Case 1:13-cv-00919-LPS Document 193-2 Filed 12/12/19 Page 1 of 51 PageID #: 5991
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`Exhibit B
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`PUBLIC VERSION
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`Case 1:13-cv-00919-LPS Document 193-2 Filed 12/12/19 Page 2 of 51 PageID #: 5992
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`C.A. No. 13-919-LPS
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`JURY TRIAL DEMANDED
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`)))))))))
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`ARENDI S.A.R.L.,
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`Plaintiff,
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`v.
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`GOOGLE INC.,
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`Defendant.
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`GOOGLE, INC.’S OBJECTIONS AND RESPONSES TO PLAINTIFF
`ARENDI S.A.R.L.’S FIRST SET OF REQUESTS
`FOR PRODUCTION OF DOCUMENTS
`Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure, Defendant Google,
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`Inc. (“Google”), by its attorneys, Kaye Scholer LLP, objects and responds to Plaintiff Arendi
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`S.A.R.L.’s (“Plaintiff”) First Set of Requests for Production of Documents(the “Requests”) as
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`follows:
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`GENERAL OBJECTIONS
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`1.
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`Google objects to the Requests to the extent that they seek information or material
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`protected by the attorney-client privilege, the work-product doctrine, the joint defense privilege,
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`or any other applicable privilege, immunity, or protection. Any inadvertent production of any
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`privileged documents in response to the Requests is not intended to constitute a waiver of any
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`applicable privilege and/or protection.
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`2.
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`Google objects to the Requests to the extent that any of them, read alone or in
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`conjunction with the “Definitions” and/or “Instructions,” purports to impose obligations not
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`imposed or contemplated by the Federal Rules of Civil Procedure, the Local Rules of the United
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`States District Court for the District of Delaware, or any agreements or stipulations entered into
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`by the parties.
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`

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`Case 1:13-cv-00919-LPS Document 193-2 Filed 12/12/19 Page 3 of 51 PageID #: 5993
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`3.
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`Google objects to the Requests to the extent that they seek documents that are not
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`relevant to the subject matter of this action and/or not reasonably calculated to lead to the
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`discovery of admissible evidence.
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`4.
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`Google objects to the Requests to the extent that they seek documents that are
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`already in Plaintiff’s possession, custody, or control, or that are publicly available or are as
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`readily available to Plaintiff as they are to Google.
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`5.
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`Google objects to the Requests to the extent that they seek documents whose
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`disclosure is governed by Google’s agreements with third parties, including confidentiality
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`agreements. Google will produce such documents only after complying with, and in compliance
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`with, the terms of such third-party agreements.
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`6.
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`Google objects to the Requests to the extent that they are vague, ambiguous,
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`overly broad, unduly burdensome, unreasonably cumulative, or duplicative.
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`7.
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`Google expressly reserves the right to object to the admissibility at trial of these
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`Responses and Objections or any documents or information produced in response to these
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`Requests. Neither Google’s Responses and Objections to the Requests nor the production of
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`materials in response to the Requests is intended as an admission or concession of the
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`admissibility of any information contained herein.
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`8.
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`Google objects to the Requests to the extent that they assume disputed facts or
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`legal conclusions in defining the information requested. Google denies any such disputed facts
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`or legal conclusions assumed by the Requests, and any response or objection to any Request is
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`without prejudice to this objection.
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`9.
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`Google objects to the Requests, and to each and every individual request
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`contained therein, to the extent that they call for Google to identify privileged documents created
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`after the filing of this lawsuit on the grounds that such Requests are overly broad and
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`burdensome and not reasonably calculated to lead to the discovery of admissible evidence, and
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`would call for counsel to review all of its files and list most of the documents therein on a
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`privilege log.
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`2
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`10.
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`Google objects to the Requests to the extent that they seek information protected
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`by or involving trade secrets or other confidential research, development, proprietary or
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`commercial information that would not be covered by the Protective Order, or similar Order
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`issued by the Court.
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`11.
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`Google objects to the Requests to the extent they call for production of documents
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`that are not within its possession, custody, or control.
