Case 2:17-cv-00514-JRG Document 166-6 Filed 02/13/19 Page 1 of 49 PageID #: 14736
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`Exhibit E
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`

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`Case 2:17-cv-00514-JRG Document 166-6 Filed 02/13/19 Page 2 of 49 PageID #: 14737
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`AGIS SOFTWARE DEVELOPMENT, LLC
`
`Plaintiff,
`
`v.
`
`HUAWEI DEVICE USA INC., ET AL.,
`
`Defendants.
`
`Case No. 2:17-CV-0513-JRG
`(LEAD CASE)
`
`GOOGLE LLC’S OBJECTIONS AND RESPONSES
`TO PLAINTIFF AGIS SOFTWARE DEVELOPMENT, LLC’S
`DEPOSITION AND DOCUMENT SUBPOENAS
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`Pursuant to Rule 45 of the Federal Rules of Civil Procedure, non-party Google LLC
`
`(“Google”) hereby provides the following responses and objections to Plaintiff AGIS Software
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`Development LLC’s (“AGIS”) Subpoena to Testify at a Deposition in a Civil Action and the
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`Subpoena to Produce Documents and accompanying exhibits (collectively, the “Subpoena”),
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`served by AGIS on August 24, 2018 in Lead Case No. 2:17-CV-0513-JRG.
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`RESERVATION OF RIGHTS
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`Google’s response to the Subpoena is made without waiving or intending to waive any
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`objections as to relevancy, materiality, privilege, or admissibility of any information or
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`documents provided in response to the Subpoena or in any subsequent proceeding on any
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`ground. A partial response to any Request that has been objected to, in whole or in part, is not
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`intended to be a waiver of the objection(s). In addition to the objections and responses set forth
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`herein, all objections as to relevance, authenticity, or admissibility of any document are expressly
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`reserved.
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`Any disclosures made herein are produced strictly pursuant to the stipulated protective
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`order in this case, including any amendments or other modifications thereto, and/or to any other
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`

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`Case 2:17-cv-00514-JRG Document 166-6 Filed 02/13/19 Page 3 of 49 PageID #: 14738
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`applicable Court order that may be entered impacting the Subpoena, or any responses,
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`productions, or information provided thereto.
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`GENERAL OBJECTIONS
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`Specific objections to the Requests and Topics are made on an individual basis in the
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`responses below. In addition to these specific objections, Google makes the following General
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`Objections, including without limitation to the instructions and definitions set forth in the
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`Subpoena. These General Objections are hereby incorporated by reference into the responses.
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`For particular emphasis, Google has, from time to time, expressly included one or more of the
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`General Objections in certain of its responses below. Google’s responses to the Requests and
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`Topics are submitted without prejudice to, and without in any respect waiving, any General
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`Objections not expressly set forth in a specific response. Accordingly, the inclusion of any
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`specific objection in response to a Request or Topic below is neither intended as, nor shall in any
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`way be deemed to be, a waiver of any General Objection or of any other specific objection that
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`may be asserted at a later date. In addition, the failure to include at this time any General or
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`specific objection is neither intended as, nor shall in any way be deemed, a waiver of Google’s
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`rights to assert that objection or any other objection at a later date. Furthermore, nothing herein
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`shall be deemed a waiver or limitation of Google’s rights and ability to take any action
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`challenging AGIS’s discovery requests as set forth in the Subpoena to Google.
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`1.
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`Google objects to the Subpoena on the ground that AGIS has failed to tender fees
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`contemporaneous with service of the Subpoena to Testify at a Deposition in a Civil Action, as
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`required by Federal Rule of Civil Procedure 45(b)(1). Failure to tender the requisite fees at the
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`time of service invalidates the Subpoena. Accordingly, Google’s responses to the Subpoena to
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`Testify at a Deposition in a Civil Action, if any, will be voluntary and not compelled.
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`2
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`Case 2:17-cv-00514-JRG Document 166-6 Filed 02/13/19 Page 4 of 49 PageID #: 14739
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`2.
