I. NEEL CHATTERJEE (SBN: 173985)
`nchatterjee@orrick.com
`SIDDHARTHA M. VENKATESAN (SBN: 245008)
`svenkatesan@orrick.com
`ANDREW S. ONG (SBN: 267889)
`aong@orrick.com
`ORRICK, HERRINGTON & SUTCLIFFE LLP
`1000 Marsh Road
`Menlo Park, California 94025
`Telephone:
`650-614-7400
`Facsimile:
`650-614-7401
`
`Attorneys for Defendant
`CORELOGIC, INC.
`
`UNITED STATES DISTRICT COURT
`
`NORTHERN DISTRICT OF CALIFORNIA
`
`SAN JOSE DIVISION
`
`BOUNDARY SOLUTIONS, INC., a California
`corporation,
`
`Plaintiff,
`
`v.
`
`CORELOGIC, INC., a Delaware corporation,
`
`Defendant.
`
`Case No. 5:14-cv-00761-PSG
`
`DEFENDANT CORELOGIC, INC.’S
`RESPONSES TO PLAINTIFF
`BOUNDARY SOLUTIONS, INC.’S
`FIRST SET OF REQUESTS FOR
`PRODUCTION OF DOCUMENTS
`(NOS. 1-62)
`
`PROPOUNDING PARTY: BOUNDARY SOLUTIONS, INC.
`
`RESPONDING PARTY:
`
`CORELOGIC, INC.
`
`SET NUMBER:
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`ONE
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`ORRICK, HERRINGTON &
`SUTCLIFFE LLP
`ATTORNEYS AT LAW
`SILICON VALLEY
`
`CORELOGIC’S RESPONSES TO FIRST SET OF
`REQUESTS FOR PRODUCTION (NOS 1-62)
`5:14-CV-00761-PSG
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`CoreLogic Exhibit 1027
`CoreLogic, Inc. v. Boundary Solutions, Inc.
`Trial IPR2015-00228
`
`Page 1 of 37
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`

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`Pursuant to Federal Rules of Civil Procedure 26 and 34, the Local Rules of this Court and
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`any other rules of discovery to which the parties agree in writing or the Court orders, Defendant
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`CoreLogic, Inc. (“CoreLogic” or “Defendant”) hereby responds and objects to Plaintiff Boundary
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`Solutions, Inc.’s (“BSI” or “Plaintiff”) First Set of Requests for Production of Documents (Nos.
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`1-62) (“Requests”) served on September 26, 2014.
`
`CoreLogic’s responses contained herein, and documents, things and other information
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`produced in response to BSI’s Requests, are provided solely for the purpose of discovery in this
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`action. CoreLogic’s responses and productions are not to be used for any purpose outside the
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`context of this lawsuit.
`
`GENERAL OBJECTIONS
`
`CoreLogic incorporates by reference each of the following general objections to BSI’s
`
`Requests into CoreLogic’s response to each individual Request as if fully set forth therein. Any
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`objection or lack of objection to any portion of a Request is not to be deemed an admission that
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`CoreLogic believes any particular documents or things exist or are in its possession, custody or
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`control.
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`1.
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`CoreLogic objects to each and every definition, instruction and request to the
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`extent that it purports to impose duties or obligations upon CoreLogic in excess of or different
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`from the duties and obligations imposed by the Federal Rules of Civil Procedure, the Local Rules
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`of this Court, the Northern District of California’s Stipulation & Order Re: Discovery Of
`
`Electronically Stored Information For Patent Litigation, any other rules of discovery to which the
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`parties agree in writing or the Court orders, and any other applicable law.
`
`2.
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`CoreLogic objects to each and every definition, instruction and request as overly
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`broad and unduly burdensome to the extent that it seeks, individually or collectively, documents
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`or things that are not relevant to any claim or defense of the case and that do not appear
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`reasonably calculated to lead to the discovery of admissible evidence, in contravention of
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`Rule 26(b)(1) of the Federal Rules of Civil Procedure.
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`3.
