IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF GEORGIA
`ATLANTA DIVISION
`
`
`
`IRONBURG INVENTIONS LTD. a
`United Kingdom Limited Company,
`
`Plaintiff,
`
`vs.
`
`COLLECTIVE MINDS GAMING
`CO. LTD.,
`
`
`
`
`
`Civil Action No. 1:16-cv-04110-TWT
`
`
`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
`
`the Federal Rules of Civil Procedure, any applicable local rules, and any
`
`obligations imposed by the Court’s scheduling and discovery orders. CMG will
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`IRONBURG EX2015, Page 1
`
`
`FOR THE NORTHERN DISTRICT OF GEORGIA
`ATLANTA DIVISION
`
`
`
`IRONBURG INVENTIONS LTD. a
`United Kingdom Limited Company,
`
`Plaintiff,
`
`vs.
`
`COLLECTIVE MINDS GAMING
`CO. LTD.,
`
`
`
`
`
`Civil Action No. 1:16-cv-04110-TWT
`
`
`Defendant.
`
`DEFENDANT’S OBJECTIONS AND RESPONSES TO PLAINTIFF’S
`SECOND SET OF REQUESTS FOR PRODUCTION
`
`
`Defendant Collective Minds Gaming Co. Ltd (“CMG”) hereby objects and
`
`
`
`
`
`
`responds to Plaintiff Ironburg Inventions Ltd.’s (“Ironburg”) Second Set of
`
`Requests for Production of Documents.
`
`General Objections
`
`1.(cid:1)
`
`CMG objects to Ironburg’s Requests and accompanying instructions to the
`
`extent they seek to impose obligations beyond those set forth in Rules 26 and 34 of
`
`the Federal Rules of Civil Procedure, any applicable local rules, and any
`
`obligations imposed by the Court’s scheduling and discovery orders. CMG will
`
`IRONBURG EX2015, Page 1
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`
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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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`
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`In consideration of its general and specific objections, CMG is unaware of
`
`any documents responsive to this Request.
`
`REQUEST FOR PRODUCTION NO. 117:
`
`Any Agreement between CMG and Valve that Refers or Relates to the Action,
`
`including but not limited to, any Joint Defense Agreement.
`
`RESPONSE TO REQUEST NO. 117.(cid:1)
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`
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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
`
`any documents responsive to this Request.
`
`REQUEST FOR PRODUCTION NO. 118:
`
`Any Agreement between CMG and Valve that Refers or Relates to Collective
`
`Minds Gaming Co. Ltd. v. Ironburg Inventions Ltd., IPR2018-00354, including but
`
`not limited to, any Joint Defense Agreement.
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`
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`-15-
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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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`
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`In consideration of its general and specific objections, CMG is unaware of
`
`any documents responsive to this Request.
`
`REQUEST FOR PRODUCTION NO. 119:
`
`Any Agreement between CMG and Valve that Refers or Relates to Collective
`
`Minds Gaming Co. Ltd. v. Ironburg Inventions Ltd., IPR2018-00355, including but
`
`not limited to, any Joint Defense Agreement.
`
`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
`
`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.
`
`REQUEST FOR PRODUCTION NO. 120:
`
`Any Agreement between CMG and Valve that Refers or Relates to Collective
`
`Minds Gaming Co. Ltd. v. Ironburg Inventions Ltd., IPR2018-00356, including but
`
`not limited to, any Joint Defense Agreement.
`
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`-16-
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`IRONBURG EX2015, Page 3
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`RESPONSE TO REQUEST NO. 120.(cid:1)
`
`
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`
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`CMG objects to this Request to the extent it seeks documents covered by the
`
`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
`
`any documents responsive to this Request.
`
`REQUEST FOR PRODUCTION NO. 121:
`
`Any Agreement between CMG and Valve that Refers or Relates to Collective
`
`Minds Gaming Co. Ltd. v. Ironburg Inventions Ltd., IPR2018-00357, including but
`
`not limited to, any Joint Defense Agreement.
`
`RESPONSE TO REQUEST NO. 121.(cid:1)
`
`
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`
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`CMG objects to this Request to the extent it seeks documents covered by the
`
`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
`
`any documents responsive to this Request.
`
`
`
` Dated: March 1, 2018
`
`Respectfully Submitted,
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`
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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.
`
`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
`
`
`
`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
`
`Attorneys for Defendant
`Collective Minds Co. Ltd.
`
`
`
`
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`-18-
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`IRONBURG EX2015, Page 5
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`
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`CERTIFICATE OF SERVICE
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`
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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
`
`PRODUCTION were served upon the following counsel of record via e-mail:
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`Manatt, Phelps & Phillips Llp-Ca
`
`Christopher Laurence Wanger
`One Embarcadero Center
`San Francisco, CA 94111
`cwanger@manatt.com
`415-291-7400
`
`Robert D. Becker
`1841 Page Mill Road
`Palo Alto, CA 94304
`rbecker@manatt.com
`650-812-1300
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`
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`Dated: March 1, 2018
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`Parks IP Law
`
`Cynthia Renee Parks
`75 Ponce de Leon Avenue, NE
`Suite 102
`Atlanta, GA 30308
`cparks@parksiplaw.com
`678-365-4444
`
`Respectfully Submitted,
`
`/s/ Michelle A. Callaghan
`Michelle A. Callaghan
`
`Attorney for Defendant
`Collective Gaming Minds Co. Ltd.
`
`-1-
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`
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`IRONBURG EX2015, Page 6
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