Case 5:18-md-02834-BLF Document 503-3 Filed 08/23/19 Page 1 of 59
`Case 5:18—md-02834-BLF Document 503-3 Filed 08/23/19 Page 1 of 59
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`EXHIBIT 3
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`EXHIBIT 3
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`Case 5:18-md-02834-BLF Document 503-3 Filed 08/23/19 Page 2 of 59
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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
`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
`
`
`Case No. 5:18-cv-05619-BLF
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`RESPONSES AND OBJECTIONS OF
`TWITCH INTERACTIVE, INC. TO
`PERSONALWEB TECHNOLOGIES,
`LLC’S THIRD SET OF REQUESTS
`FOR PRODUCTION (NOS. 84–115)
`
`v.
`TWITCH INTERACTIVE, INC.,
`Defendant.
`
`PROPOUNDING PARTY:
`RESPONDING PARTY:
`SET NUMBER:
`
`
`PERSONALWEB TECHNOLOGIES, INC.
`TWITCH INTERACTIVE, INC.
`THREE (84–115)
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`TWITCH’S RESPONSES AND OBJECTIONS TO
`THIRD SET OF REQUESTS FOR PRODUCTION
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`Case 5:18-md-02834-BLF Document 503-3 Filed 08/23/19 Page 3 of 59
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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
`PersonalWeb Technologies, LLC (“PersonalWeb”), Third Set of Requests for Production (Nos. 84-
`115) 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 “Accused Instrumentality” because it seeks to
`broaden the scope of allowable discovery and seeks information relating to all of Twitch’s web
`servers, beyond the scope of the accused technology in this action. Twitch will interpret this term
`as referring to Twitch.tv only.
`4.
`Twitch objects to the definition of “Content-Based ETag” 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 an ETag calculated
`based on contents of a corresponding file.
`5.
`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
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`TWITCH’S RESPONSES AND OBJECTIONS TO
`THIRD SET OF REQUESTS FOR PRODUCTION
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`similar value that is calculated via a hash algorithm and that renders the name of a file dependent
`on the contents of the file.
`6.
`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.
`7.
`Twitch objects to the definition of “Relevant Time Period” as overly broad, unduly
`burdensome, and not proportional to the needs of the case. Twitch will interpret this phrase as
`meaning from September 14, 2012 to December 26, 2016.
`8.
`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.
`9.
`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.
`10.
`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.
`
`11.
`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).
`12.
`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.
`13.
`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.
`14.
`Twitch objects to each and every instruction, definition, and request to the extent
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`TWITCH’S RESPONSES AND OBJECTIONS TO
`THIRD SET OF REQUESTS FOR PRODUCTION
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`Case 5:18-md-02834-BLF Document 503-3 Filed 08/23/19 Page 5 of 59
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`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.
`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.
`15.
`Twitch objects to these requests to the extent they purport to include email. Email
`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.”).)
`16.
`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
`objection to the use of such information, documents, or things in any other proceeding filed after
`the production of such information or documents.
`17.
`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.
`18.
`Discovery in this matter is ongoing and Twitch reserves the right to revise or
`supplement any response herein.
`19.
`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
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`TWITCH’S RESPONSES AND OBJECTIONS TO
`THIRD SET OF REQUESTS FOR PRODUCTION
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`Requests for Production shall not be construed as a waiver of such objection(s), or any of these
`objections, in any other response.
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`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. 84:
`All Documents reflecting any use of HTTP by the Accused Instrumentality to deny content
`requested by a Twitch customer or end user who has not paid for the content and/or does not have
`a subscription to access the content.
`RESPONSE TO REQUEST FOR PRODUCTION NO. 84:
`Twitch incorporates by reference its General Objections as if fully set forth herein. Twitch
`objects to this request to the extent it seeks information protected by the attorney-client privilege,
`attorney work-product doctrine, joint defense privilege, common interest exception, duty of
`confidentiality, or any other applicable privilege, immunity, doctrine or protection. Twitch objects
`to this request to the extent it seeks to impose upon Twitch obligations broader than, different from,
`or in addition to those obligations imposed by the Federal Rules, the Local Rules, case law, or any
`applicable order of the Court.