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`CoreLogic objects to each and every definition, instruction and request to the
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`extent that it seeks disclosure of documents or information protected from disclosure under the
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`- 1 -
`
`CORELOGIC’S RESPONSES TO FIRST SET OF
`REQUESTS FOR PRODUCTION (NOS 1-62)
`5:14-CV-00761-PSG
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`ORRICK, HERRINGTON &
`SUTCLIFFE LLP
`ATTORNEYS AT LAW
`SILICON VALLEY
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`Page 2 of 37
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`attorney-client privilege, the doctrine of work product immunity, the common interest and joint
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`defense privileges, or any other claim of privilege, law or rule (“Privileged documents” or
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`“Privileged Information”). CoreLogic will not disclose Privileged Information in response to
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`these Requests, and CoreLogic’s undertaking to respond to these Requests should be understood
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`to exclude Privileged Information. Any disclosure of Privileged Information is inadvertent and
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`should not be construed to constitute a waiver.
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`4.
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`CoreLogic objects to each and every definition, instruction and request to the
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`extent that it purports to require CoreLogic to account for documents or things that are no longer
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`in its possession, custody or control or in existence, on the grounds that such a requirement is
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`overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of
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`admissible evidence.
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`5.
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`CoreLogic objects to each and every definition, instruction and request to the
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`extent that it purports to require production of documents or things outside the possession,
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`custody or control of CoreLogic, on the grounds that such discovery requests are overly broad,
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`unduly burdensome, oppressive and will cause undue hardship to CoreLogic. For example, many
`
`of BSI’s document requests purport to seek documents and things that may relate to third parties
`
`and third party products.
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`6.
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`CoreLogic further objects to each definition, instruction and request to the extent
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`that it purports to require production of documents or things that are already in Plaintiff’s
`
`possession, known or disclosed to Plaintiff, or which are equally available to Plaintiff
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`independently of CoreLogic.
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`7.
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`CoreLogic objects to each definition, instruction and request to the extent that it is
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`an interrogatory in disguise intended to circumvent the restrictions on the number of
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`interrogatories imposed by the Federal Rules of Civil Procedure and/or Court order.
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`8.
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`CoreLogic objects to the definition of “CoreLogic” as overly broad, unduly
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`burdensome, and as seeking documents or information not within CoreLogic’s possession,
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`custody or control to the extent that it seeks to encompass entities other than CoreLogic or
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`persons not within CoreLogic’s control. CoreLogic will respond only on behalf of CoreLogic,
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`- 2 -
`
`CORELOGIC’S RESPONSES TO FIRST SET OF
`REQUESTS FOR PRODUCTION (NOS 1-62)
`5:14-CV-00761-PSG
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`ORRICK, HERRINGTON &
`SUTCLIFFE LLP
`ATTORNEYS AT LAW
`SILICON VALLEY
`
`Page 3 of 37
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`Inc.
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`9.
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`CoreLogic objects to the definition of “Accused Products” as vague, ambiguous,
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`overly broad and unduly burdensome. The list of products identified in BSI’s Infringement
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`Contentions goes well beyond the scope of the few products identified in BSI’s First Amended
`
`Complaint. In addition, BSI has yet to serve Infringement Contentions that comply with Patent
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`L.R. 3-1, as noted in CoreLogic’s pending motion to strike and for a stay of discovery. For
`
`example, BSI has not provided a separate claim chart for each accused product as required by
`
`Patent L.R. 3-1(c). Thus, CoreLogic to date has been unable to determine how BSI contends each
`
`of the products listed in its Infringement Contentions allegedly infringes any of the asserted
`
`claims. For purposes of responding to these Requests, CoreLogic will interpret “Accused
`
`Products” to mean only those products identified in BSI’s First Amended Complaint: ParcelPoint,
`
`PxPoint, Marcellus Data & Utica Shales Data Suite, Xiance, and CoreLogic’s own use of
`
`www.floodcert.com.
`
`10.
`
`CoreLogic objects to the date, place and format of production set forth in
`
`Plaintiff’s First Set of Requests for Production of Documents. CoreLogic will produce
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`responsive documents and things that do not constitute Privileged Information and are not
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`otherwise objectionable in a reasonable format, and at a mutually agreeable date and place.
`
`11.
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`CoreLogic objects to each and every Request to the extent that it calls for a legal
`
`conclusion or opinion, or call for expert testimony. CoreLogic’s responses should not be
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`construed to provide legal conclusions or opinions.
`
`12.
`
`CoreLogic objects to each and every Request to the extent that it is not sufficiently
`
`limited in time and is thus overly burdensome, oppressive and will cause undue hardship to
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`CoreLogic. CoreLogic will interpret each Request as seeking documents from 2008 to present.
`
`13.
