Any ESI (by type, date, custodian, electronic system or other criteria) that _a party asserts is not reasonably accessible under Fed. R. Civ.
Production of information subject to privacy protections, 1 The three Defendant Groups are: (1) Activision/Blizzard, Inc. ("Activision"); (2) Electronics Arts, Inc. ("EA"); and (3) Take-Two Interactive Software, Inc., Rockstar Games, Inc., and 2K Sports, Inc. (collectively, "Take-Two").
Defendants shall produce to Plaintiff the core technical documents related to the accused product(s) and accused networking functionalities (to the extent such documents exist), including but not limited to operation manuals, product literature, schematics, and specifications as follows: i. December 16, 2015: for specific games and version identified in Original Complaint as to Take-Two and EA and the First Amended Complaint as to Activision.3 1i.
Plaintiff shall produce to Defendant(s) an initial claim .chart relating each accused product to the asserted claims each product allegedly infringes as follows: i. February 17, 2016: for specific games and version identified in Original Complaint as to Take-Two and EA and the First Amended Complaint as to Activision, as well as any other versions of those games for which core technical documents were produced prior to December 16, 2015.
The parties are not required to -prepare privilege logs or otherwise schedule documents withheld from production to the extent they (1) relate to activities undertaken in compliance with the duty to preserve information under Fed. R. Civ.