`Twitch objects to this request to the extent it seeks information that is subject to any
`protective order, privacy interest, contractual obligation, or other confidentiality obligation owed
`to any third party. Twitch further objects to this request to the extent that it purports to require
`Twitch to disclose private or personally-identifiable information of its employees, customers, or
`users. Twitch does not intend to provide such information without the consent of the relevant
`persons or a court order.
`Twitch objects to the term “Accused Instrumentality” on the basis identified in the General
`Objections above and incorporates those bases herein. Twitch will interpret “Accused
`Instrumentality” as Twitch.tv only.
`Twitch objects to this request to the extent it seeks information that is neither relevant to
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`TWITCH’S RESPONSES AND OBJECTIONS TO
`THIRD SET OF REQUESTS FOR PRODUCTION
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`any claim or defense in this action nor proportional to the needs of the case. The accused
`instrumentality is a website which necessarily uses HTTP, the required industry standard. Thus,
`this request seeks information that is not accused or related to any infringement theories.
`Twitch objects to this request as overbroad and irrelevant because it is not limited to a
`particular time period and/or geographic area relevant to the case. Twitch objects to this request as
`vague and ambiguous, overly broad, unduly burdensome, and unintelligible in that it seeks “[a]ll
`Documents reflecting any use of HTTP by the Accused Instrumentality” without connection to any
`accused functionality in the case.
`Subject to and without waiving any objections, Twitch responds as follows:
`Twitch will produce non-privileged, non-protected documents sufficient to show the
`technical design, operation, and functionality of the accused features of Twitch.tv during the time
`period of September 14, 2012 to December 26, 2016 for the United States, to the extent such
`documents existed 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. 85:
`All Documents reflecting any use of HTTP by the Accused Instrumentality showing that a
`Twitch customer or end user is authorized to receive or use requested content or showing the
`duration for which cached content is permitted to be used without obtaining reauthorization.
`RESPONSE TO REQUEST FOR PRODUCTION NO. 85:
`Twitch incorporates by reference its General Objections as if fully set forth herein. Twitch
`objects to this request to the extent it seeks information protected by the attorney-client privilege,
`attorney work-product doctrine, joint defense privilege, common interest exception, duty of
`confidentiality, or any other applicable privilege, immunity, doctrine or protection. Twitch objects
`to this request to the extent it seeks to impose upon Twitch obligations broader than, different from,
`or in addition to those obligations imposed by the Federal Rules, the Local Rules, case law, or any
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`TWITCH’S RESPONSES AND OBJECTIONS TO
`THIRD SET OF REQUESTS FOR PRODUCTION
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`applicable order of the Court.
`Twitch objects to this request to the extent it seeks information that is subject to any
`protective order, privacy interest, contractual obligation, or other confidentiality obligation owed
`to any third party. Twitch further objects to this request to the extent that it purports to require
`Twitch to disclose private or personally-identifiable information of its employees, customers, or
`users. Twitch does not intend to provide such information without the consent of the relevant
`persons or a court order.
`Twitch objects to the term “Accused Instrumentality” on the basis identified in the General
`Objections above and incorporates those bases herein. Twitch will interpret “Accused
`Instrumentality” as Twitch.tv only.
`Twitch objects to this request as vague and ambiguous, overly broad, unduly burdensome,
`and unintelligible. For example, Twitch objects to the undefined terms “authorized” and
`“reauthorization” and the use of those terms in this request. To the extent PersonalWeb uses these
`terms to imply its proposed claim constructions, Twitch objects to such use as PersonalWeb’s
`proposed constructions are not supported by the intrinsic and extrinsic evidence and have not been
`adopted by the Court.
