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13-07-01 Declaration in Support of Skyhook Motion to Compel

13-07-01 Declaration in Support of Skyhook Motion to Compel

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Published by Florian Mueller
July 1, 2023 declaration (and exhibits) in support of Skyhook's motion to compel in its patent infringement case against Google in the District of Massachusetts (case no. 10-cv-11571)
July 1, 2023 declaration (and exhibits) in support of Skyhook's motion to compel in its patent infringement case against Google in the District of Massachusetts (case no. 10-cv-11571)

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Categories:Types, Business/Law
Published by: Florian Mueller on Jul 02, 2013
Copyright:Attribution Non-commercial

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09/06/2013

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All Documents Relating to the use of Google Location, Google Location Service, Google’s
Network Location Provider, or the Google Wi-Fi Location Database, or any Android Enabled
Mobile Phone or Tablet to estimate an expected error of a position estimate based in whole or in
part on signal strength, estimated geographic location, or signal coverage area.

RESPONSE TO REQUEST FOR PRODUCTION NO. 280:

Google objects to this Request as vague, ambiguous, overly broad, and unduly

burdensome, including without limitation in its use of the terms “Google Location,” “Google

Location Service,” “Google Wi-Fi Location Database,” “Android Enabled Mobile Phone or

Tablet,” and “expected error,” on the grounds that it seeks information that is irrelevant to the

claims and defenses asserted in this action and is not reasonably calculated to lead to the

discovery of admissible evidence, and to the extent that it seeks information concerning products

not accused in this action. Google objects to this Request to the extent that it seeks documents

protected by the attorney-client privilege and/or the work-product doctrine. Google objects to

this Request to the extent that it seeks information that is within Skyhook’s knowledge,

possession, custody or control; that is in the public domain; or that is easily obtainable through

less burdensome means. Google objects to this Request to the extent that it is cumulative or

duplicative of other Requests, and seeks materials previously produced by Google.

Subject to and without waiving the foregoing and all General Objections set forth above

and in Exhibit A, and to the extent Google understands this request, Google has produced or will

produce such representative, non-privileged documents as, after a reasonable and good faith

search, Google determines exist in its possession, custody, or control, if any, that may be

responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted

in Skyhook I—excluding source code as Google has produced all source code responsive to this

Request.

Case 1:10-cv-11571-RWZ Document 196-6 Filed 07/01/13 Page 100 of 145

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