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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 reports, meeting agendas, meeting minutes and other Documents of management, sales, and
marketing personnel Relating To (1) Google Location, (2) location determination technology, (3)
the Patents-in-Suit or the Related Patents, (4) Skyhook Technology, (5) Skyhook, or (6) this
litigation.

Case 1:10-cv-11571-RWZ Document 196-6 Filed 07/01/13 Page 59 of 145

59

RESPONSE TO REQUEST FOR PRODUCTION NO. 236:

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

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

determination technology,” “Patents-in-Suit,” “Related Patents,” and “Skyhook Technology,” 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, including without

limitation Request No. 68, and seeks materials previously produced by Google. Google

incorporates herein its Response to Request No. 68.

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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