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`Google objects to the Subpoena to the extent it requests information that AGIS
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`has already admitted to the Court is irrelevant for the issues presented in its cases. In particular,
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`AGIS has publicly represented in briefing opposing motions to transfer AGIS’s cases to the
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`Northern District of California that the confidential technical information from Google as
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`requested in the Subpoena is unnecessary to its infringement suit against defendants with
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`Android-based accused devices. (See, e.g., No. 2:17-cv-513-JRG, D.I. 56; D.I. 68.)
`
`3.
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`Google objects to the date, time, and place of the deposition and the production of
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`documents as inconvenient and burdensome. To the extent ordered, Google will produce
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`responsive documents and provide witnesses at mutually agreeable places and times, subject to
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`witness availability, in Northern California.
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`4.
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`Google objects to the Subpoena to the extent the Requests and Topics call for the
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`disclosure of information or the production of documents that are shielded from discovery by
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`attorney-client privilege, the work product doctrine, or any related joint defense or common
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`interest privilege, privileges applicable to settlement materials or documents or information
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`which constitute trial preparation materials, or any other applicable privilege (collectively,
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`“Privileged Information”). Any statement herein to the effect that Google will provide
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`information in response to a Request or Topic is limited to information that does not fall within
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`the scope of any Privileged Information.
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`5.
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`Google objects to the production of any information or documents to the extent
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`they include confidential, proprietary, trade secret, private or financial information that is
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`protected from disclosure by any applicable trade secret or privacy statute or law. Google will
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`only provide such information pursuant to the confidentiality protections embodied in the
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`Federal Rules of Civil Procedure and the terms of the protective order entered in this action, and
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`3
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`Case 2:17-cv-00514-JRG Document 166-6 Filed 02/13/19 Page 5 of 49 PageID #: 14740
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`to the extent applicable, with the consent of any third party that may claim confidentiality rights
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`with respect to information responsive to the request.
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`6.
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`Google objects to testifying about any confidential information under the
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`Protective Order entered in this action before Google knows the identity of and has an
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`opportunity to object to the experts, in-house counsel, or other individuals who would have
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`access to Google’s confidential information under the Protective Order.
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`7.
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`Google objects to the Subpoena to the extent that it requests documents or
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`information that can be requested with much less burden from one or more parties to the
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`litigation. In particular, Google objects to producing documents duplicative of those the named-
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`defendants has already produced or may produce in their respective litigations. Any documents
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`that have not or will not be produced by a party to the litigation should not be taken as an
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`admission that there are any such documents in existence or that any such documents are even
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`likely to exist in Google’s possession, custody, or control.
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`8.
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`Google objects to the Subpoena as overly broad, unduly burdensome, irrelevant,
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`and not reasonable calculated to lead to the discovery of admissible evidence to the extent it
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`requests information related to damages when there is no such allegations or claims against
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`Google. Google further objects to the Subpoena to the extent it request Google information that
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`is not relevant to any damages claims against alleged infringement by the named defendants in
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`the above-captioned case.
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`9.
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`Google objects to the definition of “Google,” “You,” and “Your” as overly broad
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`and unduly burdensome to the extent it includes “affiliates, or others acting on Google LLC’s
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`behalf.” Google understands this term to mean non-party Google LLC, and may, to the extent
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`4
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`Case 2:17-cv-00514-JRG Document 166-6 Filed 02/13/19 Page 6 of 49 PageID #: 14741
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`relevant, include its officers, directors, members, principals, employees, agents, and
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`representatives acting on behalf of and at the complete direction of Google.
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`10.
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`Google objects to the definition of “Huawei Defendants” as overly broad and
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`unduly burdensome to the extent it includes all predecessors-in-interest, successors in-interest,
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`parents, subsidiaries, and affiliates, as well as past officers, directors, employees, agents,
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`representatives, affiliates, and others acting on the Huawei Defendants’ behalf. Google
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`understands this term to mean Huawei Device USA Inc., Huawei Device Co., Ltd. and Huawei
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`Device (Dongguan) Co., Ltd. as the named defendants in their respective, above-captioned
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`action.
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`11.
