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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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Documents sufficient to show the total number of times, by month, for each year from 2007 to
the present, of Android Enabled Mobile Phones or Tablets in the United States that have
accessed Google’s Wi-Fi Location Database.

RESPONSE TO REQUEST FOR PRODUCTION NO. 308:

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

burdensome, including without limitation in its use of the terms “Google’s Wi-Fi Location

Database” and “Android Enabled Mobile Phones or Tablets,” on the grounds that it seeks

Case 1:10-cv-11571-RWZ Document 196-6 Filed 07/01/13 Page 125 of 145

125

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.

Google is willing to meet and confer with Skyhook concerning a reasonable scope for

this Request.

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