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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 marketing and sales Documents Relating To Google Location, including product literature,
promotional brochures, catalogues, press releases, and advertisements.

RESPONSE TO REQUEST FOR PRODUCTION NO. 202:

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

burdensome, including without limitation in its use of the term “Google Location,” and on the

grounds that it seeks information that is irrelevant to the claims and defenses asserted in this

Case 1:10-cv-11571-RWZ Document 196-6 Filed 07/01/13 Page 28 of 145

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action and is not reasonably calculated to lead to the discovery of admissible evidence. 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, including

without limitation Request No. 26, and seeks materials previously produced by Google. Google

incorporates herein its Response to Request No. 26.

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 states that it has

produced such non-privileged documents as exist in its possession, custody, or control, as have

been located after a reasonable and good faith search that are responsive to this Request.

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