Case 6:20-cv-01214-ADA Document 54-7 Filed 02/16/22 Page 1 of 58
`Case 6:20-cv-01214-ADA Document 54-7 Filed 02/16/22 Page 1 of 58
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`EXHIBIT F
`EXHIBIT F
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`

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`Case 6:20-cv-01214-ADA Document 54-7 Filed 02/16/22 Page 2 of 58
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`Robert G. Litts (No. 205984)
`CANDESCENT LAW GROUP
`1350 Old Bayshore Hwy, Ste. 520
`Burlingame, CA 94010
`Telephone: (925) 644-1102
`robert.litts@candescentlaw.com
`
`Attorney for Non-Party
`UNITED MICROELECTRONICS
`CORPORATION
`
`
`
`UNITED STATES DISTRICT COURT
`
`NORTHERN DISTRICT OF CALIFORNIA
`
`
` Case No. 6:20-cv-1210-ADA
`(Pending in W.D. Tex.)
`
`NON-PARTY UNITED
`MICROELECTRONICS
`CORPORATION’S OBJECTIONS TO
`OCEAN SEMICONDUCTOR LLC’S
`SUBPOENA TO TESTIFY AT A
`DEPOSITION IN A CIVIL ACTION
`
`
`OCEAN SEMICONDUCTOR LLC,
`
`
`
`Plaintiff,
`
`v.
`
`MEDIATEK INC. AND MEDIATEK USA
`INC.,
`
`
`
`
`Defendants.
`
`
`
`
`
`
`Pursuant to Rules 26, 30, 34 and 45 of the Federal Rules of Civil Procedure, non-party
`United Microelectronics Corporation (“UMC”) hereby objects to the Subpoena to Testify at a
`Deposition in a Civil Action (“Subpoena”) which was purportedly issued by Plaintiff Ocean
`Semiconductor LLC (“Ocean” or “Plaintiff”) in the above-captioned action and transmitted by
`electronic mail to counsel for UMC on January 27, 2022. The Subpoena seeks deposition
`testimony from UMC on eleven Deposition Topics (each a “Topic” and collectively the
`“Topics”) listed in Attachment A to the Subpoena, and production by UMC of documents,
`electronically stored information (“ESI”), or objects described in twenty-two Requests for
`Production of Documents (each a “Request” and collectively the “Requests”) also listed in
`Attachment A.
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`UMC’S OBJECTIONS TO OCEAN SEMICONDUCTOR LLC’S SUBPOENA
`TO TESTIFY AT A DEPOSITION IN A CIVIL ACTION
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`Case 6:20-cv-01214-ADA Document 54-7 Filed 02/16/22 Page 3 of 58
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`PRELIMINARY STATEMENT
`UMC is a Taiwanese company having its headquarters in Hsinchu, Taiwan.
`A.
`Accordingly, UMC is beyond the subpoena power of United States courts, which have no
`jurisdiction over UMC for purposes of the Subpoena. Ocean failed to request and obtain
`issuance of a letter rogatory to the Appropriate Judicial Authority of Taiwan requesting their
`assistance in serving and enforcing the Subpoena, failed to provide a Chinese translation of the
`Subpoena, and failed to follow the other requirements under the Federal Rules of Civil
`Procedure, the United States Code, and Taiwan law for issuance of a subpoena to a Taiwanese
`entity. Moreover, Ocean’s attempted service of the Subpoena by emailing an electronic copy to
`counsel for UMC is unauthorized under the Federal Rules of Civil Procedure and the United
`States Code, and is in contravention of Taiwan Law, and thus is improper and ineffective.
`Accordingly, UMC is under no obligation to respond to the Subpoena. Any production by UMC
`of information sought by the Subpoena would be entirely voluntary.
`Nothing in these objections, no production by UMC of information sought by the
`B.
`Subpoena, and no request by UMC for additional protections in the underlying action through
`entry of a supplemental protective order or other measures should be construed as an acceptance
`by UMC of service of the Subpoena, as a submission by UMC to the jurisdiction of any United
`States court, or as a waiver by UMC of any rights under applicable rules and governing laws,
`including any objections regarding improper and ineffective service or lack of jurisdiction.
`UMC’s objections to a particular Request or Topic should not be interpreted as
`C.