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`Google objects to the definition of “Android Applications” as a general reference
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`to “Google Maps, Find My Device, Android Device Manager, and Google Messenger” without
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`any limitation to functionality implicated by or relevant to Plaintiff’s patent infringement claims
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`against the Huawei Defendants (collectively also referred to herein as “Android Defendants”), as
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`Google understands them. Moreover, Google objects to the phrase “Google Messenger” as an
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`unknown product name. Google will interpret that phrase to mean “Messenger.”
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`12.
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`Google objects to the definition of “Android Devices” as overly broad and unduly
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`burdensome to the extent it includes products allegedly made, used, sold, offered for sale, or
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`imported into the United States by Defendants’ affiliates or entities other than the Android
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`Defendants. Google further objects to the definition of “Android Devices” as overly broad to the
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`extent that it includes any products or devices accused of infringing any patent later asserted by
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`Plaintiff in this Action. Google understands this term to mean only those specific products
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`allegedly made, used, sold, offered for sale, or imported into the United States by the Android
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`Defendants as formally identified by AGIS in the above-captioned case, including Android-
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`5
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`Case 2:17-cv-00514-JRG Document 166-6 Filed 02/13/19 Page 7 of 49 PageID #: 14742
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`based applications or software that AGIS alleges allows users to utilize forced message alerts or
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`to form groups with other users such that users may view each other’s locations on a map and
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`engage in communication. Google further objects to the definition of “Android Devices” as
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`irrelevant and not properly limited in time and scope as it seeks information beyond the time
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`period allowed under at least 35 U.S.C. § 286.
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`13.
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`Google objects to the definition of “Google Servers” as overly broad, unduly
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`burdensome, and not limited in time and scope, to the extent it requests information regarding
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`servers owned and operated by Google for Android Applications that are not limited to any
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`functionality implicated by or relevant to Plaintiff’s patent infringement claims against the
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`Android Defendants, as Google understands them. Moreover, Google objects to the definition of
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`“Google Servers” as calling for admittedly irrelevant information as it relates to Google’s non-
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`public backend infrastructure or operation. As explained above, AGIS has publicly represented
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`in briefing opposing motions to transfer AGIS’s cases to the Northern District of California that
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`confidential technical information from Google is unnecessary to its infringement suit against
`
`defendants with Android-based accused devices. (See, e.g., No. 2:17-cv-513-JRG, D.I. 56; D.I.
`
`68.)
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`14.
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`Google objects to the definition of “Google Identifier” as overly broad, unduly
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`burdensome, and not limited in time and scope to the extent it requests information regarding
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`“any identifier used by Google to associate a user or a device with any account or group, such as
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`a Google Account, Google Group and/or Family Link account.” Moreover, Google objects to
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`the definition to the extent it is not limited to any Android Applications or any functionality in
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`those Android Applications implicated by or relevant to Plaintiff’s patent infringement claims
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`against the Android Defendants, as Google understands them. Moreover, Google objects to the
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`6
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`Case 2:17-cv-00514-JRG Document 166-6 Filed 02/13/19 Page 8 of 49 PageID #: 14743
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`definition as calling for admittedly irrelevant information as it relates to non-public Google
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`information. As explained above, AGIS has publicly represented in briefing opposing motions
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`to transfer AGIS’s cases to the Northern District of California that the confidential technical
`
`information from Google is unnecessary to its infringement suit against defendants with
`
`Android-based accused devices. (See, e.g., No. 2:17-cv-513-JRG, D.I. 56; D.I. 68.)
`
`15.
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`Google objects to the definition of “Person(s)” as overly broad to the extent that it
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`includes other persons or entities outside of the Person’s control. In responding to the Subpoena,
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`Google understands this term to mean only the persons or entities within the Person’s control,
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`and with respect to such persons or entities within the Person’s control, Google shall only
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`provide relevant information that is accessible by means of the business relationship with the
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`Person(s).
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`16.
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`Google objects to the Requests and Topics to the extent they are overly broad,
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`unduly burdensome, or seek information that is not relevant to any party’s claim or defense or
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`not proportional to the needs of the case.
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`17.
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`Google objects to the Requests and Topics to the extent they are vague,
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`ambiguous, and use unlimited, undefined, subjective, or open-ended terms or phrases.
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`18.