`
`CoreLogic objects to each and every Request to the extent that it is premature in
`
`light of the parties’ agreement(s) regarding the exchange of information and documents and/or the
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`Court’s Scheduling Orders to be entered in this case.
`
`14.
`
`CoreLogic objects to each and every Request to the extent that it is oppressive,
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`harassing, incomprehensible, unduly burdensome, redundant, duplicative and/or cumulative of
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`- 3 -
`
`CORELOGIC’S RESPONSES TO FIRST SET OF
`REQUESTS FOR PRODUCTION (NOS 1-62)
`5:14-CV-00761-PSG
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`ORRICK, HERRINGTON &
`SUTCLIFFE LLP
`ATTORNEYS AT LAW
`SILICON VALLEY
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`other discovery, particularly to the extent it seeks “all” documents and things relating to a
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`particular subject matter. CoreLogic will not search for documents and things from all employees
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`affiliated with it, but rather will limit its search in the first instance to the employees who are
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`likely to have non-duplicative documents and things relevant to the issues in this case.
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`15.
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`CoreLogic objects to each and every Request to the extent that it seeks information
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`or documents that are a matter of public record or are equally obtainable from some other source,
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`including but not limited to Plaintiff, that is equally or more convenient, or equally or less
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`burdensome or expensive. CoreLogic also objects to each and every Request to the extent that
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`the burden or expense of discovery sought outweighs its likely benefit.
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`16.
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`CoreLogic objects to each and every Request to the extent that it seeks to elicit
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`information that comprises third-party proprietary information, trade secrets or other confidential
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`commercial information that CoreLogic is obligated not to disclose.
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`17.
`
`CoreLogic objects to each and every Request to the extent that it seeks CoreLogic
`
`confidential, competitively sensitive, proprietary or trade secret information, which CoreLogic
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`will not disclose until an appropriate protective order establishing procedures and limitations on
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`the handling and dissemination of such information is in place or as the parties otherwise agree.
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`18.
`
`The following responses are based on information reasonably available to
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`CoreLogic as of the date of this response. CoreLogic’s investigation is continuing and ongoing,
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`and CoreLogic expressly reserves the right to revise and/or supplement the responses based on
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`information discovered after the date of this response and to use such information in defending
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`against Plaintiff’s claims at trial or for any other purpose in this litigation.
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`19.
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`All of the foregoing General Objections are incorporated in each of the specific
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`responses to BSI’s Requests set forth below. Where CoreLogic elects specifically to restate some
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`or all of these objections in the specific responses that follow, it does so merely to give further
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`emphasis to the objection. No specific response to any of the Requests is, or shall be deemed, a
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`waiver of CoreLogic’s General Objections.
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`20.
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`CoreLogic, in responding to these Requests, does not make any admissions
`
`relative to the existence of any document or information, to the relevance or admissibility of any
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`- 4 -
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`CORELOGIC’S RESPONSES TO FIRST SET OF
`REQUESTS FOR PRODUCTION (NOS 1-62)
`5:14-CV-00761-PSG
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`SUTCLIFFE LLP
`ATTORNEYS AT LAW
`SILICON VALLEY
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`Page 5 of 37
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`documents or information, or to the truth or accuracy of any statement or characterization
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`contained in BSI’s Requests. CoreLogic expressly reserves all objections as to relevance,
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`competency, materiality, privilege, authenticity, or admissibility of any document or thing.
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`CoreLogic has responded to BSI’s Requests as it interprets and understands them. If BSI
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`subsequently asserts an interpretation of any Request or sub-part thereof that differs from
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`CoreLogic’s understanding of that Request, or sub-part thereof, CoreLogic reserves the right to
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`supplement its objections and/or responses.
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`RESPONSES TO REQUESTS FOR PRODUCTION
`
`REQUEST FOR PRODUCTION NO. 1:
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`Documents sufficient to describe the corporate structure, both inter- and intra-entity, and
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`including ownership and control, of Defendant, and any corporate parents, subsidiaries, affiliates,
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`predecessors or successors thereof.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 1:
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`CoreLogic incorporates by reference its General Objections as if fully set forth herein.
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`CoreLogic further objects that this request is vague as to the time period for the requested
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`documents.
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`Subject to and without waiving the foregoing General and Specific Objections, CoreLogic
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`responds that it will produce non-privileged documents believed to be responsive to this Request
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`that are in its possession, custody or control and that can be located after a reasonable and diligent
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`search.
