It is argued that for the micro controllers genuinely at issue in this investigation, Renesas has already listed separately all sales in the United States and issue in this investigation, Renesas has already listed separately all sales in the United States and importations of those products during 2006 and 2007, along with much more detailed importations of those products during 2006 and 2007, along with much more detailed See, e.g., Samsung Mot.
")("Accused Product" includes “any Semiconductor Product designed, developed, fabricated, produced, manufactured, "any Semiconductor Product designed, developed, fabricated, produced, manufactured, assembled or distributed by or for Renesas, including but not limited to all models and version of assembled or distributed by or for Renesas, including but not limited to all models and version of ] microcontroller ... .” (emphasis added)).
In any event, as in the case of the discovery requests discussed above, some of the deposition topics served by Samsung are extremely broad, if not vague.
Renesas is, of course, under an obligation to provide Samsung with any reasonable Renesas is, of course, under an obligation to provide Samsung with any reasonable assistance that it may require in locating information within the many thousands of pages already assistance that it may require in locating information within the many thousands of pages already produced, such as the detailed identification of responsive documents by Bates number.