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`Google objects to the Requests and Topics to the extent that the purported benefit
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`of the discovery sought by the Requests and Topics is outweighed by the burden and expense of
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`responding pursuant to Rules 26(b)(1) and 26(b)(2) of the Federal Rules of Civil Procedure.
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`19.
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`Google objects to the Subpoena to the extent it attempts to impose burdens on
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`Google inconsistent with, or in excess of, the requirements of the Federal Rules of Civil
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`Procedures and/or the Local Rules of the Northern District of California and/or any other
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`applicable rule of the court that may have jurisdiction over enforcement of the Subpoena.
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`7
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`Case 2:17-cv-00514-JRG Document 166-6 Filed 02/13/19 Page 9 of 49 PageID #: 14744
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`20.
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`Google objects to the Requests and Topics to the extent they seek information that
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`is not in the possession, custody, or control of Google and/or purport to call for any description
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`of documents that Google no longer possesses and/or was under no obligation to maintain. With
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`respect to documents that were but are no longer in Google’s possession, custody or control,
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`Google objects to the Subpoena to the extent that they seek a description of the circumstances of
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`such loss or destruction of the documents and any efforts to recover such documents.
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`21.
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`Google objects to AGIS’s reservation of right as it relates to the definitions AGIS
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`sets forth in the Subpoena, particularly to the extent that AGIS is seeking to later supplement,
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`clarify, amend, or otherwise modify the scope of such definitions. (See Subpoena, ¶ 21.)
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`SPECIFIC OBJECTIONS AND RESPONSES TO DOCUMENT REQUESTS
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`DOCUMENT REQUEST NO. 1:
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`Documents and communications sufficient to show the number of users that have utilized
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`the Android Applications and the number of transactions between each user and each Google
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`Server since 2011.
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`RESPONSE TO DOCUMENT REQUEST NO. 1:
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`Google incorporates by reference its General Objections as if fully set forth herein.
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`Google objects to this Request as overbroad, unduly burdensome, and not proportional to the
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`needs of the case to the extent it requires Google to produce all “documents and communications
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`sufficient to show” the subject matter of the Request. Google further objects to this Request as
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`calling for information that is not relevant and not reasonably calculated to lead to the discovery
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`of admissible evidence to the extent it calls for information that is untethered to any claim or
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`defense or accused functionality. Google objects to the Request to the extent it seeks
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`information protected from disclosure by the attorney-client privilege, work product doctrine,
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`joint defense privilege, common interest privilege, or any other applicable privileges,
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`8
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`Case 2:17-cv-00514-JRG Document 166-6 Filed 02/13/19 Page 10 of 49 PageID #: 14745
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`immunities, or protections. Google further objects to the extent it seeks confidential, proprietary,
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`trade secret, private or financial information that is protected from disclosure by any applicable
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`trade secret or privacy statute or law. Google also objects to the Request as vague, ambiguous,
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`overly broad, unduly burdensome, and undefined as to the terms “users that have utilized the
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`Android Applications” and the “number of transactions between each user and each Google
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`Server.” Google further objects to this Request in scope and time to the extent it requests
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`information beyond the time period allowed under at least 35 U.S.C. § 286. Google additionally
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`objects to this Request to the extent it requests information that is not in Google’s possession,
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`custody, or control, or to the extent it can be more easily obtained from another source. Finally,
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`Google objects to the Request to the extent it requests confidential Google information that
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`AGIS has already admitted to the Court is irrelevant for the issues presented in its cases. In
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`particular, AGIS has publicly represented in briefing opposing motions to transfer AGIS’s cases
`
`to the Northern District of California that any confidential Google information within the scope
`
`of AGIS’s request here is unnecessary to its infringement suit against defendants with Android-
`
`based accused devices. (See, e.g., No. 2:17-cv-513-JRG, D.I. 56; D.I. 68.)
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`Subject to and without waiving the foregoing General and specific objections, Google
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`responds as follows: Google is willing to meet and confer as to the scope of this Request.
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`DOCUMENT REQUEST NO. 2:
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`Documents and communications sufficient to show the number of downloads of each
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`Android Application by a user or customer onto the Android Devices.
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`RESPONSE TO DOCUMENT REQUEST NO. 2:
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`Google incorporates by reference its General Objections as if fully set forth herein.