`implying that documents responsive to the Request exist or that information covered by the
`Topic is known or reasonably available to UMC, or that UMC acknowledges the appropriateness
`of the Request or Topic.
`Any production by UMC of information sought by the Subpoena will be made
`D.
`pursuant to the Protective Order governing the disclosure of confidential information in the
`underlying action. UMC reserves the right to insist upon supplemental protections.
`
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`UMC’S OBJECTIONS TO OCEAN SEMICONDUCTOR LLC’S SUBPOENA
`TO TESTIFY AT A DEPOSITION IN A CIVIL ACTION
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`Case 6:20-cv-01214-ADA Document 54-7 Filed 02/16/22 Page 4 of 58
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`GENERAL OBJECTIONS
`UMC objects to the time, place, and manner specified in the Subpoena for
`1.
`appearing for a deposition and producing documents to the extent they are inconvenient and
`unduly burdensome to UMC. UMC will appear for a deposition and produce documents, if at
`all, at a time and location, and in a manner, to be agreed upon by UMC and Ocean.
`UMC objects to each Request and Topic to the extent it seeks to impose duties or
`2.
`obligations beyond or inconsistent with those set forth in the Federal Rules of Civil Procedure or
`any other applicable rule or law.
`UMC objects to each Request and Topic to the extent it seeks information that is
`3.
`protected from discovery by the attorney-client privilege, the attorney work-product doctrine, or
`any other applicable privilege or immunity.
`UMC objects to each Request and Topic to the extent it seeks trade secret and/or
`4.
`other confidential research, development, or commercial information. Any production by UMC
`of information sought by the Subpoena will be made pursuant to the Protective Order governing
`the disclosure of confidential information in the underlying action. UMC reserves the right to
`insist upon supplemental protections.
`UMC objects to each Request and Topic to the extent it seeks information not in
`5.
`UMC’s possession, custody or control.
`UMC objects to each Request and Topic to the extent it seeks information that is
`6.
`available from one or more parties to the underlying action and/or from public sources.
`UMC objects to each Request and Topic to the extent it seeks information that is
`7.
`more readily and/or appropriately available from, or confidential to, another non-party.
`UMC objects to each Request and Topic to the extent it is duplicative of other
`8.
`discovery already taken or requested in the underlying action.
`UMC objects to each Request and Topic to the extent it seeks information that is
`9.
`not relevant to any party’s claim or defense and proportional to the needs of the case.
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`UMC’S OBJECTIONS TO OCEAN SEMICONDUCTOR LLC’S SUBPOENA
`TO TESTIFY AT A DEPOSITION IN A CIVIL ACTION
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`Case 6:20-cv-01214-ADA Document 54-7 Filed 02/16/22 Page 5 of 58
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`UMC objects to each Request and Topic to the extent it is overbroad, vague and
`10.
`ambiguous, and/or imposes undue burden or expense upon UMC.
`UMC objects to each Request and Topic to the extent it is not reasonably limited
`11.
`in time and scope.
`UMC objects to each Request and Topic to the extent that responding or
`12.
`providing testimony would require subjective judgment and/or speculation on the part of UMC.
`UMC objects to each Request and Topic to the extent that it calls for a legal
`13.
`conclusion.
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`OBJECTIONS TO DEFINITIONS
`UMC objects to the definition of “UMC,” “You,” and “Your” as overbroad,
`1.
`vague and ambiguous, calling for a legal conclusion, and seeking to impose duties or obligations
`beyond or inconsistent with those set forth in the Federal Rules of Civil Procedure, at least to the
`extent it covers entities and persons other than UMC. For purposes of these objections, UMC
`will interpret these terms to mean only United Microelectronics Corporation.
`UMC objects to the definition of “Plaintiff,” “Ocean Semiconductor,” and
`2.
`“Ocean” as overbroad, vague and ambiguous, calling for a legal conclusion, providing
`insufficient identification and specificity, requiring subjective judgment and speculation, and
`seeking to impose duties or obligations beyond or inconsistent with those set forth in the Federal
`Rules of Civil Procedure, at least to the extent it covers entities and persons other than Ocean
`Semiconductor LLC. For purposes of these objections, UMC will interpret these terms to mean
`only Ocean Semiconductor LLC.
`UMC objects to the definition of “ASML” as overbroad, vague and ambiguous,
`3.
