`FOR THE NORTHERN DISTRICT OF GEORGIA
`ATLANTA DIVISION
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`IRONBURG INVENTIONS LTD. a
`United Kingdom Limited Company,
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`Plaintiff,
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`vs.
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`COLLECTIVE MINDS GAMING
`CO. LTD.,
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`Civil Action No. 1:16-cv-04110-TWT
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`Defendant.
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`DEFENDANT’S OBJECTIONS AND RESPONSES TO PLAINTIFF’S
`SECOND SET OF REQUESTS FOR PRODUCTION
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`Defendant Collective Minds Gaming Co. Ltd (“CMG”) hereby objects and
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`responds to Plaintiff Ironburg Inventions Ltd.’s (“Ironburg”) Second Set of
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`Requests for Production of Documents.
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`General Objections
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`1.(cid:1)
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`CMG objects to Ironburg’s Requests and accompanying instructions to the
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`extent they seek to impose obligations beyond those set forth in Rules 26 and 34 of
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`the Federal Rules of Civil Procedure, any applicable local rules, and any
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`obligations imposed by the Court’s scheduling and discovery orders. CMG will
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`IRONBURG EX2015, Page 1
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`RESPONSE TO REQUEST NO. 116.(cid:1)
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`CMG objects to this Request to the extent it seeks documents covered by the
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`attorney-client privilege, work product doctrine, or other applicable privilege.
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`CMG also objects to this Request as overbroad, irrelevant, and unduly burdensome
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`to the extent it seeks documents irrelevant to the subject matter of this case.
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`In consideration of its general and specific objections, CMG is unaware of
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`any documents responsive to this Request.
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`REQUEST FOR PRODUCTION NO. 117:
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`Any Agreement between CMG and Valve that Refers or Relates to the Action,
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`including but not limited to, any Joint Defense Agreement.
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`RESPONSE TO REQUEST NO. 117.(cid:1)
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`CMG objects to this Request to the extent it seeks documents covered by the
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`attorney-client privilege, work product doctrine, or other applicable privilege.
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`In consideration of its general and specific objections, CMG is unaware of
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`any documents responsive to this Request.
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`REQUEST FOR PRODUCTION NO. 118:
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`Any Agreement between CMG and Valve that Refers or Relates to Collective
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`Minds Gaming Co. Ltd. v. Ironburg Inventions Ltd., IPR2018-00354, including but
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`not limited to, any Joint Defense Agreement.
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`IRONBURG EX2015, Page 2
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`RESPONSE TO REQUEST NO. 118.(cid:1)
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`CMG objects to this Request to the extent it seeks documents covered by the
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`attorney-client privilege, work product doctrine, or other applicable privilege.
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`In consideration of its general and specific objections, CMG is unaware of
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`any documents responsive to this Request.
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`REQUEST FOR PRODUCTION NO. 119:
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`Any Agreement between CMG and Valve that Refers or Relates to Collective
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`Minds Gaming Co. Ltd. v. Ironburg Inventions Ltd., IPR2018-00355, including but
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`not limited to, any Joint Defense Agreement.
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`RESPONSE TO REQUEST NO. 119.(cid:1)
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`CMG objects to this Request to the extent it seeks documents covered by the
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`attorney-client privilege, work product doctrine, or other applicable privilege.
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`In consideration of its general and specific objections, CMG is unaware of
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`any documents responsive to this Request.
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`REQUEST FOR PRODUCTION NO. 120:
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`Any Agreement between CMG and Valve that Refers or Relates to Collective
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`Minds Gaming Co. Ltd. v. Ironburg Inventions Ltd., IPR2018-00356, including but
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`not limited to, any Joint Defense Agreement.
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`IRONBURG EX2015, Page 3
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`RESPONSE TO REQUEST NO. 120.(cid:1)
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`CMG objects to this Request to the extent it seeks documents covered by the
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`attorney-client privilege, work product doctrine, or other applicable privilege.
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`In consideration of its general and specific objections, CMG is unaware of
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`any documents responsive to this Request.
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`REQUEST FOR PRODUCTION NO. 121:
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`Any Agreement between CMG and Valve that Refers or Relates to Collective
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`Minds Gaming Co. Ltd. v. Ironburg Inventions Ltd., IPR2018-00357, including but
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`not limited to, any Joint Defense Agreement.
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`RESPONSE TO REQUEST NO. 121.(cid:1)
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`CMG objects to this Request to the extent it seeks documents covered by the
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`attorney-client privilege, work product doctrine, or other applicable privilege.
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`In consideration of its general and specific objections, CMG is unaware of
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`any documents responsive to this Request.
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` Dated: March 1, 2018
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`Respectfully Submitted,
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`/s/ Paul R. Hart
`Paul R. Hart, admitted pro hac vice
`CO Bar No. 45697
`Michelle Callaghan, admitted pro hac vice
`CO Bar No. 50082
`ERISE IP, P.A.
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`-17-
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`IRONBURG EX2015, Page 4
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`5600 Greenwood Plaza Blvd.
`Suite 200
`Greenwood Village, CO 80111
`Telephone: (913) 777-5600
`Facsimile: (913) 777-5601
`Attorneys for Defendant
`Collective Minds Co. Ltd.
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`Eric A. Buresh, admitted pro hac vice
`KS Bar No. 19895
`ERISE IP, P.A.
`7015 College Blvd.
`Suite 700
`Overland Park, KS 66211
`Telephone: (913) 777-5600
`Facsimile: (913) 777-5601
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`Steven G. Hill, local counsel
`GA Bar No. 354658
`Martha L. Decker
`GA Bar No. 420867
`HILL, KERTSCHER & WHARTON, LLP
`3350 Riverwood Parkway
`Suite 800
`Atlanta, GA 30339
`Telephone: (770) 953-0995
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`Attorneys for Defendant
`Collective Minds Co. Ltd.
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`IRONBURG EX2015, Page 5
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`CERTIFICATE OF SERVICE
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`I hereby certify that on March 1, 2018, the foregoing OBJECTIONS AND
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`RESPONSES TO PLAINTIFF’S SECOND SET OF REQUESTS FOR
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`PRODUCTION were served upon the following counsel of record via e-mail:
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`Manatt, Phelps & Phillips Llp-Ca
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`Christopher Laurence Wanger
`One Embarcadero Center
`San Francisco, CA 94111
`cwanger@manatt.com
`415-291-7400
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`Robert D. Becker
`1841 Page Mill Road
`Palo Alto, CA 94304
`rbecker@manatt.com
`650-812-1300
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`Dated: March 1, 2018
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`Parks IP Law
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`Cynthia Renee Parks
`75 Ponce de Leon Avenue, NE
`Suite 102
`Atlanta, GA 30308
`cparks@parksiplaw.com
`678-365-4444
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`Respectfully Submitted,
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`/s/ Michelle A. Callaghan
`Michelle A. Callaghan
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`Attorney for Defendant
`Collective Gaming Minds Co. Ltd.
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`IRONBURG EX2015, Page 6
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