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`Google objects to this Request as overbroad, unduly burdensome, and not proportional to the
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`9
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`Case 2:17-cv-00514-JRG Document 166-6 Filed 02/13/19 Page 11 of 49 PageID #: 14746
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`needs of the case to the extent it requires Google to produce all “documents and communications
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`sufficient to show” the subject matter of the Request. Google objects to the Request to the extent
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`it seeks information protected from disclosure by the attorney-client privilege, work product
`
`doctrine, joint defense privilege, common interest privilege, or any other applicable privileges,
`
`immunities, or protections. Google further objects to the extent it seeks confidential, proprietary,
`
`trade secret, private or financial information that is protected from disclosure by any applicable
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`trade secret or privacy statute or law. Google also objects to the Request as vague, ambiguous,
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`overly broad, unduly burdensome, and undefined as to the phrase, “downloads of each Android
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`Application by a user or customer.” Google additionally objects to this Request to the extent it
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`seeks information that is not in Google’s possession, custody, or control, or to the extent it can be
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`more easily obtained from another source. Google objects to this Request as irrelevant and not
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`reasonably calculated to lead to the discovery of admissible evidence to the extent it calls for
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`download information that does not relate to any claims, including, but not limited to, damages,
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`against the Android Defendants. Finally, Google objects to the Request to the extent it requests
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`confidential Google information that AGIS has already admitted to the Court is irrelevant for the
`
`issues presented in its cases. In particular, AGIS has publicly represented in briefing opposing
`
`motions to transfer AGIS’s cases to the Northern District of California that any confidential
`
`Google information within the scope of AGIS’s request here is unnecessary to its infringement
`
`suit against defendants with Android-based accused devices. (See, e.g., No. 2:17-cv-513-JRG,
`
`D.I. 56; D.I. 68.)
`
`Subject to and without waiving the foregoing General and specific objections, Google
`
`responds as follows: Google is willing to meet and confer as to the scope of this Request.
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`10
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`Case 2:17-cv-00514-JRG Document 166-6 Filed 02/13/19 Page 12 of 49 PageID #: 14747
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`DOCUMENT REQUEST NO. 3:
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`Documents and communications sufficient to show the number of Android Devices on
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`which the Android Applications are installed prior to sale.
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`RESPONSE TO DOCUMENT REQUEST NO. 3:
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`Google incorporates by reference its General Objections as if fully set forth herein.
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`Google objects to this Request as overbroad, unduly burdensome, and not proportional to the
`
`needs of the case to the extent it requires Google to produce all “documents and communications
`
`sufficient to show” the subject matter of the Request. Google objects to the Request to the extent
`
`it seeks information protected from disclosure by the attorney-client privilege, work product
`
`doctrine, joint defense privilege, common interest privilege, or any other applicable privileges,
`
`immunities, or protections. Google further objects to the extent it seeks confidential, proprietary,
`
`trade secret, private or financial information that is protected from disclosure by any applicable
`
`trade secret or privacy statute or law. Google also objects to the Request as vague, ambiguous,
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`overly broad, unduly burdensome, and undefined as to the phrase, “installed prior to sale.”
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`Google further objects to this Request as not limited in time and scope. Google additionally
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`objects to this Request to the extent it seeks information that is not in Google’s possession,
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`custody, or control, or to the extent it can be more easily obtained from another source,
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`including, without limitation, the Android Defendants. Finally, Google objects to the Request to
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`the extent it requests confidential Google information that AGIS has already admitted to the
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`Court is irrelevant for the issues presented in its cases. In particular, AGIS has publicly
`
`represented in briefing opposing motions to transfer AGIS’s cases to the Northern District of
`
`California that any confidential Google information within the scope of AGIS’s request here is
`
`unnecessary to its infringement suit against defendants with Android-based accused devices.
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`11
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`Case 2:17-cv-00514-JRG Document 166-6 Filed 02/13/19 Page 13 of 49 PageID #: 14748
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`(See, e.g., No. 2:17-cv-513-JRG, D.I. 56; D.I. 68.)
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`Subject to and without waiving the foregoing General and specific objections, Google
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`responds as follows: Google is willing to meet and confer as to the scope of this Request.