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`12.
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`Google objects to the Requests to the extent they use undefined, vague, and
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`ambiguous terms.
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`13.
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`Google objects to the Requests to the extent they purport to require Google to
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`draw a legal conclusion concerning the meaning or application of any terms or phrases used.
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`14.
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`Google objects to the Requests to the extent they exceed the limits of permissible
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`discovery allowed under any court order or the local rules.
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`15.
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`Google reserves the right at any time to revise, correct, add to, supplement, or
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`clarify any of the responses contained herein.
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`16.
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`Google objects to Plaintiff’s definitions of “Document” and “Documents” as
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`overbroad, unduly burdensome and not reasonably calculated to lead to the discovery of
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`admissible evidence.
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`17.
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`Google objects to Plaintiff’s definitions of “sale,” “sales,” “sell,” or “sold” as
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`overbroad, unduly burdensome and not reasonably calculated to lead to the discovery of
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`admissible evidence.
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`18.
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`Google objects to Plaintiff’s definitions of “identify” and “identification” as
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`overbroad, unduly burdensome and not reasonably calculated to lead to the discovery of
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`admissible evidence.
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`19.
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`Google objects to Plaintiff’s definitions of “relate to,” “related to,” “relating to,”
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`or “concerning” as overbroad, unduly burdensome and not reasonably calculated to lead to the
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`discovery of admissible evidence.
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`3
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`Case 1:13-cv-00919-LPS Document 193-2 Filed 12/12/19 Page 5 of 51 PageID #: 5995
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`20.
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`Google objects to Plaintiff’s definitions of “you,” “your,” “yours” or “Defendant”
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`as overbroad, unduly burdensome and not reasonably calculated to lead to the discovery of
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`admissible evidence.
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`21.
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`Google’s agreement to produce responsive documents does not and shall not
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`constitute an admission that such responsive documents in fact exist. Rather, Google’s
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`agreement to produce is only an agreement to produce responsive documents found after a
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`reasonable search, if in fact such responsive documents are found to exist.
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`22.
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`Google will only produce documents relevant to the products actually identified
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`as accused products and charted in Plaintiff’s infringement charts as required under the local
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`rules.
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`23.
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`All of the General Objections set forth herein are hereby incorporated into each
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`specific response set forth below and have the same force and effect as if fully set forth therein.
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`RESPONSES TO REQUESTS FOR PRODUCTION
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`REQUEST FOR PRODUCTION NO. 1:
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`Documents sufficient to identify on at least a quarterly basis your unit sales for each of
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`the Accused Products by customer and territory.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 1:
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`Google objects to this Request as vague and overly broad. Google objects to this Request
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`to the extent it seeks information or documents protected from discovery by the attorney-client
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`privilege and/or the attorney work-product doctrine, the joint defense privilege, or any other
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`applicable privileges. Google objects to this request as premature in advance of its core technical
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`document production and Plaintiff’s infringement contentions. Google objects to this Request on
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`the grounds that the terms and phrases in this Request are vague and ambiguous, including but
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`not limited to “unit sales,” “customer,” and “territory.” Google objects to this Request to the
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`extent it seeks information not relevant to any inquiry in this matter.
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`Subject to and without waiving the foregoing general and specific objections, Google
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`responds that it will produce relevant documents responsive to this Request to the extent any
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`4
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`Case 1:13-cv-00919-LPS Document 193-2 Filed 12/12/19 Page 6 of 51 PageID #: 5996
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`exist that are in its possession, custody or control that are not protected from disclosure by any
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`applicable privilege or doctrine to the extent responsive documents can be identified after a
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`reasonable search and in accordance with the Scheduling Order.