`calling for a legal conclusion, providing insufficient identification and specificity, requiring
`subjective judgment and speculation, and seeking to impose duties or obligations beyond or
`inconsistent with those set forth in the Federal Rules of Civil Procedure, at least to the extent it
`covers entities and persons other than ASML Holding N.V. and ASML Netherlands B.V. For
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`UMC’S OBJECTIONS TO OCEAN SEMICONDUCTOR LLC’S SUBPOENA
`TO TESTIFY AT A DEPOSITION IN A CIVIL ACTION
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`Case 6:20-cv-01214-ADA Document 54-7 Filed 02/16/22 Page 6 of 58
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`purposes of these objections, UMC will interpret this term to mean only ASML Holding N.V.
`and ASML Netherlands B.V.
`UMC objects to the definition of “Applied Materials” as overbroad, vague and
`4.
`ambiguous, calling for a legal conclusion, providing insufficient identification and specificity,
`requiring subjective judgment and speculation, and seeking to impose duties or obligations
`beyond or inconsistent with those set forth in the Federal Rules of Civil Procedure, at least to the
`extent it covers entities and persons other than Applied Materials, Inc. For purposes of these
`objections, UMC will interpret this term to mean only Applied Materials, Inc.
`UMC objects to the definition of “PDF Solutions” as overbroad, vague and
`5.
`ambiguous, calling for a legal conclusion, providing insufficient identification and specificity,
`requiring subjective judgment and speculation, and seeking to impose duties or obligations
`beyond or inconsistent with those set forth in the Federal Rules of Civil Procedure, at least to the
`extent it covers entities and persons other than PDF Solutions, Inc. For purposes of these
`objections, UMC will interpret this term to mean only PDF Solutions, Inc.
`UMC objects to the definition of “Defendant” and “Defendants” as overbroad,
`6.
`vague and ambiguous, calling for a legal conclusion, providing insufficient identification and
`specificity, requiring subjective judgment and speculation, and seeking to impose duties or
`obligations beyond or inconsistent with those set forth in the Federal Rules of Civil Procedure, at
`least to the extent it covers entities and persons other than MediaTek Inc., MediaTek USA Inc.,
`NVIDIA Corporation, NXP USA, Inc., Renesas Electronics Corporation, Renesas Electronics
`America, Inc., STMicroelectronics, Inc., Analog Devices, Inc., Infineon Technologies AG, and
`Infineon Technologies Americas Corp. For purposes of these objections, UMC will interpret
`these terms to mean only MediaTek Inc., MediaTek USA Inc., NVIDIA Corporation, NXP USA,
`Inc., Renesas Electronics Corporation, Renesas Electronics America, Inc., STMicroelectronics,
`Inc., Analog Devices, Inc., Infineon Technologies AG, and Infineon Technologies Americas
`Corp.
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`UMC’S OBJECTIONS TO OCEAN SEMICONDUCTOR LLC’S SUBPOENA
`TO TESTIFY AT A DEPOSITION IN A CIVIL ACTION
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`Case 6:20-cv-01214-ADA Document 54-7 Filed 02/16/22 Page 7 of 58
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`UMC objects to the definitions of “Mediatek Infringing Instrumentalities,”
`7.
`“NVIDIA Infringing Instrumentalities,” “NXP Infringing Instrumentalities,” “Renesas Infringing
`Instrumentalities,” “STMicro Infringing Instrumentalities,” “Analog Devices Infringing
`Instrumentalities,” “Infineon Infringing Instrumentalities,” and “Infringing Instrumentalities” as
`overbroad, vague and ambiguous, calling for a legal conclusion, providing insufficient
`identification and specificity, requiring subjective judgment and speculation, and seeking to
`impose duties or obligations beyond or inconsistent with those set forth in the Federal Rules of
`Civil Procedure, at least to the extent they list product identifiers that are unfamiliar to UMC and
`therefore would require UMC to speculate about what product(s) are associated with those
`product identifiers and about the identity of the manufacturer(s) of those products, and to the
`extent they would require UMC to speculate about what constitutes “similar systems, products,
`devices, and integrated circuits.” UMC further objects to the definitions of these terms as
`overbroad and vague and ambiguous, at least to the extent they improperly suggest that any
`products associated with the listed product identifiers infringe the Asserted Patents. Alleged
`infringement of the Asserted Patents has not yet been adjudicated in the underlying action.