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`DOCUMENT REQUEST NO. 4:
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`Documents and communications sufficient to show all consideration furnished to date
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`to Huawei Defendants and their Affiliates for providing and making available the Android
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`Applications on the Android Devices.
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`RESPONSE TO DOCUMENT REQUEST NO. 4:
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`Google incorporates by reference its General Objections as if fully set forth herein.
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`Google objects to this Request as overbroad, unduly burdensome, and not proportional to the
`
`needs of the case to the extent it requires Google to produce all “documents and communications
`
`sufficient to show” the subject matter of the Request. Google objects to the Request to the extent
`
`it seeks information protected from disclosure by the attorney-client privilege, work product
`
`doctrine, joint defense privilege, common interest privilege, or any other applicable privileges,
`
`immunities, or protections. Google further objects to the extent it seeks confidential, proprietary,
`
`trade secret, private or financial information that is protected from disclosure by any applicable
`
`trade secret or privacy statute or law. Google additional objects to the Request to the extent it
`
`seeks information that is subject to confidentiality and disclosure restrictions. Google also
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`objects to the Request as vague, ambiguous, overly broad, unduly burdensome, and undefined as
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`to the phrases, “all consideration furnished to date” and “for providing and making available.”
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`Google further objects to this Request as not limited in time and scope and to the extent it calls
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`for information related to “Affiliates” who are not named defendants in the above-captioned
`
`action. Google additionally objects to this Request to the extent it seeks information that is not
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`12
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`Case 2:17-cv-00514-JRG Document 166-6 Filed 02/13/19 Page 14 of 49 PageID #: 14749
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`in Google’s possession, custody, or control, or to the extent it can be more easily obtained from
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`another source, including, without limitation, the Android Defendants. Finally, Google objects
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`to the Request to the extent it requests confidential Google information that AGIS has already
`
`admitted to the Court is irrelevant for the issues presented in its cases. In particular, AGIS has
`
`publicly represented in briefing opposing motions to transfer AGIS’s cases to the Northern
`
`District of California that any confidential Google information within the scope of AGIS’s
`
`request here is unnecessary to its infringement suit against defendants with Android-based
`
`accused devices. (See, e.g., No. 2:17-cv-513-JRG, D.I. 56; D.I. 68.)
`
`Subject to and without waiving the foregoing General and specific objections, Google
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`responds as follows: Google is willing to meet and confer as to the scope of this Request.
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`DOCUMENT REQUEST NO. 5:
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`Documents and communications sufficient to show any consideration to be furnished to
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`Huawei Defendants and their Affiliates through September 20, 2024 for providing and making
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`available the Android Applications on the Android Devices.
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`RESPONSE TO DOCUMENT REQUEST NO. 5:
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`Google incorporates by reference its General Objections as if fully set forth herein.
`
`Google objects to this Request as overbroad, unduly burdensome, and not proportional to the
`
`needs of the case to the extent it requires Google to produce all “documents and communications
`
`sufficient to show” the subject matter of the Request. Google objects to the Request to the extent
`
`it seeks information protected from disclosure by the attorney-client privilege, work product
`
`doctrine, joint defense privilege, common interest privilege, or any other applicable privileges,
`
`immunities, or protections. Google further objects to the extent it seeks confidential, proprietary,
`
`trade secret, private or financial information that is protected from disclosure by any applicable
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`13
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`Case 2:17-cv-00514-JRG Document 166-6 Filed 02/13/19 Page 15 of 49 PageID #: 14750
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`trade secret or privacy statute or law. Google additional objects to the Request to the extent it
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`seeks information that is subject to confidentiality and disclosure restrictions. Google also
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`objects to the Request as vague, ambiguous, overly broad, unduly burdensome, and undefined as
`
`to the phrases, “any consideration to be furnished” and “for providing and making available.”
