: Discovery
`of Electronically Stored Information for Patent Litigation (“General ESI production requests . . .
`shall not include email or other forms of electronic correspondence.”).
`17.
`The responses given herein shall not be deemed to waive any claim of privilege or
`immunity Twitch may have as to any response, document, or thing, or any question or right of
`objection as to authenticity, competency, relevancy, materiality, admissibility, or any other
`objection Twitch may have as to a demand for further response to these or other requests, or to any
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`TWITCH’S RESPONSES AND OBJECTIONS TO
`FIRST SET OF REQUESTS FOR PRODUCTION
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`objection to the use of such information, documents, or things in any other proceeding filed after
`the production of such information or documents.
`18.
`Nothing contained herein may be construed as an admission relative to the existence
`or non-existence of any document, and no response may be construed as an admission with respect
`to the relevancy or admissibility in evidence of any statement or characterization contained in these
`requests or respecting the authenticity, competency, relevancy, materiality, or admissibility of any
`document or thing referenced by these requests.
`19.
`Discovery in this matter is ongoing and Twitch reserves the right to revise or
`supplement any response herein.
`20.
`These General Objections are applicable to and are incorporated in each specific
`response herein without further reference. The inclusion of specific objection(s) in response to any
`Requests for Production shall not be construed as a waiver of such objection(s), or any of these
`objections, in any other response.
`
`RESPONSES AND OBJECTIONS
`Subject to the foregoing General Objections, which are incorporated by reference as if set
`forth fully in each and every response, Twitch also specifically responds and objects to the
`Document Request as follows:
`REQUEST FOR PRODUCTION NO. 1:
`All documents showing how You used Content-Based ETags during the Relevant Time
`Period.
`RESPONSE TO REQUEST FOR PRODUCTION NO. 1:
`Twitch incorporates by reference its General Objections as if fully set forth herein. To the
`extent this request seeks information protected by the attorney-client privilege, attorney work
`product doctrine, joint defense privilege, common interest exception, or any other applicable
`privilege, immunity, doctrine or protection, Twitch objects to it and will not provide any such
`information in response. If any information responsive to this request is subject to any
`confidentiality obligations owed by Twitch to any third party, Twitch will provide such information
`only after it complies with those obligations, and, if necessary, only after it obtains the required
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`TWITCH’S RESPONSES AND OBJECTIONS TO
`FIRST SET OF REQUESTS FOR PRODUCTION
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`permission to do so from the third party.
`Twitch objects to this request as vague and ambiguous, not relevant to any claim or defense
`in this action and not proportional to the needs of the case as it lacks geographic limitations. Twitch
`will only respond with respect to the United States.
`Twitch objects to the term “You” on the basis identified in the General Objections above
`and incorporates this basis herein. Twitch will interpret this term to refer to Twitch Interactive,
`Inc. only.
`Twitch objects to the undefined term “Content-Based ETags” as vague and ambiguous,
`overly broad, unduly burdensome, and not proportional to the needs of the case, as it does not
`identify the items or features with specificity. Twitch will interpret this term as ETags calculated
`based on contents of a corresponding file.
`Twitch objects to this request as overly broad, unduly burdensome, and not proportional to
`the needs of the case in seeking all documents concerning how Twitch used “Content-Based
`ETags.”
`Twitch objects to this request to the extent it is duplicative of other discovery requests,
`including but not limited to Interrogatory No. 1.
`Subject to and without waiving any objections, Twitch responds as follows:
`Twitch will produce non-privileged, non-protected documents sufficient to how the
`www.twitch.tv website used ETags calculated based on contents of a corresponding file in HTTP
`requests during the time period of January 8, 2012 to December 26, 2016 for the United States, to
`the extent such documents exist in Twitch’s possession, custody, or control and can be identified
`upon a reasonable search.
`Investigation and discovery are ongoing, and Twitch reserves the right to supplement,
`amend, or modify its response to this request as additional facts are learned and as otherwise
`appropriate.
`REQUEST FOR PRODUCTION NO. 2:
`All documents identifying each major piece of software or hardware You used during the
`Relevant Time Period to generate, store or serve a Content-Based ETag or to process an HTTP
`
`TWITCH’S RESPONSES AND OBJECTIONS TO
`FIRST SET OF REQUESTS FOR PRODUCTION
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`request that included the Content-Based ETag.