`UMC objects to the definitions of “person,” “documents,” “thing,” “sale,” “sold,”
`8.
`“communication,” “identify,” “identity,” “information,” “describe,” “date,” “relate to,” “related
`to,” “relating to,” “concerning,” and “possession,” at least to the extent they seek to impose
`duties or obligations beyond or inconsistent with those set forth in the Federal Rules of Civil
`Procedure or any other applicable rule or law. For purposes of these objections, UMC will
`interpret these terms in a manner consistent with Federal Rules of Civil Procedure and any other
`applicable rules and laws.
`UMC objects to the definition of “Advanced Process Control” and “APC” as
`9.
`overbroad, vague and ambiguous, calling for a legal conclusion, providing insufficient
`identification and specificity, requiring subjective judgment and speculation, and seeking to
`impose duties or obligations beyond or inconsistent with those set forth in the Federal Rules of
`Civil Procedure, at least to the extent it would require UMC to speculate about what constitutes
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`UMC’S OBJECTIONS TO OCEAN SEMICONDUCTOR LLC’S SUBPOENA
`TO TESTIFY AT A DEPOSITION IN A CIVIL ACTION
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`Case 6:20-cv-01214-ADA Document 54-7 Filed 02/16/22 Page 8 of 58
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`“any computer integrated system or factory automation hardware or software for monitoring
`and/or controlling processes and tools,” to the extent it covers systems, hardware, and/or
`software that has not been identified by Ocean in its pleadings or in its Preliminary Disclosure of
`Asserted Claims and Infringement Contentions in the underlying action and/or does not perform
`the accused functionalities claimed in any of the Asserted Patents, and to the extent it is
`inconsistent with any use of this term or similar terms in any of the Asserted Patents, or in any
`claim construction order or other orders entered in the underlying action.
`UMC objects to the definition of “Fault Detection and Classification” and “FDC”
`10.
`as overbroad, vague and ambiguous, calling for a legal conclusion, providing insufficient
`identification and specificity, requiring subjective judgment and speculation, and seeking to
`impose duties or obligations beyond or inconsistent with those set forth in the Federal Rules of
`Civil Procedure, at least to the extent it would require UMC to speculate about what constitutes
`“any computer integrated hardware or software for the detection and/or classification of
`manufacturing-related fault events,” to the extent it covers systems, hardware, and/or software
`that has not been identified by Ocean in its pleadings or in its Preliminary Disclosure of Asserted
`Claims and Infringement Contentions in the underlying action and/or does not perform the
`accused functionalities claimed in any of the Asserted Patents, and to the extent it is inconsistent
`with any use of this term or similar terms in any of the Asserted Patents, or in any claim
`construction order or other orders entered in the underlying action.
`UMC objects to the definition of “YieldStar” as overbroad, vague and ambiguous,
`11.
`calling for a legal conclusion, providing insufficient identification and specificity, requiring
`subjective judgment and speculation, and seeking to impose duties or obligations beyond or
`inconsistent with those set forth in the Federal Rules of Civil Procedure, at least to the extent it
`would require UMC to speculate about what constitutes “any and all metrology and inspection
`systems designed, developed, assembled, and/or manufactured by ASML,” “ASML’s optical
`metrology systems,” “E-beam metrology and inspection systems,” and “all models, versions, and
`their predecessors,” and to the extent it covers systems, hardware, and/or software that has not
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`UMC’S OBJECTIONS TO OCEAN SEMICONDUCTOR LLC’S SUBPOENA
`TO TESTIFY AT A DEPOSITION IN A CIVIL ACTION
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`Case 6:20-cv-01214-ADA Document 54-7 Filed 02/16/22 Page 9 of 58
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`been identified by Ocean in its pleadings or in its Preliminary Disclosure of Asserted Claims and
`Infringement Contentions in the underlying action and/or does not perform the accused
`functionalities claimed in any of the Asserted Patents.
`UMC objects to the definition of “TWINSCAN” as overbroad, vague and
`12.