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`REQUEST FOR PRODUCTION NO. 2:
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`Documents sufficient to show the current organizational structures of Defendant,
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`including, the research and/or development unit(s), departments(s), and division(s) thereof.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 2:
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`CoreLogic incorporates by reference its General Objections as if fully set forth herein.
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`Subject to and without waiving the foregoing General and Specific Objections, CoreLogic
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`responds that it will produce non-privileged documents believed to be responsive to this Request
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`ORRICK, HERRINGTON &
`SUTCLIFFE LLP
`ATTORNEYS AT LAW
`SILICON VALLEY
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`- 5 -
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`CORELOGIC’S RESPONSES TO FIRST SET OF
`REQUESTS FOR PRODUCTION (NOS 1-62)
`5:14-CV-00761-PSG
`
`Page 6 of 37
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`that are in its possession, custody or control and that can be located after a reasonable and diligent
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`search.
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`REQUEST FOR PRODUCTION NO. 3:
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`Documents identifying all customers that have bought or licensed any Accused Product,
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`since February 2008.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 3:
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`CoreLogic incorporates by reference its General Objections as if fully set forth herein.
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`CoreLogic further objects that the term “customers” is vague and ambiguous and CoreLogic will
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`interpret this term to cover third parties that have direct customer relationships with CoreLogic.
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`Subject to and without waiving the foregoing General and Specific Objections, CoreLogic
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`responds that it will produce non-privileged documents sufficient to identify customers of the
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`products identified in BSI’s First Amended Complaint.
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`REQUEST FOR PRODUCTION NO. 4:
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`Source code, software, and/or documents correlating to source code or software that relate
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`to or are used in connection with the Accused Products. Such documents shall include any data
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`dictionaries, schema, and include the names of tables, fields, relationships, views, indexes,
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`packages, procedures, functions, queues, triggers, types, sequences, materialized views,
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`synonyms, database links, directories, XML schemas, and other elements.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 4:
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`CoreLogic incorporates by reference its General Objections as if fully set forth herein.
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`CoreLogic further objects that the term “correlating” is vague and ambiguous and that CoreLogic
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`will interpret this request to seek CoreLogic source code used in the Accused Products identified
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`in the BSI First Amended Complaint. CoreLogic further objects to the extent this request seeks
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`to impose an obligation on CoreLogic to modify the format it maintains source code in the
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`ordinary course of business.
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`Subject to and without waiving the foregoing General and Specific Objections, CoreLogic
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`responds that it will make available for inspection the source code for the products identified in
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`BSI’s First Amended Complaint at the appropriate CoreLogic location in which the source code
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`- 6 -
`
`CORELOGIC’S RESPONSES TO FIRST SET OF
`REQUESTS FOR PRODUCTION (NOS 1-62)
`5:14-CV-00761-PSG
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`ORRICK, HERRINGTON &
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`ATTORNEYS AT LAW
`SILICON VALLEY
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`Page 7 of 37
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`is maintained following entry of a mutually agreeable Protective Order.
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`REQUEST FOR PRODUCTION NO. 5:
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`Documents sufficient to show the design, development, and implementations of the
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`features and functionality used by the Accused Products, including, but not limited to, any
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`documents that discuss or describe CoreLogic’s decision to include those features in the products
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`or services.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 5:
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`CoreLogic incorporates by reference its General Objections as if fully set forth herein.
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`CoreLogic further objects that this request is vague as to the time period for the requested
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`documents and that the term “CoreLogic’s decision to include those features” vague and
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`ambiguous.
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`Subject to and without waiving the foregoing General and Specific Objections, CoreLogic
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`responds that it will produce non-privileged documents relating to the design, development, and
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`implementation of the products identified in BSI’s First Amended Complaint from 2008 to
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`present to the extent such documents exist, are within CoreLogic’s possession, custody or control,
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`and can be located after a reasonable and diligent search.
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`REQUEST FOR PRODUCTION NO. 6:
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`Documents sufficient to describe Defendant’s policies, procedures and practices regarding
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`the storage and maintenance of documents (including, but not limited to, schematics, circuit
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`diagrams, laboratory notebooks, process flows, data sheets, manuals, and technical specifications)
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`that relate to any Accused Products.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 6:
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`CoreLogic incorporates by reference its General Objections as if fully set forth herein.