`RESPONSE TO REQUEST FOR PRODUCTION NO. 2:
`Twitch incorporates by reference its General Objections as if fully set forth herein. To the
`extent this request seeks information protected by the attorney-client privilege, attorney work
`product doctrine, joint defense privilege, common interest exception, or any other applicable
`privilege, immunity, doctrine or protection, Twitch objects to it and will not provide any such
`information in response. If any information responsive to this request is subject to any
`confidentiality obligations owed by Twitch to any third party, Twitch will provide such information
`only after it complies with those obligations, and, if necessary, only after it obtains the required
`permission to do so from the third party.
`Twitch objects to this request as vague and ambiguous, not relevant to any claim or defense
`in this action and not proportional to the needs of the case as it lacks geographic limitations. Twitch
`will only respond with respect to the United States.
`Twitch objects to the term “You” on the basis identified in the General Objections above
`and incorporates this basis herein. Twitch will interpret this term to refer to Twitch Interactive,
`Inc. only.
`Twitch objects to the undefined term “Content-Based ETags” as vague and ambiguous,
`overly broad, unduly burdensome, and not proportional to the needs of the case, as it does not
`identify the items or features with specificity. Twitch will interpret this phrase as ETags calculated
`based on contents of a corresponding file. Twitch further objects to the undefined term “major piece
`of software or hardware” as overly broad, unduly burdensome, vague, and ambiguous, as it does
`not identify the information sought with sufficient particularity.
`Twitch objects to this request as overly broad, unduly burdensome, and not proportional to
`the needs of the case in seeking all documents concerning “each major piece of software or hard-
`ware” used to generate ETags calculated based on contents of a corresponding file.
`Twitch objects to this request to the extent it is duplicative of other discovery requests,
`including but not limited to Interrogatory No. 1 and Request for Production No. 1.
`Subject to and without waiving any objections, Twitch responds as follows:
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`TWITCH’S RESPONSES AND OBJECTIONS TO
`FIRST SET OF REQUESTS FOR PRODUCTION
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`Twitch will produce non-privileged, non-protected documents sufficient to show the
`www.twitch.tv website used ETags calculated based on contents of a corresponding file in HTTP
`requests during the time period of January 8, 2012 to December 26, 2016 for the United States, to
`the extent such documents exist in Twitch’s possession, custody, or control and can be identified
`upon a reasonable search.
`Investigation and discovery are ongoing, and Twitch reserves the right to supplement,
`amend, or modify its response to this request as additional facts are learned and as otherwise
`appropriate.
`REQUEST FOR PRODUCTION NO. 3:
`All documents showing how You used a Fingerprint during the Relevant Time Period.
`RESPONSE TO REQUEST FOR PRODUCTION NO. 3:
`Twitch incorporates by reference its General Objections as if fully set forth herein. To the
`extent this request seeks information protected by the attorney-client privilege, attorney work
`product doctrine, joint defense privilege, common interest exception, or any other applicable
`privilege, immunity, doctrine or protection, Twitch objects to it and will not provide any such
`information in response. If any information responsive to this request is subject to any
`confidentiality obligations owed by Twitch to any third party, Twitch will provide such information
`only after it complies with those obligations, and, if necessary, only after it obtains the required
`permission to do so from the third party.
`Twitch objects to this request as vague and ambiguous, not relevant to any claim or defense
`in this action and not proportional to the needs of the case as it lacks geographic limitations. Twitch
`will only respond with respect to the United States.
`Twitch objects to the terms “Fingerprint” and “You” on the bases identified in the General
`Objections above and incorporates those bases herein. Twitch will interpret these terms as a Ruby
`on Rails fingerprint or a similar value that is calculated via a hash algorithm and that renders the
`name of a file dependent on the contents of the file and Twitch Interactive, Inc., respectively.
`Twitch objects to this request as overly broad, unduly burdensome, and not proportional to
`the needs of the case in seeking all documents concerning Twitch’s use of Ruby on Rails
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`TWITCH’S RESPONSES AND OBJECTIONS TO
`FIRST SET OF REQUESTS FOR PRODUCTION
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`fingerprints or similar values.
`Twitch objects to this request to the extent it is duplicative of other discovery requests,
`including but not limited to Interrogatory No. 2.
`Subject to and without waiving any objections, Twitch responds as follows:
`Twitch will produce non-privileged, non-protected documents sufficient to show the
`www.twitch.tv website used a Ruby on Rails fingerprint or a similar value that is calculated via a
`hash algorithm and that renders the name of a file dependent on the contents of the file in HTTP
`requests during the time period of January 8, 2012 to December 26, 2016 for the United States, to
`the extent such documents exist in Twitch’s possession, custody, or control and can be identified
`upon a reasonable search.