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`REQUEST FOR PRODUCTION NO. 2:
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`Documents sufficient to identify on at least a quarterly basis the revenue you and entities
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`related to you have generated from sales of each of the Accused Products by customer and
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`territory.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 2:
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`Google objects to this Request as vague and overly broad. Google objects to this Request
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`to the extent it seeks information or documents protected from discovery by the attorney-client
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`privilege and/or the attorney work-product doctrine, the joint defense privilege, or any other
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`applicable privileges. Google objects to this request as premature in advance of its core technical
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`document production and Plaintiff’s infringement contentions. Google objects to this Request on
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`the grounds that the terms and phrases in this Request are vague and ambiguous, including but
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`not limited to “entities related to you,” “sales,” “customer,” and “territory.” Google objects to
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`this Request to the extent it seeks information not relevant to any inquiry in this matter.
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`Subject to and without waiving the foregoing general and specific objections, Google
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`responds that it will produce relevant documents responsive to this Request to the extent any
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`exist that are in its possession, custody or control that are not protected from disclosure by any
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`applicable privilege or doctrine to the extent responsive documents can be identified after a
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`reasonable search and in accordance with the Scheduling Order.
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`REQUEST FOR PRODUCTION NO. 3:
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`Documents sufficient to identify on at least a quarterly basis the costs you and entities
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`related to you have incurred in connection with each of the Accused Products by type of
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`expense.
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`5
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`Case 1:13-cv-00919-LPS Document 193-2 Filed 12/12/19 Page 7 of 51 PageID #: 5997
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 3:
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`Google objects to this Request as vague and overly broad. Google objects to this Request
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`to the extent it seeks information or documents protected from discovery by the attorney-client
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`privilege and/or the attorney work-product doctrine, the joint defense privilege, or any other
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`applicable privileges. Google objects to this request as premature in advance of its core technical
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`document production and Plaintiff’s infringement contentions. Google objects to this Request on
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`the grounds that the terms and phrases in this Request are vague and ambiguous, including but
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`not limited to “costs,” “entities related to you,” “in connection with,” and “type of expense.”
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`Google objects to this Request to the extent it seeks information not relevant to any inquiry in
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`this matter.
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`Subject to and without waiving the foregoing general and specific objections, Google
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`responds that it will produce relevant documents responsive to this Request to the extent any
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`exist that are in its possession, custody or control that are not protected from disclosure by any
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`applicable privilege or doctrine to the extent responsive documents can be identified after a
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`reasonable search and in accordance with the Scheduling Order.
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`REQUEST FOR PRODUCTION NO. 4:
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`Documents sufficient to identify on at least a quarterly basis the gross profits you and
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`entities related to you have earned in connection with each of the Accused Products, including
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`without limitation gross profit per unit.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 4:
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`Google objects to this Request as vague and overly broad. Google objects to this Request
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`to the extent it seeks information or documents protected from discovery by the attorney-client
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`privilege and/or the attorney work-product doctrine, the joint defense privilege, or any other
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`applicable privileges. Google objects to this request as premature in advance of its core technical
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`document production and Plaintiff’s infringement contentions. Google objects to this Request on
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`the grounds that the terms and phrases in this Request are vague and ambiguous, including but
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`6
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`Case 1:13-cv-00919-LPS Document 193-2 Filed 12/12/19 Page 8 of 51 PageID #: 5998
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`not limited to “entities related to you,” “in connection with,” and “unit.” Google objects to this
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`Request to the extent it seeks information not relevant to any inquiry in this matter.
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`Subject to and without waiving the foregoing general and specific objections, Google
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`responds that it will produce relevant documents responsive to this Request to the extent any
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`exist that are in its possession, custody or control that are not protected from disclosure by any
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`applicable privilege or doctrine to the extent responsive documents can be identified after a
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`reasonable search and in accordance with the Scheduling Order.
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`REQUEST FOR PRODUCTION NO. 5:
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`Documents sufficient to identify on at least a quarterly basis the operating profits you and
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`entities related to you have earned in connection with each of the Accused Products.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 5:
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`Google objects to this Request as vague and overly broad. Google objects to this Request
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`to the extent it seeks information or documents protected from discovery by the attorney-client
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`privilege and/or the attorney work-product doctrine, the joint defense privilege, or any other
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`applicable privileges. Google objects to this request as premature in advance of its core technical
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`document production and Plaintiff’s infringement contentions. Google objects to this Request on
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`the grounds that the terms and phrases in this Request are vague and ambiguous, including but
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`not limited to “operating profits,” “entities related to you,” and “in connection with.” Google
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`objects to this Request to the extent it seeks information not relevant to any inquiry in this
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`matter.