`
`Google further objects to this Request as not properly limited in time and scope as it seeks
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`information to September 20, 2024. Moreover, Google objects to this Request to the extent it
`
`calls for information related to “Affiliates” who are not named defendants in the above-captioned
`
`action. Google additionally objects to this Request to the extent it seeks information that is not
`
`in Google’s possession, custody, or control, or to the extent it can be more easily obtained from
`
`another source, including, without limitation, the Android Defendants. Google further objects to
`
`this Request as duplicative and cumulative of Request No. 4. Finally, Google objects to the
`
`Request to the extent it requests confidential Google information that AGIS has already admitted
`
`to the Court is irrelevant for the issues presented in its cases. In particular, AGIS has publicly
`
`represented in briefing opposing motions to transfer AGIS’s cases to the Northern District of
`
`California that any confidential Google information within the scope of AGIS’s request here is
`
`unnecessary to its infringement suit against defendants with Android-based accused devices.
`
`(See, e.g., No. 2:17-cv-513-JRG, D.I. 56; D.I. 68.)
`
`Subject to and without waiving the foregoing General and specific objections, Google
`
`responds as follows: Google is willing to meet and confer as to the scope of this Request.
`
`DOCUMENT REQUEST NO. 6:
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`Documents and communications sufficient to show all compliance and certification
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`requirements that Google mandates for the Android Applications.
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`Case 2:17-cv-00514-JRG Document 166-6 Filed 02/13/19 Page 16 of 49 PageID #: 14751
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`RESPONSE TO DOCUMENT REQUEST NO. 6:
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`Google incorporates by reference its General Objections as if fully set forth herein.
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`Google objects to this Request as overbroad, unduly burdensome, and not proportional to the
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`needs of the case to the extent it requires Google to produce all “documents and communications
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`sufficient to show” the subject matter of the Request. Google further objects to this request as
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`overly broad, unduly burdensome, and not relevant to the extent it calls for documents beyond
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`those involving or related to the Android Defendants. Google objects to the Request to the
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`extent it seeks information protected from disclosure by the attorney-client privilege, work
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`product doctrine, joint defense privilege, common interest privilege, or any other applicable
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`privileges, immunities, or protections. Google further objects to the extent it seeks confidential,
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`proprietary, trade secret, private or financial information that is protected from disclosure by any
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`applicable trade secret or privacy statute or law. Google additional objects to the Request to the
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`extent it seeks information that is subject to confidentiality and disclosure restrictions. Google
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`also objects to the Request as vague, ambiguous, overly broad, unduly burdensome, and
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`undefined as to the phrases, “all compliance and certification requirements” and “Google
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`mandates.” Google further objects to this Request as not properly limited in time and scope.
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`Google additionally objects to this Request to the extent it seeks information that is not in
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`Google’s possession, custody, or control, or to the extent it can be more easily obtained from
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`another source, including, without limitation, the Android Defendants. Finally, Google objects
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`to the Request to the extent it requests confidential Google information that AGIS has already
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`admitted to the Court is irrelevant for the issues presented in its cases. In particular, AGIS has
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`publicly represented in briefing opposing motions to transfer AGIS’s cases to the Northern
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`District of California that any confidential Google information within the scope of AGIS’s
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`Case 2:17-cv-00514-JRG Document 166-6 Filed 02/13/19 Page 17 of 49 PageID #: 14752
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`request here is unnecessary to its infringement suit against defendants with Android-based
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`accused devices. (See, e.g., No. 2:17-cv-513-JRG, D.I. 56; D.I. 68.) AGIS has also expressly
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`admitted in open court that Google information related to certification and compliance of
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`Android Devices is irrelevant to its cases. (See, e.g., No. 2:17-cv-513-JRG, D.I. 176 at 61:19-62-
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`14, 69:22-70:4.)
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`Subject to and without waiving the foregoing General and specific objections, Google
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`responds as follows: Google is willing to meet and confer as to the scope of this Request.
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`DOCUMENT REQUEST NO. 7:
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`All agreements between Google and Huawei Defendants and their Affiliates relating to
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`Google Mobile Services and the Android Applications.
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`RESPONSE TO DOCUMENT REQUEST NO. 7:
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`Google incorporates by reference its General Objections as if fully set forth herein. Google
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`objects to this Request as overbroad, unduly burdensome, and not proportional to the needs of the case to
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`the extent it requires Google to produce “all agreements” regarding the subject matter of the Request.
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`Google ob