`ambiguous, calling for a legal conclusion, providing insufficient identification and specificity,
`requiring subjective judgment and speculation, and seeking to impose duties or obligations
`beyond or inconsistent with those set forth in the Federal Rules of Civil Procedure, at least to the
`extent it would require UMC to speculate about what constitutes “any and all lithography
`systems designed, developed, assembled, and/or manufactured by ASML,” “ASML’s deep
`ultraviolet (DUY) lithography systems,” “extreme ultraviolet (EUV) lithography systems,”
`“lithography systems that utilize more than one wafer table,” and “their predecessors,” and to the
`extent it covers systems, hardware, and/or software that has not been identified by Ocean in its
`pleadings or in its Preliminary Disclosure of Asserted Claims and Infringement Contentions in
`the underlying action and/or does not perform the accused functionalities claimed in any of the
`Asserted Patents.
`UMC objects to the definition of “E3” as overbroad, vague and ambiguous,
`13.
`calling for a legal conclusion, providing insufficient identification and specificity, requiring
`subjective judgment and speculation, and seeking to impose duties or obligations beyond or
`inconsistent with those set forth in the Federal Rules of Civil Procedure, at least to the extent it
`would require UMC to speculate about what constitutes “Applied Materials’ E3 framework,
`platform, hardware, and/or software and all equipment modules of E3” and “all models, versions,
`and their predecessors,” and to the extent it covers systems, hardware, and/or software that has
`not been identified by Ocean in its pleadings or in its Preliminary Disclosure of Asserted Claims
`and Infringement Contentions in the underlying action and/or does not perform the accused
`functionalities claimed in any of the Asserted Patents.
`UMC objects to the definition of “SmartFactory” as overbroad, vague and
`14.
`ambiguous, calling for a legal conclusion, providing insufficient identification and specificity,
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`UMC’S OBJECTIONS TO OCEAN SEMICONDUCTOR LLC’S SUBPOENA
`TO TESTIFY AT A DEPOSITION IN A CIVIL ACTION
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`Case 6:20-cv-01214-ADA Document 54-7 Filed 02/16/22 Page 10 of 58
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`requiring subjective judgment and speculation, and seeking to impose duties or obligations
`beyond or inconsistent with those set forth in the Federal Rules of Civil Procedure, at least to the
`extent it would require UMC to speculate about what constitutes “Applied Materials’
`SmartFactory Productivity Solution framework, platform, hardware and/or software and all
`equipment modules of SmartFactory” and “all models, versions, and their predecessors,” and to
`the extent it covers systems, hardware, and/or software that has not been identified by Ocean in
`its pleadings or in its Preliminary Disclosure of Asserted Claims and Infringement Contentions
`in the underlying action and/or does not perform the accused functionalities claimed in any of the
`Asserted Patents.
`UMC objects to the definition of “Exensio” as overbroad, vague and ambiguous,
`15.
`calling for a legal conclusion, providing insufficient identification and specificity, requiring
`subjective judgment and speculation, and seeking to impose duties or obligations beyond or
`inconsistent with those set forth in the Federal Rules of Civil Procedure, at least to the extent it
`would require UMC to speculate about what constitutes “PDF Solutions’ Exensio framework,
`platform, hardware and/or software and all equipment modules of Exensio” and “all models,
`versions, and their predecessors,” and to the extent it covers systems, hardware, and/or software
`that has not been identified by Ocean in its pleadings or in its Preliminary Disclosure of Asserted
`Claims and Infringement Contentions in the underlying action and/or does not perform the
`accused functionalities claimed in any of the Asserted Patents.
`UMC objects to the definition of “Manufacturing Equipment” as overbroad,
`16.
`vague and ambiguous, calling for a legal conclusion, providing insufficient identification and
`specificity, requiring subjective judgment and speculation, and seeking to impose duties or
`obligations beyond or inconsistent with those set forth in the Federal Rules of Civil Procedure, at
`least to the extent it refers to “TWINSCAN,” “YieldStar,” “E3,” “SmartFactory,” and “Exensio,”
`for the same reasons as provided herein for those terms individually, and to the extent it would
`require UMC to speculate about what constitutes “their respective frameworks, platforms,
`hardware and/or software and all equipment modules.”
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`UMC’S OBJECTIONS TO OCEAN SEMICONDUCTOR LLC’S SUBPOENA
`TO TESTIFY AT A DEPOSITION IN A CIVIL ACTION
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`Case 6:20-cv-01214-ADA Document 54-7 Filed 02/16/22 Page 11 of 58
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`UMC objects to the definition of “Equipment Manufacturers” as overbroad, vague
`17.