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`Subject to and without waiving the foregoing general and specific objections, Google
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`responds that it will produce relevant documents responsive to this Request to the extent any
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`exist that are in its possession, custody or control that are not protected from disclosure by any
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`applicable privilege or doctrine to the extent responsive documents can be identified after a
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`reasonable search and in accordance with the Scheduling Order.
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`7
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`Case 1:13-cv-00919-LPS Document 193-2 Filed 12/12/19 Page 9 of 51 PageID #: 5999
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`REQUEST FOR PRODUCTION NO. 6:
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`Documents sufficient to identify on at least a quarterly basis the incremental profit
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`margins you and entities related to you have realized for each of the Accused Products.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 6:
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`Google objects to this Request as vague and overly broad. Google objects to this Request
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`to the extent it seeks information or documents protected from discovery by the attorney-client
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`privilege and/or the attorney work-product doctrine, the joint defense privilege, or any other
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`applicable privileges. Google objects to this request as premature in advance of its core technical
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`document production and Plaintiff’s infringement contentions. Google objects to this Request on
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`the grounds that the terms and phrases in this Request are vague and ambiguous, including but
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`not limited to “incremental profit margins,” “entities related to you,” and “have realized for.”
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`Google objects to this Request to the extent it seeks information not relevant to any inquiry in
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`this matter.
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`Subject to and without waiving the foregoing general and specific objections, Google
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`responds that it will produce relevant documents responsive to this Request to the extent any
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`exist that are in its possession, custody or control that are not protected from disclosure by any
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`applicable privilege or doctrine to the extent responsive documents can be identified after a
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`reasonable search and in accordance with the Scheduling Order.
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`REQUEST FOR PRODUCTION NO. 7:
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`All documents relating to any indirect revenue or profit you realize by offering or selling
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`the Accused Products.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 7:
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`Google objects to this Request as vague and overly broad as it requests “all documents
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`relating to.” Google objects to this Request to the extent it seeks information or documents
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`protected from discovery by the attorney-client privilege and/or the attorney work-product
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`doctrine, the joint defense privilege, or any other applicable privileges. Google objects to this
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`request as premature in advance of its core technical document production and Plaintiff’s
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`8
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`Case 1:13-cv-00919-LPS Document 193-2 Filed 12/12/19 Page 10 of 51 PageID #: 6000
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`infringement contentions. Google objects to this Request on the grounds that the terms and
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`phrases in this Request are vague and ambiguous, including but not limited to “indirect revenue
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`or profit,” “realize,” and “offering or selling.” Google objects to this Request to the extent it
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`seeks information not relevant to any inquiry in this matter.
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`This request exceeds the scope of discovery permitted under FRCP 26(b)(1), seeks
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`information not relevant to any matter at issue in this litigation and/or is not likely to lead to the
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`discovery of admissible evidence. Therefore, Google states that it will not produce documents
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`responsive to this request. Google is willing to meet and confer with Plaintiff to discuss the
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`meaning, scope, and relevancy of this Request.
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`REQUEST FOR PRODUCTION NO. 8:
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`Charts of accounts sufficient to identify each type of revenue and expense you and
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`entities related to you track for the Accused Products.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 8:
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`Google objects to this Request as vague and overly broad. Google objects to this Request
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`to the extent it seeks information or documents protected from discovery by the attorney-client
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`privilege and/or the attorney work-product doctrine, the joint defense privilege, or any other
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`applicable privileges. Google objects to this request as premature in advance of its core technical
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`document production and Plaintiff’s infringement contentions. Google objects to this Request on
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`the grounds that the terms and phrases in this Request are vague and ambiguous, including but
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`not limited to “each type of revenue and expense,” “entities related to you,” and “track.” Google
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`objects to this Request to the extent it seeks information not relevant to any inquiry in this
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`matter.