`Investigation and discovery are ongoing, and Twitch reserves the right to supplement,
`amend, or modify its response to this request as additional facts are learned and as otherwise
`appropriate.
`REQUEST FOR PRODUCTION NO. 4:
`All documents identifying each major piece of software or hardware used during the
`Relevant Time Period to generate, store or serve a Fingerprint or to process an HTTP request that
`included the Fingerprint.
`RESPONSE TO REQUEST FOR PRODUCTION NO. 4:
`Twitch incorporates by reference its General Objections as if fully set forth herein. To the
`extent this request seeks information protected by the attorney-client privilege, attorney work
`product doctrine, joint defense privilege, common interest exception, or any other applicable
`privilege, immunity, doctrine or protection, Twitch objects to it and will not provide any such
`information in response. If any information responsive to this request is subject to any
`confidentiality obligations owed by Twitch to any third party, Twitch will provide such information
`only after it complies with those obligations, and, if necessary, only after it obtains the required
`permission to do so from the third party.
`Twitch objects to this request as vague and ambiguous, not relevant to any claim or defense
`in this action and not proportional to the needs of the case as it lacks geographic limitations. Twitch
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`TWITCH’S RESPONSES AND OBJECTIONS TO
`FIRST SET OF REQUESTS FOR PRODUCTION
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`will only respond with respect to the United States.
`Twitch objects to the term “Fingerprint” on the basis identified in the General Objections
`above and incorporates this basis herein. Twitch will interpret this term as a Ruby on Rails
`fingerprint or a similar value that is calculated via a hash algorithm and that renders the name of a
`file dependent on the contents of the file.
`Twitch further objects to the undefined term “major piece of software or hardware” as
`overly broad, unduly burdensome, vague, and ambiguous, as it does not identify the information
`sought with sufficient particularity.
`Twitch objects to this request to the extent it is duplicative of other requests, including but
`not limited to Interrogatory No. 3.
`Twitch objects to this request as overly broad, unduly burdensome, and not proportional to
`the needs of the case in seeking all documents concerning “each major piece of software or
`hardware” used in connection with Ruby on Rails fingerprints or similar values and processing
`HTTP requests including such fingerprints.
`Subject to and without waiving any objections, Twitch responds as follows:
`Twitch will produce non-privileged, non-protected documents sufficient to show the
`www.twitch.tv website used a Ruby on Rails fingerprint or a similar value that is calculated via a
`hash algorithm and that renders the name of a file dependent on the contents of the file in HTTP
`requests during the time period of January 8, 2012 to December 26, 2016 for the United States, to
`the extent such documents exist in Twitch’s possession, custody, or control and can be identified
`upon a reasonable search.
`Investigation and discovery are ongoing, and Twitch reserves the right to supplement,
`amend, or modify its response to this request as additional facts are learned and as otherwise
`appropriate.
`REQUEST FOR PRODUCTION NO. 5:
`All documents discussing why You used a Content-Based ETag during the Relevant Time
`Period including but not limited to any reason or advantage factored into Your decision to use a
`Content-Based ETag.
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`TWITCH’S RESPONSES AND OBJECTIONS TO
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 5:
`Twitch incorporates by reference its General Objections as if fully set forth herein. To the
`extent this request seeks information protected by the attorney-client privilege, attorney work
`product doctrine, joint defense privilege, common interest exception, or any other applicable
`privilege, immunity, doctrine or protection, Twitch objects to it and will not provide any such
`information in response. If any information responsive to this request is subject to any
`confidentiality obligations owed by Twitch to any third party, Twitch will provide such information
`only after it complies with those obligations, and, if necessary, only after it obtains the required
`permission to do so from the third party.
`Twitch objects to this request as vague and ambiguous, not relevant to any claim or defense
`in this action and not proportional to the needs of the case as it lacks geographic limitations. Twitch
`will only respond with respect to the United States.
`Twitch objects to the terms “You” and “Your” on the basis identified in the General
`Objections above and incorporates those bases herein. Twitch will interpret these term as Twitch
`Interactive, Inc.
`Twitch objects to the term “Content-Based Etags” as vague and ambiguous, overly broad,
`unduly burdensome, and not proportional to the needs of the case, as it does not identify the items
`or features with specificity. Twitch will interpret this term as ETags calculated based on contents
`of a corresponding file. Twitch further objects to the term “advantage” as overly broad, unduly
`burdensome, vague, and ambiguous.
`Twitch objects to this request to the extent it is duplicative of other requests, including but
`not limited to Interrogatory No. 3 and Request For Production Nos. 1-2.
