Case 2:19-cv-06301-AB-KS Document 83-3 Filed 07/22/20 Page 1 of 17 Page ID #:2512
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`Exhibit C
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`Exhibit C
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`Case 2:19-cv-06301-AB-KS Document 83-3 Filed 07/22/20 Page 2 of 17 Page ID #:2513
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`JEAN-PAUL CIARDULLO, CA Bar No. 284170
` jciardullo@foley.com
`FOLEY & LARDNER LLP
`555 South Flower Street, Suite 3300
`Los Angeles, CA 90071
`Telephone: 213-972-4500
`Facsimile: 213-486-0065
`
`ELEY O. THOMPSON (pro hac vice)
` ethompson@foley.com
`FOLEY & LARDNER LLP
`321 N. Clark Street, Suite 2800
`Chicago, IL 60654-5313
`Telephone: 312-832-4359
`Facsimile: 312-83204700
`
`LUCAS I. SILVA (pro hac vice)
`lsilva@foley.com
`RUBEN J. RODRIGUES (pro hac vice)
`rrodrigues@foley.com
`JOHN W. CUSTER (pro hac vice)
`jcuster@foley.com
`
`FOLEY & LARDNER LLP
`111 Huntington Avenue, Suite 2500
`Boston, MA 02199-7610
`Telephone: (617) 342-4000
`Facsimile: (617) 342-4001
`
`Attorneys for Plaintiff
`Philips North America LLC
`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF CALIFORNIA
`WESTERN DIVISION
`
` Case No. 2:19-cv-06301-AB-KS
`PHILIPS NORTH AMERICA, LLC’S
`OBJECTIONS AND RESPONSES TO
`DEFENDANT GARMIN
`INTERNATIONAL, INC’S FOURTH
`SET OF DISCOVERY REQUESTS
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`
`
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`Philips North America LLC,
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`
`
`
`Plaintiff,
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`
`v.
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`Garmin International, Inc.
`and Garmin Ltd.,
`
`
`
`
`Defendants.
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`
`
`
`
`PHILIPS’S OBJECTIONS AND RESPONSES TO GARMIN
`INTERNATIONAL’S FOURTH SET OF DISCOVERY REQUESTS
`CASE NO. 2:19-cv-06301-AB-KS
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`Case 2:19-cv-06301-AB-KS Document 83-3 Filed 07/22/20 Page 3 of 17 Page ID #:2514
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`PHILIPS NORTH AMERICA, LLC’S
`OBJECTIONS AND RESPONSES TO DEFENDANT GARMIN
`INTERNATIONAL, INC’S FOURTH SET OF DISCOVERY REQUESTS
`
`Pursuant to Rules 26, 33 and 34 of the Federal Rules of Civil Procedure, Plaintiff
`Philips North America LLC (“Philips”), by and through its attorneys, hereby objects and
`responds to Defendant Garmin International, Inc.’s (“Garmin”) Fourth Set of Discovery
`Requests as follows:
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`GENERAL OBJECTIONS
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`1.
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`Philips objects to each and every definition, interrogatory, request, and
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`instruction to the extent Garmin seeks to impose requirements or any burdens
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`inconsistent with or in addition to Philips’s obligations under the applicable rules,
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`including the Federal Rules of Civil Procedure, the Local Rules, any order of this Court,
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`or any stipulation or agreement between the parties.
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`2.
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`Philips objects to each and every interrogatory, request, definition, and
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`instruction to the extent it is overly broad, unduly burdensome, oppressive, and/or
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`irrelevant to the subject matter of this action. Philips further objects to each and every
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`interrogatory, request, definition, and instruction to the extent it is not proportional to the
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`needs of the case, considering the importance of the issues at stake in the action, the
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`amount in controversy, the party’s relative resources, the importance of the discovery in
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`resolving the issues, and whether the burden or expense of the proposed discovery
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`outweighs its likely benefit.
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`3.