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`Subject to and without waiving the foregoing general and specific objections, Google
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`responds that it will produce relevant documents responsive to this Request to the extent any
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`exist that are in its possession, custody or control that are not protected from disclosure by any
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`applicable privilege or doctrine to the extent responsive documents can be identified after a
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`reasonable search and in accordance with the Scheduling Order.
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`9
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`Case 1:13-cv-00919-LPS Document 193-2 Filed 12/12/19 Page 11 of 51 PageID #: 6001
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`REQUEST FOR PRODUCTION NO. 9:
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`Documents sufficient to explain any acronyms or terminology used in your financial
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`reporting.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 9:
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`Google objects to this Request as vague and overly broad. Google objects to this Request
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`to the extent it seeks documents that are already in Plaintiff’s possession, custody, or control, or
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`that are publicly available or are as readily available to Plaintiff as they are to Google. Google
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`objects to this Request to the extent it seeks information or documents protected from discovery
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`by the attorney-client privilege and/or the attorney work-product doctrine, the joint defense
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`privilege, or any other applicable privileges. Google objects to this request as premature in
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`advance of its core technical document production and Plaintiff’s infringement contentions.
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`Google objects to this Request on the grounds that the terms and phrases in this Request are
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`vague and ambiguous, including but not limited to “terminology,” and “financial reporting.”
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`Google objects to this Request to the extent it seeks information not relevant to any inquiry in
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`this matter.
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`Subject to and without waiving the foregoing general and specific objections, Google
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`responds that it will produce relevant documents responsive to this Request to the extent any
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`exist that are in its possession, custody or control that are not protected from disclosure by any
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`applicable privilege or doctrine to the extent responsive documents can be identified after a
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`reasonable search and in accordance with the Scheduling Order.
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`REQUEST FOR PRODUCTION NO. 10:
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`All documents relating to the pricing of the Accused Products.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 10:
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`Google objects to this Request as vague and overly broad as it requests “all documents
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`relating to.” Google objects to this Request to the extent it seeks information or documents
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`protected from discovery by the attorney-client privilege and/or the attorney work-product
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`doctrine, the joint defense privilege, or any other applicable privileges. Google objects to this
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`10
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`Case 1:13-cv-00919-LPS Document 193-2 Filed 12/12/19 Page 12 of 51 PageID #: 6002
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`request as premature in advance of its core technical document production and Plaintiff’s
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`infringement contentions. Google objects to this Request on the grounds that the terms and
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`phrases in this Request are vague and ambiguous, including but not limited to “pricing.” Google
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`objects to this Request to the extent it seeks information not relevant to any inquiry in this
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`matter.
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`This request exceeds the scope of discovery permitted under FRCP 26(b)(1), seeks
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`information not relevant to any matter at issue in this litigation and/or is not likely to lead to the
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`discovery of admissible evidence. Therefore, Google states that it will not produce documents
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`responsive to this request. Google is willing to meet and confer with Plaintiff to discuss the
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`meaning, scope, and relevancy of this Request.
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`REQUEST FOR PRODUCTION NO. 11:
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`All documents relating to pricing proposals for any of the Accused Products regardless of
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`whether such proposals were implemented, including without limitation proposals that
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`contemplate different prices depending upon the features included.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 11:
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`Google objects to this Request as vague and overly broad as it requests “all documents
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`relating to.” Google objects to this Request to the extent it seeks information or documents
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`protected from discovery by the attorney-client privilege and/or the attorney work-product
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`doctrine, the joint defense privilege, or any other applicable privileges. Google objects to this
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`request as premature in advance of its core technical document production and Plaintiff’s
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`infringement contentions. Google objects to this Request on the grounds that the terms and
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`phrases in this Request are vague and ambiguous, including but not limited to “pricing
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`proposals,” “implemented,” “contemplate,” or “features included.” Google objects to this
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`Request to the extent it seeks information not relevant to any inquiry in this matter.