`Twitch objects to this request as overly broad, unduly burdensome, and not proportional to
`the needs of the case in seeking all documents relating to why Twitch used ETags calculated based
`on contents of a corresponding file.
`Subject to and without waiving any objections, Twitch responds as follows:
`Twitch will produce non-privileged, non-protected documents sufficient to show any ben-
`efits of using ETags calculated based on contents of a corresponding file on the www.twitch.tv
`
`TWITCH’S RESPONSES AND OBJECTIONS TO
`FIRST SET OF REQUESTS FOR PRODUCTION
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`website during the time period of January 8, 2012 to December 26, 2016 for the United States, to
`the extent such documents exist in Twitch’s possession, custody, or control and can be identified
`upon a reasonable search.
`Investigation and discovery are ongoing, and Twitch reserves the right to supplement,
`amend, or modify its response to this request as additional facts are learned and as otherwise
`appropriate.
`REQUEST FOR PRODUCTION NO. 6:
`All documents discussing why You used a Fingerprint during the Relevant Time Period
`including but not limited to any reason or advantage factored into Your decision to use a
`Fingerprint.
`RESPONSE TO REQUEST FOR PRODUCTION NO. 6:
`Twitch incorporates by reference its General Objections as if fully set forth herein. To the
`extent this request seeks information protected by the attorney-client privilege, attorney work
`product doctrine, joint defense privilege, common interest exception, or any other applicable
`privilege, immunity, doctrine or protection, Twitch objects to it and will not provide any such
`information in response. If any information responsive to this request is subject to any
`confidentiality obligations owed by Twitch to any third party, Twitch will provide such information
`only after it complies with those obligations, and, if necessary, only after it obtains the required
`permission to do so from the third party.
`Twitch objects to this request as vague and ambiguous, not relevant to any claim or defense
`in this action and not proportional to the needs of the case as it lacks geographic limitations. Twitch
`will only respond with respect to the United States.
`Twitch objects to the terms “You,” “Your,” and “Fingerprint” on the bases identified in the
`General Objections above and incorporates those bases herein. Twitch will interpret the first two
`terms as Twitch Interactive, Inc. and the third as a Ruby on Rails fingerprint or a similar value that
`is calculated via a hash algorithm and that renders the name of a file dependent on the contents of
`the file. Twitch objects to the term “advantage” as overly broad, unduly burdensome, vague, and
`ambiguous.
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`TWITCH’S RESPONSES AND OBJECTIONS TO
`FIRST SET OF REQUESTS FOR PRODUCTION
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`Case 5:18-md-02834-BLF Document 503-1 Filed 08/23/19 Page 14 of 47
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`Twitch objects to this request to the extent it is duplicative of other requests, including but
`not limited to Interrogatory No. 3, and Request For Production Nos. 3-4.
`Twitch objects to this request as overly broad, unduly burdensome, and not proportional to
`the needs of the case in seeking all documents relating to why Twitch used Ruby on Rails
`fingerprint or a similar value.
`Subject to and without waiving any objections, Twitch responds as follows:
`Twitch will produce non-privileged, non-protected documents sufficient to show any
`benefits of using Fingerprints calculated based on contents of a corresponding file on the
`www.twitch.tv website during the time period of January 8, 2012 to December 26, 2016 for the
`United States, to the extent such documents exist in Twitch’s possession, custody, or control and
`can be identified upon a reasonable search.
`Investigation and discovery are ongoing, and Twitch reserves the right to supplement,
`amend, or modify its response to this request as additional facts are learned and as otherwise
`appropriate.
`REQUEST FOR PRODUCTION NO. 7:
`All Documents including, but not limited to, deposition testimony summarizing your net
`income, gross revenue, costs of goods sold, and/or operating expenses during the Relevant Time
`Period, broken out monthly or by the lowest level of temporal aggregation maintained in the
`ordinary course of business, for each distinct source of revenue that you track in the ordinary course
`of business.
`RESPONSE TO REQUEST FOR PRODUCTION NO. 7:
`Twitch incorporates by reference its General Objections as if fully set forth herein. To the
`extent this request seeks information protected by the attorney-client privilege, attorney work
`product doctrine, joint defense privilege, common interest exception, or any other applicable
`privilege, immunity, doctrine or protection, Twitch objects to it and will not provide any such
`information in response. If any information responsive to this request is subject to any
`confidentiality obligations owed by Twitch to any third party, Twitch will provide such information
`only after it complies with those obligations, and, if necessary, only after it obtains the required
`
`TWITCH’S RESPONSES AND OBJECTIONS TO
`FIRST SET OF REQUESTS FOR PRODUCTION
`
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`