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`Philips objects to each and every interrogatory, request, definition, and
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`instruction to the extent Garmin seeks information that is protected by the attorney-client
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`1
` PHILIPS’S OBJECTIONS AND RESPONSES TO GARMIN
`INTERNATIONAL’S FOURTH SET OF DISCOVERY REQUESTS
`CASE NO. 2:19-cv-06301-AB-KS
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`Case 2:19-cv-06301-AB-KS Document 83-3 Filed 07/22/20 Page 4 of 17 Page ID #:2515
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`privilege, the work product immunity doctrine, and/or any other applicable privilege,
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`prohibition, limitation, or immunity from disclosure. Inadvertent production of such
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`information shall not constitute the waiver of any applicable privilege, doctrine,
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`immunity, or objection, including, but not limited to, objections on the basis of
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`competency, confidentiality, relevancy, materiality, work product, privilege, and/or
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`admissibility as evidence.
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`4.
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` Philips objects to each and every interrogatory, request, definition, and
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`instruction to the extent Garmin calls for information or the production of documents or
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`things not in Philips’s possession, custody, or control, and/or not obtainable by means of
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`a reasonably diligent search, including, without limitation, documents or things that are
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`not maintained by Philips in the normal course of business or that are no longer
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`maintained by Philips.
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`5.
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`Philips objects to each and every interrogatory, request, definition, and
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`instruction to the extent Garmin seeks information that is already in its possession or
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`available from a public source as to which the burden of Garmin’s obtaining such
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`information is the same as or less than it would be for Philips.
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`6.
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`Philips objects to each and every interrogatory, request, definition, and
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`instruction to the extent Garmin seeks information that is a trade secret and/or
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`confidential or proprietary business information of Philips or any third party. To the
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`extent that Philips agrees to provide documents or material containing confidential
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`2
` PHILIPS’S OBJECTIONS AND RESPONSES TO GARMIN
`INTERNATIONAL’S FOURTH SET OF DISCOVERY REQUESTS
`CASE NO. 2:19-cv-06301-AB-KS
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`Case 2:19-cv-06301-AB-KS Document 83-3 Filed 07/22/20 Page 5 of 17 Page ID #:2516
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`information, it will only do so subject to the Protective Order proposed and/or entered in
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`this case.
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`7.
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`Philips objects to each request that may seek documents or information
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`related to foreign proceedings on the basis that any foreign proceedings are not relevant
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`to this action, and any production of materials in response to this request should not be
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`treated as an admission as to the relevance or admissibility of any documents, materials,
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`or submissions made in a foreign proceeding.
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`8.
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`Philips objects to each and every request, definition, and instruction to the
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`extent it is vague, ambiguous, or confusing by failing to adequately define terms or
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`failing to describe the information with reasonable particularity. Subject to the General
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`and Specific Objections, Philips will produce reasonably available, relevant, responsive,
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`non-privileged information only to the extent that Philips understands each request and to
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`the extent such information is available after a reasonable search.
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`9.
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`Philips objects to each and every request, definition, and instruction to the
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`extent Garmin seeks the disclosure of third party confidential information that Philips is
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`under a legal duty not to disclose.
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`10. Philips objects to each and every request, definition, and instruction to the
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`extent they are inconsistent with the Local Rules, any applicable Standing Orders, any
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`Scheduling Order in this case, any Docket Control Order in this case, any order on the
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`discovery of Electronically Stored Information, and/or any Joint Discovery / Case
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`Management Plan in this case.
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`3
` PHILIPS’S OBJECTIONS AND RESPONSES TO GARMIN
`INTERNATIONAL’S FOURTH SET OF DISCOVERY REQUESTS
`CASE NO. 2:19-cv-06301-AB-KS
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`Case 2:19-cv-06301-AB-KS Document 83-3 Filed 07/22/20 Page 6 of 17 Page ID #:2517
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`11. Philips objects to each and every production request, definition, and
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`instruction to the extent it seeks production of “all” documents that relate to a particular
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`subject on the grounds of overbreadth, undue burden, and expense.