`Twitch objects to this request as overbroad and irrelevant because it is not limited to a
`particular time period and/or geographic area relevant to the case. Twitch objects to this request as
`vague and ambiguous, overly broad, unduly burdensome, and unintelligible in that it seeks “[a]ll
`Documents reflecting any use of HTTP by the Accused Instrumentality” without connection to any
`accused functionality in the case.
` Subject to and without waiving any objections, Twitch responds as follows:
`Twitch will produce non-privileged, non-protected documents sufficient to show caching
`parameters used by Twitch.tv during the time period of September 14, 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
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`TWITCH’S RESPONSES AND OBJECTIONS TO
`THIRD SET OF REQUESTS FOR PRODUCTION
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`appropriate.
`REQUEST FOR PRODUCTION NO. 86:
`All Documents showing the arrival or receipt of HTTP Conditional GET Requests at the
`Accused Instrumentality server(s), including server logs showing such arrival and/or receipt, and
`the date or time stamping of same.
`RESPONSE TO REQUEST FOR PRODUCTION NO. 86:
`Twitch incorporates by reference its General Objections as if fully set forth herein. Twitch
`objects to this request to the extent it seeks information protected by the attorney-client privilege,
`attorney work-product doctrine, joint defense privilege, common interest exception, duty of
`confidentiality, or any other applicable privilege, immunity, doctrine or protection. Twitch objects
`to this request to the extent it seeks to impose upon Twitch obligations broader than, different from,
`or in addition to those obligations imposed by the Federal Rules, the Local Rules, case law, or any
`applicable order of the Court.
`Twitch objects to this request to the extent it seeks information that is subject to any
`protective order, privacy interest, contractual obligation, or other confidentiality obligation owed
`to any third party. Twitch further objects to this request to the extent that it purports to require
`Twitch to disclose private or personally-identifiable information of its employees, customers, or
`users. Twitch does not intend to provide such information without the consent of the relevant
`persons or a court order.
`Twitch objects to the term “Accused Instrumentality” on the basis identified in the General
`Objections above and incorporates those bases herein. Twitch will interpret “Accused
`Instrumentality” as Twitch.tv only.
`Twitch objects to this request as overbroad, unduly burdensome, vague, ambiguous,
`exceeding the boundaries of discoverable information, failing to describe the information sought
`with the required reasonable particularity, not proportional to the needs of the case, and/or seeking
`information that is not relevant to any claim or defense in this action to the extent that it seeks
`information about the aspects of the accused technology not specifically accused in PersonalWeb’s
`Infringement Contentions. For example, Twitch objects to the undefined phrase “server logs” as
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`TWITCH’S RESPONSES AND OBJECTIONS TO
`THIRD SET OF REQUESTS FOR PRODUCTION
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`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 objects to this request as overbroad and irrelevant because it is not limited to a
`particular time period and/or geographic area relevant to the case. Twitch objects to this request as
`vague and ambiguous, overly broad, unduly burdensome, and unintelligible in that it seeks “[a]ll
`documents showing the arrival or receipt of HTTP Conditional GET Requests” as the request spans
`several years and Twitch.tv processes numerous transactions daily.
`Subject to and without waiving any objections, Twitch responds as follows:
`Twitch will produce non-privileged, non-protected documents sufficient to show the receipt
`of HTTP Conditional GET requests by Twitch.tv during the time period of September 14, 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. 87:
`All Documents regarding the configuration of Your web server(s) of the Accused
`Instrumentality during the Relevant Time Period, including, without limitation, all configuration
`files and/or configuration parameters as well as any scripts or programs used to manage its
`configuration and/or operation.