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`CoreLogic further objects that this request is vague as to the time period for the requested
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`documents. CoreLogic further objects to this Request to the extent it seeks the production of
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`materials that are not relevant and not reasonably calculated to lead to the discovery of admissible
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`evidence.
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`ORRICK, HERRINGTON &
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`ATTORNEYS AT LAW
`SILICON VALLEY
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`Subject to and without waiving the foregoing General and Specific Objections, CoreLogic
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`- 7 -
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`CORELOGIC’S RESPONSES TO FIRST SET OF
`REQUESTS FOR PRODUCTION (NOS 1-62)
`5:14-CV-00761-PSG
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`responds that it will produce non-privileged documents believed to be responsive to this request
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`to the extent such documents exist, are within CoreLogic’s possession, custody or control, and
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`can be located after a reasonable and diligent search.
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`REQUEST FOR PRODUCTION NO. 7:
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`Documents sufficient to describe Defendant’s document retention policies.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 7:
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`CoreLogic incorporates by reference its General Objections as if fully set forth herein.
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`CoreLogic further objects that this request is vague as to the time period for the requested
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`documents.
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`Subject to and without waiving the foregoing General and Specific Objections, CoreLogic
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`responds that it will produce non-privileged documents believed to be responsive to this request
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`to the extent such documents exist, are within CoreLogic’s possession, custody or control, and
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`can be located after a reasonable and diligent search.
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`REQUEST FOR PRODUCTION NO. 8:
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`All presentations made, and any materials and things provided, to any third party by
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`Defendant that refer or relate to any Accused Product.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 8:
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`CoreLogic incorporates by reference its General Objections as if fully set forth herein.
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`CoreLogic further objects that this request is vague as to the time period for the requested
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`documents and that the term “presentations” is vague and ambiguous and shall be interpreted to
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`refer to sales and marketing related documents.
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`Subject to and without waiving the foregoing General and Specific Objections, CoreLogic
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`responds that it will produce non-privileged documents relating to the products identified in BSI’s
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`First Amended Complaint believed to be responsive to this request from 2008 to the present to the
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`extent such documents exist, are within CoreLogic’s possession, custody or control, and can be
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`located after a reasonable and diligent search.
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`ORRICK, HERRINGTON &
`SUTCLIFFE LLP
`ATTORNEYS AT LAW
`SILICON VALLEY
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`- 8 -
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`CORELOGIC’S RESPONSES TO FIRST SET OF
`REQUESTS FOR PRODUCTION (NOS 1-62)
`5:14-CV-00761-PSG
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`Page 9 of 37
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`REQUEST FOR PRODUCTION NO. 9:
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`Documents sufficient to identify all entities, including any third parties, that are involved
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`in providing products or services that form a part of any Accused Product.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 9:
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`CoreLogic incorporates by reference its General Objections as if fully set forth herein.
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`CoreLogic further objects that this request is vague as to the time period for the requested
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`documents and that the term “involved in providing” is vague and overbroad and seeks
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`information not in CoreLogic’s possession, custody or control.
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`Subject to and without waiving the foregoing General and Specific Objections, CoreLogic
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`responds that it will produce non-privileged documents concerning third party online mapping
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`portals that utilize the products identified in BSI’s First Amended Complaint to the extent
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`CoreLogic is aware of such third party uses, such documents exist, are within CoreLogic’s
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`possession, custody or control, and can be located after a reasonable and diligent search.
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`REQUEST FOR PRODUCTION NO. 10:
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`Documents sufficient to identify the respective role(s), functions, and obligations of all
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`entities, including any third parties, that are involved in providing any part of any Accused
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`Product to any end user.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 10:
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`CoreLogic incorporates by reference its General Objections as if fully set forth herein.
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`CoreLogic further objects that this request is vague as to the time period for the requested
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`documents and that the term “involved in providing” is vague and overbroad and seeks
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`information not in CoreLogic’s possession, custody or control.
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`Subject to and without waiving the foregoing General and Specific Objections, CoreLogic
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`responds that it will produce non-privileged documents concerning third party online mapping
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`portals that utilize the products identified in BSI’s First Amended Complaint to the extent
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`CoreLogic is aware of such third party uses, such documents exist, are within CoreLogic’s
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`possession, custody or control, and can be located after a reasonable and diligent search.