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`12. Philips objects to the definitions of the terms “you” and “Philips” to the
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`extent that Garmin seeks to compel Philips to collect or produce information or
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`documents from parties from whom Philips has no right or obligation to collect
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`information or documents. Philips also objects to these definitions insofar as they seek
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`information that is (a) not within Philips’s possession, custody, or control, and/or (b)
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`protected from discovery by the attorney-client privilege, work product doctrine, or any
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`other applicable privilege, immunity, or protection. Philips further objects to the
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`definitions of the terms “you” and “Philips” as being vague, overbroad, and unduly
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`burdensome to the extent that Garmin intends to impose discovery obligations on any
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`person who is not a party to this litigation. Philips further objects to the definitions to the
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`extent Garmin seeks to impose obligations on Philips beyond those required by the
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`Federal Rules of Civil Procedure, the Local Civil Rules of this Court, and any applicable
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`orders of this Court.
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`13. Philips objects to the definitions of the term “Prior Art” to the extent that
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`this definition calls for legal conclusions.
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`14. Philips does not waive any objection that may be applicable to: (a) the use,
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`for any purpose, by Philips of any information provided in response; or (b) the
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`admissibility, relevance, or materiality of any of the information to any issue in this case.
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`4
` PHILIPS’S OBJECTIONS AND RESPONSES TO GARMIN
`INTERNATIONAL’S FOURTH SET OF DISCOVERY REQUESTS
`CASE NO. 2:19-cv-06301-AB-KS
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`Case 2:19-cv-06301-AB-KS Document 83-3 Filed 07/22/20 Page 7 of 17 Page ID #:2518
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`Moreover, a response stating that Philips will produce information regarding a request
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`does not constitute an admission that any information regarding that request exists or can
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`be located after a reasonable search, or is known or reasonably available to Philips.
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`15. Each and every General Objection shall be deemed to be incorporated in full
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`into each of the individual responses set forth below. Any specific objections to a
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`production request or interrogatory are made in addition to the General Objections, not as
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`a replacement for them. Philips’s investigation into the party’s claims and defenses is
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`continuing. Philips’s objections and responses to these production requests are based
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`upon the information in its possession after diligent inquiry at the time of preparation of
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`these responses. Philips reserves the right to amend, supplement, modify, and/or correct
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`its objections or responses as additional information becomes available to Philips and in
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`the course of its investigation and as discovery in this case progresses.
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`SPECIFIC OBJECTIONS AND RESPONSES
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`Philips hereby incorporates its General Objections set forth above into its Specific
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`Objections and Responses set forth below.
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`REQUESTS FOR PRODUCTION
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`Request for Production No. 33:
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`
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`Communications and agreements between You and any other party, including the
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`inventors of the Asserted Patents, relating to this Lawsuit.
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`Response to Request for Production No. 33:
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`5
` PHILIPS’S OBJECTIONS AND RESPONSES TO GARMIN
`INTERNATIONAL’S FOURTH SET OF DISCOVERY REQUESTS
`CASE NO. 2:19-cv-06301-AB-KS
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`Case 2:19-cv-06301-AB-KS Document 83-3 Filed 07/22/20 Page 8 of 17 Page ID #:2519
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`In addition to its General Objections, which are incorporated herein by reference,
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`Philips objects to the extent this Request seeks information protected from discovery by
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`the attorney client privilege and/or attorney work product.
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`Subject to and without waiving its General and Specific Objections, Philips
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`responds as follows: Philips will produce reasonably available, non-privileged responsive
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`documents, to the extent any exist, that are in its possession, custody or control, subject to
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`the protective order and e-discovery order entered in this case and does not intend to
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`withhold documents except on the basis of privilege.
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`Philips reserves the right to supplement its response to this Request.
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`Request for Production No. 34:
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`Documents relating to the prosecution of the ’192 Patent, including but not limited
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`to files, documents, communications, drafts, or memoranda relating to the prosecution of
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`the patent.
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`Response to Request for Production No. 34:
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`In addition to its General Objections, which are incorporated herein by reference,
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`Philips objects to the extent this Request seeks information protected from discovery by
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`the attorney client privilege and/or attorney work product.