`RESPONSE TO REQUEST FOR PRODUCTION NO. 87:
`Twitch incorporates by reference its General Objections as if fully set forth herein. Twitch
`objects to this request to the extent it seeks information protected by the attorney-client privilege,
`attorney work-product doctrine, joint defense privilege, common interest exception, duty of
`confidentiality, or any other applicable privilege, immunity, doctrine or protection. Twitch objects
`to this request to the extent it seeks to impose upon Twitch obligations broader than, different from,
`or in addition to those obligations imposed by the Federal Rules, the Local Rules, case law, or any
`applicable order of the Court.
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`TWITCH’S RESPONSES AND OBJECTIONS TO
`THIRD SET OF REQUESTS FOR PRODUCTION
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`Twitch objects to this request to the extent it seeks information that is subject to any
`protective order, privacy interest, contractual obligation, or other confidentiality obligation owed
`to any third party. Twitch further objects to this request to the extent that it purports to require
`Twitch to disclose private or personally-identifiable information of its employees, customers, or
`users. Twitch does not intend to provide such information without the consent of the relevant
`persons or a court order.
`Twitch objects to the term “Accused Instrumentality” on the basis identified in the General
`Objections above and incorporates those bases herein. Twitch will interpret “Accused
`Instrumentality” as Twitch.tv only.
`Twitch objects to this request as overbroad, unduly burdensome, vague, ambiguous,
`exceeding the boundaries of discoverable information, failing to describe the information sought
`with the required reasonable particularity, not proportional to the needs of the case, and/or seeking
`information that is not relevant to any claim or defense in this action to the extent that it seeks
`information about the aspects of the accused technology not specifically accused in PersonalWeb’s
`Infringement Contentions.
`Twitch objects to this request as vague and ambiguous, overly broad, unduly burdensome,
`and unintelligible. For example, Twitch objects to the undefined phrases “configuration of Your
`web server(s),” “configuration parameters,” and “scripts or programs use to manage its
`configuration and/or operation” as vague and ambiguous, overly broad, unduly burdensome, and
`not proportional to the needs of the case, as they do not identify the items or features with
`specificity.
`Twitch objects to this request as overbroad and irrelevant because it is not limited to a
`particular geographic area relevant to the case. Twitch objects to this request as vague and
`ambiguous, overly broad, unduly burdensome, and unintelligible in that it seeks “[a]ll Documents
`regarding the configuration of Your web server(s)” without connection to any accused functionality
`in the case.
`Subject to and without waiving any objections, Twitch responds as follows:
`Twitch has already made available for inspection, pursuant to the terms of the protective
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`TWITCH’S RESPONSES AND OBJECTIONS TO
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`order, source code reflecting the operation of the accused Twitch.tv website available in the United
`States, including the revisions to that code that existed between September 14, 2012 through
`December 26, 2016.
`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. 88:
`All Documents identifying Your web server(s) of the Accused Instrumentality and/or their
`location during the Relevant Time Period.
`RESPONSE TO REQUEST FOR PRODUCTION NO. 88:
`Twitch incorporates by reference its General Objections as if fully set forth herein. Twitch
`objects to this request to the extent it seeks information protected by the attorney-client privilege,
`attorney work-product doctrine, joint defense privilege, common interest exception, duty of
`confidentiality, or any other applicable privilege, immunity, doctrine or protection. Twitch objects
`to this request to the extent it seeks to impose upon Twitch obligations broader than, different from,
`or in addition to those obligations imposed by the Federal Rules, the Local Rules, case law, or any
`applicable order of the Court.
`Twitch objects to this request to the extent it seeks information that is subject to any
`protective order, privacy interest, contractual obligation, or other confidentiality obligation owed
`to any third party. Twitch further objects to this request to the extent that it purports to require
`Twitch to disclose private or personally-identifiable information of its employees, customers, or
`users. Twitch does not intend to provide such information without the consent of the relevant
`persons or a court order.
`Twitch objects to this request to the extent it seeks information equally available to
`PersonalWeb in the public domain.