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`This request exceeds the scope of discovery permitted under FRCP 26(b)(1), seeks
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`information not relevant to any matter at issue in this litigation and/or is not likely to lead to the
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`discovery of admissible evidence. Therefore, Google states that it will not produce documents
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`11
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`Case 1:13-cv-00919-LPS Document 193-2 Filed 12/12/19 Page 13 of 51 PageID #: 6003
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`responsive to this request. Google is willing to meet and confer with Plaintiff to discuss the
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`meaning, scope, and relevancy of this Request.
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`REQUEST FOR PRODUCTION NO. 12:
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`All reports prepared by or for you containing actual, budgeted, or projected financial
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`results for any of the Accused Products, including without limitation profit and loss statements,
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`income statements, and sales reports.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 12:
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`Google objects to this Request as vague and overly broad as it requests “all reports
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`prepared by or for you.” Google objects to this Request to the extent it seeks information or
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`documents protected from discovery by the attorney-client privilege and/or the attorney work-
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`product doctrine, the joint defense privilege, or any other applicable privileges. Google objects
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`to this request as premature in advance of its core technical document production and Plaintiff’s
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`infringement contentions. Google objects to this Request on the grounds that the terms and
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`phrases in this Request are vague and ambiguous, including but not limited to “reports,” “for
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`you,” “financial results,” or “sales reports.” Google objects to this Request to the extent it seeks
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`information not relevant to any inquiry in this matter.
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`Subject to and without waiving the foregoing general and specific objections, Google
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`responds that it will produce relevant documents responsive to this Request to the extent any
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`exist that are in its possession, custody or control that are not protected from disclosure by any
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`applicable privilege or doctrine to the extent responsive documents can be identified after a
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`reasonable search and in accordance with the Scheduling Order.
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`REQUEST FOR PRODUCTION NO. 13:
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`All presentations containing actual, budgeted, or projected financial results for any of the
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`Accused Products.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 13:
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`Google objects to this Request as vague and overly broad as it requests “all
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`presentations.” Google objects to this Request to the extent it seeks information or documents
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`12
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`Case 1:13-cv-00919-LPS Document 193-2 Filed 12/12/19 Page 14 of 51 PageID #: 6004
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`protected from discovery by the attorney-client privilege and/or the attorney work-product
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`doctrine, the joint defense privilege, or any other applicable privileges. Google objects to this
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`request as premature in advance of its core technical document production and Plaintiff’s
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`infringement contentions. Google objects to this Request on the grounds that the terms and
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`phrases in this Request are vague and ambiguous, including but not limited to “presentations,” or
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`“financial results.” Google objects to this Request to the extent it seeks information not relevant
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`to any inquiry in this matter.
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`Subject to and without waiving the foregoing general and specific objections, Google
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`responds that it will produce relevant documents responsive to this Request to the extent any
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`exist that are in its possession, custody or control that are not protected from disclosure by any
`
`applicable privilege or doctrine to the extent responsive documents can be identified after a
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`reasonable search and in accordance with the Scheduling Order.
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`REQUEST FOR PRODUCTION NO. 14:
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`Documents sufficient to identify the entity or entities that assemble each of the Accused
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`Products, including the location(s) where such assembly occurs.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 14:
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`Google objects to this Request as vague and overly broad. Google objects to this Request
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`to the extent it seeks documents that are already in Plaintiff’s possession, custody, or control, or
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`that are publicly available or are as readily available to Plaintiff as they are to Google. Google
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`objects to this Request to the extent it seeks information or documents protected from discovery
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`by the attorney-client privilege and/or the attorney work-product doctrine, the joint defense
`
`privilege, or any other applicable privileges. Google objects to this request as premature in
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`advance of its core technical document production and Plaintiff’s infringement contentions.
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`Google objects to this Request on the grounds that the terms and phrases in this Request are
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`vague and ambiguous, including but not limited to “assemble,” or “assembly.” Google objects to
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`this Request to the extent it seeks information not relevant to any inquiry in this matter.