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`Subject to and without waiving its General and Specific Objections, Philips
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`responds as follows: Philips has produced reasonably available, non-privileged
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`responsive documents, to the extent any exist, that are in its possession, custody or
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`6
` PHILIPS’S OBJECTIONS AND RESPONSES TO GARMIN
`INTERNATIONAL’S FOURTH SET OF DISCOVERY REQUESTS
`CASE NO. 2:19-cv-06301-AB-KS
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`Case 2:19-cv-06301-AB-KS Document 83-3 Filed 07/22/20 Page 9 of 17 Page ID #:2520
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`control, subject to the protective order and e-discovery order entered in this case and does
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`not intend to withhold documents except on the basis of privilege.
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`Philips reserves the right to supplement its response to this Request.
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`Request for Production No. 35:
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`Documents reflecting the structure, contents, filing hierarchy, and accessibility of
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`information related to Philips Intellectual Property and Standards (“Philips IP&S”)
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`internal docketing number “PH003603,” which was later changed to “2005PO2656”
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`specifically including but not limited to the U.S. application with internal docketing
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`number PH003603 US1/2005PO2656WOUS and the European application with internal
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`docketing number PH003603 EP2/2005PO2656WE.
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`Response to Request for Production No. 35:
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`In addition to its General Objections, which are incorporated herein by reference,
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`Philips objects to the extent this Request seeks information protected from discovery by
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`the attorney client privilege and/or attorney work product.
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`Subject to and without waiving its General and Specific Objections, Philips
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`responds as follows: Philips will produce reasonably available, non-privileged responsive
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`documents, to the extent any exist, that are in its possession, custody or control, subject to
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`the protective order and e-discovery order entered in this case and does not intend to
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`withhold documents except on the basis of privilege.
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`Philips reserves the right to supplement its response to this Request.
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`Request for Production No. 36:
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`7
` PHILIPS’S OBJECTIONS AND RESPONSES TO GARMIN
`INTERNATIONAL’S FOURTH SET OF DISCOVERY REQUESTS
`CASE NO. 2:19-cv-06301-AB-KS
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`Case 2:19-cv-06301-AB-KS Document 83-3 Filed 07/22/20 Page 10 of 17 Page ID #:2521
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`Documents reflecting the identity of computers or server architecture utilized by
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`Philips IP&S in connection with the prosecution of the ’192 Patent.
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`Response to Request for Production No. 36:
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`In addition to its General Objections, which are incorporated herein by reference,
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`Philips objects to the extent this Request seeks information protected from discovery by
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`the attorney client privilege and/or attorney work product. Philips additionally objects to
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`this request as vague and ambiguous to the extent it requests information reflecting “the
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`identity of computers or server architecture utilized by Philips.” Philips further objects to
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`this request as overly broad and unduly burdensome to the extent it requests that Philips
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`conduct an inventory of computers and servers that may have had some connection with
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`the prosecution of the ’192 Patent, which would involve a significant expenditure of time
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`and resources which would not be commensurate with the needs of this case.
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`Accordingly, Philips can agree to meet and confer with regard to the scope of this
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`request.
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`Philips reserves the right to supplement its response to this Request.
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`Request for Production No. 37:
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`Documents sufficient to identify all individuals affiliated with Philips IP&S that
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`were involved in any way with the prosecution of the ’192 Patent.
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`Response to Request for Production No. 37:
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`In addition to its General Objections, which are incorporated herein by reference,
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`Philips objects to the extent this Request seeks information protected from discovery by
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`8
` PHILIPS’S OBJECTIONS AND RESPONSES TO GARMIN
`INTERNATIONAL’S FOURTH SET OF DISCOVERY REQUESTS
`CASE NO. 2:19-cv-06301-AB-KS
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`Case 2:19-cv-06301-AB-KS Document 83-3 Filed 07/22/20 Page 11 of 17 Page ID #:2522
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`the attorney client privilege and/or attorney work product. Philips further objects to this
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`request as vague and ambiguous for requesting materials sufficient to identify all
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`individuals “involved in any way” with the prosecution of the ’192 Patent.