`Twitch objects to the term “Accused Instrumentality” on the basis identified in the General
`Objections above and incorporates those bases herein. Twitch will interpret “Accused
`Instrumentality” as Twitch.tv only.
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`TWITCH’S RESPONSES AND OBJECTIONS TO
`THIRD SET OF REQUESTS FOR PRODUCTION
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`Case 5:18-md-02834-BLF Document 503-3 Filed 08/23/19 Page 13 of 59
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`Twitch objects to this request because it is grossly overbroad and is not relevant to any issue
`in this case. For example, the request on its face seeks information relating to web servers that
`Twitch relies on, including their location, even if servers are not directly related to provision of the
`specific Twitch.tv services and features accused in this litigation. Twitch’s use of web server
`networks, without specific limitations to Twitch.tv, is not relevant to this case.
`Twitch objects to this request as vague and ambiguous, overly broad, unduly burdensome,
`and unintelligible. For example, Twitch objects to the undefined phrase “web server(s)” 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 objects to this request as overbroad and irrelevant because it is not limited to a
`particular geographic area relevant to the case. Twitch objects to this request as vague and
`ambiguous, overly broad, unduly burdensome, and unintelligible in that it seeks “[a]ll Documents
`identifying Your web server(s)” without connection to any accused functionality in the case. Twitch
`objects to this request as unreasonably duplicative and/or redundant of Request Nos. 69 and 86.
`Subject to and without waiving any objections, Twitch responds as follows:
`Twitch has already made available for inspection, pursuant to the terms of the protective
`order, source code reflecting the operation of the accused Twitch.tv website available in the United
`States, including the revisions to that code that existed between September 14, 2012 through
`December 26, 2016.
`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. 89:
`All source code and documents regarding the use of Ruby on Rails as part of Your Accused
`Instrumentality.
`RESPONSE TO REQUEST FOR PRODUCTION NO. 89:
`Twitch incorporates by reference its General Objections as if fully set forth herein. Twitch
`objects to this request to the extent it seeks information protected by the attorney-client privilege,
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`TWITCH’S RESPONSES AND OBJECTIONS TO
`THIRD SET OF REQUESTS FOR PRODUCTION
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`Case 5:18-md-02834-BLF Document 503-3 Filed 08/23/19 Page 14 of 59
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`attorney work-product doctrine, joint defense privilege, common interest exception, duty of
`confidentiality, or any other applicable privilege, immunity, doctrine or protection. Twitch objects
`to this request to the extent it seeks to impose upon Twitch obligations broader than, different from,
`or in addition to those obligations imposed by the Federal Rules, the Local Rules, case law, or any
`applicable order of the Court.
`Twitch objects to this request to the extent it seeks information that is subject to any
`protective order, privacy interest, contractual obligation, or other confidentiality obligation owed
`to any third party. Twitch further objects to this request to the extent that it purports to require
`Twitch to disclose private or personally-identifiable information of its employees, customers, or
`users. Twitch does not intend to provide such information without the consent of the relevant
`persons or a court order.
`Twitch objects to this request to the extent it seeks information not in Twitch’s possession,
`custody or control.
`Twitch objects to the term “Accused Instrumentality” on the basis identified in the General
`Objections above and incorporates those bases herein. Twitch will interpret “Accused
`Instrumentality” as Twitch.tv only.
`Twitch objects to this request as overbroad, unduly burdensome, vague, ambiguous,
`exceeding the boundaries of discoverable information, failing to describe the information sought
`with the required reasonable particularity, not proportional to the needs of the case, and/or seeking
`information that is not relevant to any claim or defense in this action to the extent that it seeks
`information about the aspects of the accused technology not specifically accused in PersonalWeb’s
`Infringement Contentions.
`Twitch objects to this request as vague and ambiguous, overly broad, unduly burdensome,
`and unintelligible. For example, Twitch objects to the undefined phrase “the use of Ruby on Rails
`as part of” 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 objects to this request