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`ORRICK, HERRINGTON &
`SUTCLIFFE LLP
`ATTORNEYS AT LAW
`SILICON VALLEY
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`- 9 -
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`CORELOGIC’S RESPONSES TO FIRST SET OF
`REQUESTS FOR PRODUCTION (NOS 1-62)
`5:14-CV-00761-PSG
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`Page 10 of 37
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`REQUEST FOR PRODUCTION NO. 11:
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`All agreements between Defendant and any third party(ies) regarding the use of any
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`technology that is a part of any Accused Product.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 11:
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`CoreLogic incorporates by reference its General Objections as if fully set forth herein.
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`CoreLogic further objects that this request is vague as to the time period for the requested
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`documents and that the phrase “use of any technology that is a part of any Accused Product” is
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`vague and overbroad and seeks information not in CoreLogic’s possession, custody or control.
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`Subject to and without waiving the foregoing General and Specific Objections, CoreLogic
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`responds that it will produce non-privileged documents relating to the products identified in BSI’s
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`First Amended Complaint believed to be responsive to this request to the extent such documents
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`exist, are within CoreLogic’s possession, custody or control, and can be located after a reasonable
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`and diligent search.
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`REQUEST FOR PRODUCTION NO. 12:
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`All contracts and agreements (including, but not limited to, indemnity agreements),
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`between Defendant, on one hand, and any other entity(ies), on the other hand, that relate to any
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`Accused Product.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 12:
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`CoreLogic incorporates by reference its General Objections as if fully set forth herein.
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`CoreLogic further objects that the term “relate to any Accused Product” is vague and ambiguous.
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`Subject to and without waiving the foregoing General and Specific Objections, CoreLogic
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`responds that it will produce non-privileged documents relating to the products identified in BSI’s
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`First Amended Complaint believed to be responsive to this request to the extent such documents
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`exist, are within CoreLogic’s possession, custody or control, and can be located after a reasonable
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`and diligent search.
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`REQUEST FOR PRODUCTION NO. 13:
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`All documents that refer or relate to any contract or agreement, between Defendant, on
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`one hand, and any other entity(ies), on the other hand, that relate to any Accused Product.
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`- 10 -
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`CORELOGIC’S RESPONSES TO FIRST SET OF
`REQUESTS FOR PRODUCTION (NOS 1-62)
`5:14-CV-00761-PSG
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`ORRICK, HERRINGTON &
`SUTCLIFFE LLP
`ATTORNEYS AT LAW
`SILICON VALLEY
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 13:
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`CoreLogic incorporates by reference its General Objections as if fully set forth herein.
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`CoreLogic further objects that the term “relate to any Accused Product” is vague and ambiguous.
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`Subject to and without waiving the foregoing General and Specific Objections, CoreLogic
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`responds that it will produce non-privileged documents relating to the products identified in BSI’s
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`First Amended Complaint believed to be responsive to this request to the extent such documents
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`exist, are within CoreLogic’s possession, custody or control, and can be located after a reasonable
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`and diligent search.
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`REQUEST FOR PRODUCTION NO. 14:
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`Documents sufficient to identify the date(s) that Defendant began offering each of the
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`Accused Products, including documents sufficient to identify the date of the first design and use
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`of the features and functionality used by the Accused Products that BSI has alleged infringe on
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`the Patents-in-Suit.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 14:
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`CoreLogic incorporates by reference its General Objections as if fully set forth herein.
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`CoreLogic further objects that the phrase “features and functionality used by the Accused
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`Products” is vague and ambiguous and shall be interpreted to refer to the start date for the steps
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`identified in BSI’s infringement claim charts.
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`Subject to and without waiving the foregoing General and Specific Objections, CoreLogic
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`responds that it will produce non-privileged documents relating to the products identified in BSI’s
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`First Amended Complaint believed to be responsive to this Request to the extent such documents
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`exist, are within CoreLogic’s possession, custody or control, and can be located after a reasonable
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`and diligent search.
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`REQUEST FOR PRODUCTION NO. 15:
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`Documents sufficient to identify, on a quarterly and annual basis since Defendant began
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`offering any of the Accused Products, the total number of those products sold, the total revenues
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`for these products, and the costs incurred and profits received by Defendant in connection with
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`each of these products.
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`28
`ORRICK, HERRINGTON &
`SUTCLIFFE LLP
`ATTORNEYS AT LAW
`SILICON VALLEY
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`- 11 -
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`CORELOGIC’S RESPONSES TO FIRST SET OF
`REQUESTS FOR PRODUCTION (NOS 1-62)
`5:14-CV-00761-PSG
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`Page 12 of 37
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 15:
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`CoreLogic incorporates by reference its General Objections as if fully set forth herein.