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`Subject to and without waiving its General and Specific Objections, Philips
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`responds as follows: Philips will produce reasonably available, non-privileged documents
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`concerning the prosecution of the ’192 Patent, that are in its possession, custody or
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`control, subject to the protective order and e-discovery order entered in this case and does
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`not intend to withhold documents except on the basis of privilege.
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`Philips reserves the right to supplement its response to this Request.
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`Request for Production No. 38:
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`Documents relating to Philips IP&S’ knowledge that the claims of the European
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`patent application from which the ’192 Patent claims priority were found to be not novel
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`in view of US 2006/112754 A1/WO 2004/091400 A1 (collectively, “Yamamoto”
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`reference).
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`Response to Request for Production No. 38:
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`In addition to its General Objections, which are incorporated herein by reference,
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`Philips objects to the extent this Request seeks information protected from discovery by
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`the attorney client privilege and/or attorney work product.
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`Subject to and without waiving its General and Specific Objections, Philips
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`responds as follows: Philips will produce reasonably available, non-privileged documents
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`concerning the prosecution of the ’192 Patent, that are in its possession, custody or
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`9
` PHILIPS’S OBJECTIONS AND RESPONSES TO GARMIN
`INTERNATIONAL’S FOURTH SET OF DISCOVERY REQUESTS
`CASE NO. 2:19-cv-06301-AB-KS
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`Case 2:19-cv-06301-AB-KS Document 83-3 Filed 07/22/20 Page 12 of 17 Page ID #:2523
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`control, subject to the protective order and e-discovery order entered in this case and does
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`not intend to withhold documents except on the basis of privilege.
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`Philips reserves the right to supplement its response to this Request.
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`Request for Production No. 39:
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`Documents relating to Philips IP&S’ failure to disclose Yamamoto to the United
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`States Patent and Trademark Office in connection with the prosecution of the ’192 Patent,
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`including any communications, notes, memoranda, or other documentation relating to the
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`reasons for such failure to disclose Yamamoto.
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`Response to Request for Production No. 39:
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`In addition to its General Objections, which are incorporated herein by reference,
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`Philips objects to the extent this Request seeks information protected from discovery by
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`the attorney client privilege and/or attorney work product. Philips objects to this request
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`as mischaracterizing the record for characterizing Philips’s conduct as a “failure” to do
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`anything. To Philips’s knowledge, Philips did not “fail” to meet any obligations required
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`of it.
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`Subject to and without waiving its General and Specific Objections, Philips
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`responds as follows: Philips will produce reasonably available, non-privileged documents
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`concerning the prosecution of the ’192 Patent, that are in its possession, custody or
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`control, subject to the protective order and e-discovery order entered in this case and does
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`not intend to withhold documents except on the basis of privilege.
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`Philips reserves the right to supplement its response to this Request.
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`10
` PHILIPS’S OBJECTIONS AND RESPONSES TO GARMIN
`INTERNATIONAL’S FOURTH SET OF DISCOVERY REQUESTS
`CASE NO. 2:19-cv-06301-AB-KS
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`Case 2:19-cv-06301-AB-KS Document 83-3 Filed 07/22/20 Page 13 of 17 Page ID #:2524
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`Request for Production No. 40:
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`Documents relating to Philips IP&S decision to disclose other prior art references
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`to the United States Patent and Trademark Office in connection with the prosecution of
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`the ’192 Patent, including any communications, notes, memoranda, or other
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`documentation relating to the reasons for such disclosure.
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`Response to Request for Production No. 40:
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`In addition to its General Objections, which are incorporated herein by reference,
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`Philips objects to the extent this Request seeks information protected from discovery by
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`the attorney client privilege and/or attorney work product.
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`Subject to and without waiving its General and Specific Objections, Philips
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`responds as follows: Philips will produce reasonably available, non-privileged documents
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`concerning the prosecution of the ’192 Patent, that are in its possession, custody or
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`control, subject to the protective order and e-discovery order entered in this case and does
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`not intend to withhold documents except on the basis of privilege.