`and ambiguous, calling for a legal conclusion, providing insufficient identification and
`specificity, requiring subjective judgment and speculation, and seeking to impose duties or
`obligations beyond or inconsistent with those set forth in the Federal Rules of Civil Procedure, at
`least to the extent it refers to “Manufacturing Equipment,” for the same reasons as provided
`herein for that term.
`UMC objects to the definition of “MES” as overbroad, vague and ambiguous,
`18.
`calling for a legal conclusion, providing insufficient identification and specificity, requiring
`subjective judgment and speculation, and seeking to impose duties or obligations beyond or
`inconsistent with those set forth in the Federal Rules of Civil Procedure, at least to the extent it
`would require UMC to speculate about what constitutes “any and all manufacturing execution
`system used for monitoring, tracking, and/or documenting the process of manufacturing,
`fabricating, and/or assembling,” to the extent it covers systems, hardware, and/or software that
`has not been identified by Ocean in its pleadings or in its Preliminary Disclosure of Asserted
`Claims and Infringement Contentions in the underlying action and/or does not perform the
`accused functionalities claimed in any of the Asserted Patents, and to the extent it is inconsistent
`with any use of this term or similar terms in any of the Asserted Patents, or in any claim
`construction order or other orders entered in the underlying action.
`UMC objects to the definition of “Product” and “Products” as overbroad, vague
`19.
`and ambiguous, calling for a legal conclusion, providing insufficient identification and
`specificity, requiring subjective judgment and speculation, and seeking to impose duties or
`obligations beyond or inconsistent with those set forth in the Federal Rules of Civil Procedure, at
`least to the extent it would require UMC to speculate about what constitutes “any and all
`components, subcomponents, auxiliary components, and accessory products,” and to the extent it
`covers systems, hardware, and/or software that has not been identified by Ocean in its pleadings
`or in its Preliminary Disclosure of Asserted Claims and Infringement Contentions in the
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`UMC’S OBJECTIONS TO OCEAN SEMICONDUCTOR LLC’S SUBPOENA
`TO TESTIFY AT A DEPOSITION IN A CIVIL ACTION
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`Case 6:20-cv-01214-ADA Document 54-7 Filed 02/16/22 Page 12 of 58
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`underlying action and/or does not perform the accused functionalities claimed in any of the
`Asserted Patents.
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`OBJECTIONS TO INSTRUCTIONS
`UMC objects to the Instructions in Attachment A to the Subpoena to the extent
`1.
`they seek to impose duties or obligations beyond or inconsistent with those set forth in the
`Federal Rules of Civil Procedure or any other applicable rule or law.
`
`SPECIFIC OBJECTIONS TO REQUESTS FOR
`PRODUCTION OF DOCUMENTS
`
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`REQUEST NO. 1:
`Documents sufficient to show the use, utilization, installation, implementation, and/or
`deployment of any Manufacturing Equipment in any of Your manufacturing and/or fabrication
`facility in connection with Your manufacture, fabrication, and/or assembly of any and all
`Infringing Instrumentalities for any Defendant, including the identification of all versions and
`models of any such system and the location of such use, utilization, installation, implementation,
`and/or deployment including the location of any and all such fabrication facilities.
`OBJECTIONS TO REQUEST NO. 1:
`UMC incorporates each of its General Objections, Objections to Definitions, and
`Objections to Instructions herein by reference. UMC further objects to this Request to the extent
`it seeks information that is protected from discovery by the attorney-client privilege, the attorney
`work-product doctrine, or any other applicable privilege or immunity. UMC further objects to
`this Request to the extent it seeks information not in UMC’s possession, custody or control.
`UMC further objects to this Request as overbroad, vague and ambiguous, imposing
`undue burden and expense, calling for a legal conclusion, providing insufficient identification
`and specificity, requiring subjective judgment and speculation, seeking information that is not
`relevant to any party’s claim or defense and proportional to the needs of the case, and seeking to
`impose duties or obligations beyond or inconsistent with those set forth in the Federal Rules of
`Civil Procedure, at least to the extent it seeks information about “any Manufacturing
`
`
`
`-11-
`UMC’S OBJECTIONS TO OCEAN SEMICONDUCTOR LLC’S SUBPOENA
`TO TESTIFY AT A DEPOSITION IN A CIVIL ACTION
`
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`Case 6:20-cv-01214-ADA Document 54-7 Filed 02/16/22 Page 13 of 58
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`Equipment,” about “Your manufacturing and/or fabrication facility,” about “any and all
`Infringing Instrumentalities,” and about “any Defendant.”