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`Subject to and without waiving the foregoing General and Specific Objections, CoreLogic
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`responds that it will produce non-privileged documents relating to the products identified in BSI’s
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`First Amended Complaint believed to be responsive to this Request to the extent such documents
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`exist, are within CoreLogic’s possession, custody or control, and can be located after a reasonable
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`and diligent search.
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`REQUEST FOR PRODUCTION NO. 16:
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`All End User License Agreements (EULA) used in connection with any Accused Product.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 16:
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`CoreLogic incorporates by reference its General Objections as if fully set forth herein.
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`Subject to and without waiving the foregoing General and Specific Objections, CoreLogic
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`responds that it will produce non-privileged documents relating to the products identified in BSI’s
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`First Amended Complaint believed to be responsive to this Request to the extent such documents
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`exist, are within CoreLogic’s possession, custody or control, and can be located after a reasonable
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`and diligent search.
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`REQUEST FOR PRODUCTION NO. 17:
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`All instructions, manuals, guides, or other documentation for the features and
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`functionality used by the Accused Products.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 17:
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`CoreLogic incorporates by reference its General Objections as if fully set forth herein.
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`CoreLogic further objects that the phrase “other documentation” is vague and ambiguous.
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`Subject to and without waiving the foregoing General and Specific Objections, CoreLogic
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`responds that it will produce non-privileged documents relating to the products identified in BSI’s
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`First Amended Complaint believed to be responsive to this Request to the extent such documents
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`exist, are within CoreLogic’s possession, custody or control, and can be located after a reasonable
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`and diligent search.
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`ORRICK, HERRINGTON &
`SUTCLIFFE LLP
`ATTORNEYS AT LAW
`SILICON VALLEY
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`- 12 -
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`CORELOGIC’S RESPONSES TO FIRST SET OF
`REQUESTS FOR PRODUCTION (NOS 1-62)
`5:14-CV-00761-PSG
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`Page 13 of 37
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`REQUEST FOR PRODUCTION NO. 18:
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`Documents sufficient to identify, on a monthly or quarterly basis since Defendant began
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`offering any of the Accused Products, the total revenues and profits received, and costs/expenses
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`incurred, by Defendant in connection with Defendant’s business operations in the United States.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 18:
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`CoreLogic incorporates by reference its General Objections as if fully set forth herein.
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`CoreLogic further objects to the extent this request seeks expert work product concerning
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`CoreLogic’s revenues, profits and/or expenses or otherwise purports to seek documents not
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`maintained by CoreLogic in the ordinary course of business.
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`Subject to and without waiving the foregoing General and Specific Objections, CoreLogic
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`responds that it will produce non-privileged documents relating to the products identified in BSI’s
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`First Amended Complaint believed to be responsive to this Request to the extent such documents
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`exist, are within CoreLogic’s possession, custody or control, and can be located after a reasonable
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`and diligent search.
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`REQUEST FOR PRODUCTION NO. 19:
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`Documents sufficient to identify persons with knowledge about the design, development,
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`testing, manufacturing, operation, and marketing of the Accused Products.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 19:
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`CoreLogic incorporates by reference its General Objections as if fully set forth herein.
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`CoreLogic further objects that this request is vague and overbroad and shall be interpreted to seek
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`documents concerning the design, operation and marketing of the Accused Products identified in
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`BSI’s First Amended Complaint: ParcelPoint, PxPoint, Marcellus Data & Utica Shales Data
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`Suite, Xiance, and CoreLogic’s own use of www.floodcert.com.
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`Subject to and without waiving the foregoing General and Specific Objections, CoreLogic
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`responds that it will produce non-privileged documents relating to the products identified in BSI’s
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`First Amended Complaint believed to be responsive to this Request to the extent such documents
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`exist, are within CoreLogic’s possession, custody or control, and can be located after a reasonable
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`and diligent search.
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`28
`ORRICK, HERRINGTON &
`SUTCLIFFE LLP
`ATTORNEYS AT LAW
`SILICON VALLEY
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`- 13 -
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`CORELOGIC’S RESPONSES TO FIRST SET OF
`REQUESTS FOR PRODUCTION (NOS 1-62)