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`Philips reserves the right to supplement its response to this Request.
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`Request for Production No. 41:
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`Documents relating to Philips IP&S decision to disclose JP 2003-102692 to the
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`United States Patent and Trademark Office in connection with the prosecution of the ’192
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`Patent.
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`Response to Request for Production No. 41:
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`11
` PHILIPS’S OBJECTIONS AND RESPONSES TO GARMIN
`INTERNATIONAL’S FOURTH SET OF DISCOVERY REQUESTS
`CASE NO. 2:19-cv-06301-AB-KS
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`Case 2:19-cv-06301-AB-KS Document 83-3 Filed 07/22/20 Page 14 of 17 Page ID #:2525
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`In addition to its General Objections, which are incorporated herein by reference,
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`Philips objects to the extent this Request seeks information protected from discovery by
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`the attorney client privilege and/or attorney work product.
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`Subject to and without waiving its General and Specific Objections, Philips
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`responds as follows: Philips will produce reasonably available, non-privileged documents
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`concerning the prosecution of the ’192 Patent, that are in its possession, custody or
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`control, subject to the protective order and e-discovery order entered in this case and does
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`not intend to withhold documents except on the basis of privilege.
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`Philips reserves the right to supplement its response to this Request.
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`Request for Production No. 42:
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`Documents relating to Philips’ membership in the Bluetooth Special Interest Group
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`(“Bluetooth SIG”), including any agreements between Philips and Bluetooth SIG,
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`contributions made by Philips to the Bluetooth SIG, and communications between
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`individuals at Philips and the Bluetooth SIG or its members.
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`Response to Request for Production No. 42:
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`In addition to its General Objections, which are incorporated herein by reference,
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`Philips objects to the extent this Request seeks information protected from discovery by
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`the attorney client privilege and/or attorney work product. Philips further objects to this
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`request as overly broad, unduly burdensome, and not proportional to, nor commensurate
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`with, the needs of this case. It is unclear what possible relevance or need underlies this
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`request.
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`12
` PHILIPS’S OBJECTIONS AND RESPONSES TO GARMIN
`INTERNATIONAL’S FOURTH SET OF DISCOVERY REQUESTS
`CASE NO. 2:19-cv-06301-AB-KS
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`Case 2:19-cv-06301-AB-KS Document 83-3 Filed 07/22/20 Page 15 of 17 Page ID #:2526
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`Accordingly, Philips can agree to meet and confer with regards to the scope of this
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`request.
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`Philips reserves the right to supplement its response to this Request.
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` PHILIPS’S OBJECTIONS AND RESPONSES TO GARMIN
`INTERNATIONAL’S FOURTH SET OF DISCOVERY REQUESTS
`CASE NO. 2:19-cv-06301-AB-KS
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`Case 2:19-cv-06301-AB-KS Document 83-3 Filed 07/22/20 Page 16 of 17 Page ID #:2527
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` DATED: July 13, 2020
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`Respectfully submitted
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`FOLEY & LARDNER LLP
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`/s/ Ruben J. Rodrigues
`Jean-Paul Ciardullo
`Eley O. Thompson
`Ruben J. Rodrigues
`Lucas I. Silva
`John W. Custer
`FOLEY & LARDNER LLP
`Attorneys for Plaintiff
`Philips North America, LLC
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` PHILIPS’S OBJECTIONS AND RESPONSES TO GARMIN
`INTERNATIONAL’S FOURTH SET OF DISCOVERY REQUESTS
`CASE NO. 2:19-cv-06301-AB-KS
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`Case 2:19-cv-06301-AB-KS Document 83-3 Filed 07/22/20 Page 17 of 17 Page ID #:2528
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a true and correct copy of the above
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`document was served on July 13, 2020 on counsel for Defendants via electronic mail.
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` John W. Custer
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` PHILIPS’S OBJECTIONS AND RESPONSES TO GARMIN
`INTERNATIONAL’S FOURTH SET OF DISCOVERY REQUESTS
`CASE NO. 2:19-cv-06301-AB-KS
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