`UMC further objects to this Request as seeking information that is more readily and/or
`appropriately available from, or confidential to, another non-party, at least to the extent it seeks
`information about “any Manufacturing Equipment.”
`UMC further objects to this Request as seeking information that that is available from
`one or more parties to the underlying action, and duplicative of other discovery already taken or
`requested in the underlying action, at least to the extent it seeks information about “any and all
`Infringing Instrumentalities for any Defendant.”
`UMC further objects to this Request as seeking trade secret and/or other confidential
`research, development, or commercial information, at least to the extent it seeks information
`about “use, utilization, installation, implementation, and/or deployment of any Manufacturing
`Equipment in any of Your manufacturing and/or fabrication facility,” about “Your manufacture,
`fabrication, and/or assembly of any and all Infringing Instrumentalities for any Defendant,” and
`about “identification of all versions and models of any such system and the location of such use,
`utilization, installation, implementation, and/or deployment including the location of any and all
`such fabrication facilities.” Any production by UMC of information sought by the Subpoena
`will be made pursuant to the Protective Order governing the disclosure of confidential
`information in the underlying action. UMC reserves the right to insist upon supplemental
`protections.
`In view of these specific objections and the foregoing Preliminary Statement, General
`Objections, Objections to Definitions, and Objections to Instructions, UMC is not producing
`documents sought by this Request.
`REQUEST NO. 2:
`Purchase or sales orders, invoices, purchase agreements, sales agreements, and/or
`supplier agreements relating to any Manufacturing Equipment.
`
`
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`UMC’S OBJECTIONS TO OCEAN SEMICONDUCTOR LLC’S SUBPOENA
`TO TESTIFY AT A DEPOSITION IN A CIVIL ACTION
`
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`Case 6:20-cv-01214-ADA Document 54-7 Filed 02/16/22 Page 14 of 58
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`OBJECTIONS TO REQUEST NO. 2:
`UMC incorporates each of its General Objections, Objections to Definitions, and
`Objections to Instructions herein by reference. UMC further objects to this Request to the extent
`it seeks information that is protected from discovery by the attorney-client privilege, the attorney
`work-product doctrine, or any other applicable privilege or immunity. UMC further objects to
`this Request to the extent it seeks information not in UMC’s possession, custody or control.
`UMC further objects to this Request as overbroad, vague and ambiguous, imposing
`undue burden and expense, calling for a legal conclusion, providing insufficient identification
`and specificity, requiring subjective judgment and speculation, seeking information that is not
`relevant to any party’s claim or defense and proportional to the needs of the case, and seeking to
`impose duties or obligations beyond or inconsistent with those set forth in the Federal Rules of
`Civil Procedure, at least to the extent it seeks information about “any Manufacturing
`Equipment.”
`UMC further objects to this Request as seeking information that is more readily and/or
`appropriately available from, or confidential to, another non-party, at least to the extent it seeks
`information about “[p]urchase or sales orders, invoices, purchase agreements, sales agreements,
`and/or supplier agreements relating to any Manufacturing Equipment.”
`UMC further objects to this Request as seeking trade secret and/or other confidential
`research, development, or commercial information, at least to the extent it seeks information
`about “[p]urchase or sales orders, invoices, purchase agreements, sales agreements, and/or
`supplier agreements relating to any Manufacturing Equipment.” Any production by UMC of
`information sought by the Subpoena will be made pursuant to the Protective Order governing the
`disclosure of confidential information in the underlying action. UMC reserves the right to insist
`upon supplemental protections.
`In view of these specific objections and the foregoing Preliminary Statement, General
`Objections, Objections to Definitions, and Objections to Instructions, UMC is not producing
`documents sought by this Request.
`
`
`
`-13-
`UMC’S OBJECTIONS TO OCEAN SEMICONDUCTOR LLC’S SUBPOENA
`TO TESTIFY AT A DEPOSITION IN A CIVIL ACTION
`
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`Case 6:20-cv-01214-ADA Document 54-7 Filed 02/16/22 Page 15 of 58
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`REQUEST NO. 3:
`Documents relating to the design, development, operation, and/