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`13
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`Case 1:13-cv-00919-LPS Document 193-2 Filed 12/12/19 Page 15 of 51 PageID #: 6005
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`This request exceeds the scope of discovery permitted under FRCP 26(b)(1), seeks
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`information not relevant to any matter at issue in this litigation and/or is not likely to lead to the
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`discovery of admissible evidence. Therefore, Google states that it will not produce documents
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`responsive to this request. Google is willing to meet and confer with Plaintiff to discuss the
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`meaning, scope, and relevancy of this Request.
`
`REQUEST FOR PRODUCTION NO. 15:
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`Documents sufficient to identify on at least a quarterly basis for each of the Accused
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`Products the number of units that were developed, manufactured, assembled, and/or partially
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`assembled in the United States and its territories.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 15:
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`Google objects to this Request as vague and overly broad. Google objects to this Request
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`to the extent it seeks information or documents protected from discovery by the attorney-client
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`privilege and/or the attorney work-product doctrine, the joint defense privilege, or any other
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`applicable privileges. Google objects to this request as premature in advance of its core technical
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`document production and Plaintiff’s infringement contentions. Google objects to this Request on
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`the grounds that the terms and phrases in this Request are vague and ambiguous, including but
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`not limited to “units,” “developed,” “manufactured,” assembled” or “partially assembled.”
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`Google objects to this Request to the extent it seeks information not relevant to any inquiry in
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`this matter.
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`This request exceeds the scope of discovery permitted under FRCP 26(b)(1), seeks
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`information not relevant to any matter at issue in this litigation and/or is not likely to lead to the
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`discovery of admissible evidence. Therefore, Google states that it will not produce documents
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`responsive to this request. Google is willing to meet and confer with Plaintiff to discuss the
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`meaning, scope, and relevancy of this Request.
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`REQUEST FOR PRODUCTION NO. 16:
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`All documents that relate to transfer prices proposed or used for any of the Accused
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`Products.
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`14
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`

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`Case 1:13-cv-00919-LPS Document 193-2 Filed 12/12/19 Page 16 of 51 PageID #: 6006
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 16:
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`Google objects to this Request as vague and overly broad as it requests “all documents.”
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`Google objects to this Request to the extent it seeks information or documents protected from
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`discovery by the attorney-client privilege and/or the attorney work-product doctrine, the joint
`
`defense privilege, or any other applicable privileges. Google objects to this request as premature
`
`in advance of its core technical document production and Plaintiff’s infringement contentions.
`
`Google objects to this Request on the grounds that the terms and phrases in this Request are
`
`vague and ambiguous, including but not limited to “transfer prices.” Google objects to this
`
`Request to the extent it seeks information not relevant to any inquiry in this matter.
`
`This request exceeds the scope of discovery permitted under FRCP 26(b)(1), seeks
`
`information not relevant to any matter at issue in this litigation and/or is not likely to lead to the
`
`discovery of admissible evidence. Therefore, Google states that it will not produce documents
`
`responsive to this request. Google is willing to meet and confer with Plaintiff to discuss the
`
`meaning, scope, and relevancy of this Request.
`
`REQUEST FOR PRODUCTION NO. 17:
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`All documents relating to the features of products offered by your competitors for the
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`Accused Products, including without limitation all documents that compare or contrast the
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`features of the Accused Products and those of products offered by your competitors.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 17:
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`Google objects to this Request as vague and overly broad as it requests “all documents.”
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`Google objects to this Request as vague and overly broad as it requests “features of products”
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`that are not accused. Google objects to this Request to the extent it seeks documents that are
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`already in Plaintiff’s possession, custody, or control, or that are publicly available or are as
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`readily available to Plaintiff as they are to Google. Google objects to this Request to the extent it
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`seeks information or documents protected from discovery by the attorney-client privilege and/or
`
`the attorney work-product doctrine, the joint defense privilege, or any other applicable
`
`privileges. Google objects to this request as premature in advance of its core technical document
`
`15
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`

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`Case 1:13-cv-00919-LPS Document 193-2 Filed 12/12/19 Page 17 of 51 PageID #: 6007
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`production and Plaintiff’s infringement contentions. Google objects to this Request on the
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`groun