Case 1:18-cv-01363-CFC Document 39 Filed 11/27/18 Page 1 of 16 PageID #: 1222
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`IN THE UNITED STA TES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`GENENTECH, INC. and CITY OF HOPE,
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`Plaintiffs,
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`v.
`
`C.A. No. 18-1363-CFC
`
`SAMSUNG BIOEPIS CO., LTD.
`
`Defendant.
`
`[PROPOSED] ORDER FOR DISCOVERY,
`INCLUDING DISCOVERY OF ELECTRONICALLY STORED INFORMATION
`("ESI'')
`
`After conferring on these matters, the Parties hereby stipulate to the following protocol
`
`for electronic discovery:
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`1.
`
`General Provisions
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`a.
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`Non-ESI. The Parties agree that nothing in this Order changes the Parties'
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`obligations under the Federal Rules of Civil Procedure to search for, collect, and produce non(cid:173)
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`ESI information. Such non-ESI information, including but not limited to paper, will be produced
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`in electronic form, rendered text searchable via OCR or other means by the Producing Party, and
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`include any file folders and/or labels.
`
`b.
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`Cooperation. Parties are expected to reach agreements cooperatively on how to
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`conduct discovery under Fed. R. Civ. P. 26-36. The Parties shall promptly meet and confer as
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`frequently as appropriate to negotiate in good faith to resolve any disputes that arise under this
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`Document Production Protocol.
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`RLFI 20333394v.l
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`

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`Case 1:18-cv-01363-CFC Document 39 Filed 11/27/18 Page 2 of 16 PageID #: 1223
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`c.
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`Proportionality. Parties are expected to use reasonable, good faith and
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`proportional efforts to preserve, identify and produce relevant information. 1 This includes
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`identifying appropriate limits to discovery, including limits on custodians, identification of
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`relevant subject matter, time periods for discovery and other parameters to limit and guide
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`preservation and discovery issues.
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`d.
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`Preservation of Discoverable Information. A party has a common law
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`obligation to take reasonable and proportional steps to preserve discoverable information in the
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`party's possession, custody or control.
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`(i)
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`Absent a showing of good cause by the Requesting Party, the Parties shall
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`not be required to modify, on a going-forward basis, the procedures used by them in the ordinary
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`course of business to back up and archive data; provided, however, that the Parties shall preserve
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`the non-duplicative discoverable information currently in their possession, custody or control.
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`(ii)
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`Absent a showing of good cause by the Requesting Party, the categories of
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`ESI identified in Schedule A attached hereto need not be preserved.
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`e.
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`Privilege.
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`(i)
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`The Parties are to confer on the nature and scope of privilege logs for the
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`case, including whether categories of information may be excluded from any logging
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`requirements and whether alternatives to document-by-document logs can be exchanged.
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`(ii) With respect to information generated after July 31, 2017, Parties are not
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`required to include any such information in privilege logs.
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`1 Information can originate in any form, including ESI and paper, and is not limited to
`information created or stored electronically.
`
`-2-
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`RLFl 20333394v.1
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`

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`Case 1:18-cv-01363-CFC Document 39 Filed 11/27/18 Page 3 of 16 PageID #: 1224
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`(iii)
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`The Parties will exchange privilege logs no later than 30 days after the
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`substantial completion of document production.
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`(iv) With respect to information generated at the direction of Trial Counsei2 or
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`communications with Trial Counsel, parties are not required to include any such information or
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`communications in privilege logs.
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`(v)
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`Activities undertaken in compliance with the duty to preserve information
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`are protected from disclosure and discovery under Fed. R. Civ. P. 26(b)(3)(A) and (B).
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`(vi)
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`The Parties shall confer on an appropriate non-waiver order under Fed. R.
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`Evid. 502. Until a non-waiver order is entered, information that contains privileged matter or
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`attorney work product shall be immediately returned if such information appears on its face to
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`have been inadvertently produced or if notice is provided within 30 days of inadvertent
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`production.
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`2.
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`Initial Discovery Conference. On October 16, 2018, the Court conducted a scheduling
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`conference pursuant to Fed. R. Civ. P. 16 and Local Rule 16.l(b). Counsel for the Parties
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`participated in the scheduling conference, and the Court subsequently entered a Scheduling
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`Order dated October 31, 2018 (D.I. 26).
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`3.
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`Notice. The Parties shall make a good faith effort to identify in a timely fashion any
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`issues that the parties become aware of relating to: (i) any ESI (by type, date, custodian,
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`electronic system or other criteria) that a party asserts is not reasonably accessible under Fed. R.
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`Civ. P. 26(b)(2)(C)(i); (ii) third-party discovery under Fed. R. Civ. P. 45 and otherwise,
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`including the timing and sequencing of such discovery; or (iii) production of information subject
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`2 "Trial Counsel" means Wilmer Cutler Pickering Hale & Dorr LLP, Durie Tangri LLP, White &
`Case LLP, and Potter Anderson & Corroon LLP.
`- 3 -
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`RLFl 20333394v.1
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`

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`Case 1:18-cv-01363-CFC Document 39 Filed 11/27/18 Page 4 of 16 PageID #: 1225
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`to privacy protections, including information that may need to be produced from outside of the
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`United States and subject to foreign laws.
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`4.
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`Initial Discovery in Patent Litigation.
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`a.
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`Given the Parties' exchanges under the BPCIA, the Parties shall forgo the initial
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`discovery in patent litigation provided under Delaware Default Discovery Standard Rule 4. Any
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`final supplementation of contentions shall occur by the close of fact discovery.
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`5.
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`Specific E-Discovery Issues.
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`a.
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`On-site inspection of electronic media. Such an inspection shall not be
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`permitted absent a demonstration by the Requesting Party of specific need and good cause.
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`b.
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`ESI Search methodology.
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`(i)
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`Search terms. If the producing party elects to use search terms to locate
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`potentially responsive ESI, it shall disclose the search terms to the
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`requesting party. Absent a showing of good cause, a requesting party may
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`request no more than five ( 5) additional terms in total to be used in
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`connection with the electronic search(es) of the producing party's
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`custodial data, with such additional terms to be provided within seven (7)
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`days of receipt of the producing party's disclosure of search terms. The
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`Parties will undertake their best efforts to meet the substantial completion
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`of document production deadline, but acknowledge that providing
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`additional search terms after receipt of the Producing Party's disclosure of
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`search terms may affect a Party's ability to meet this deadline. The search
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`terms proposed by the requesting party shall be narrowly tailored to the
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`-4-
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`RLFI 20333394v. l
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`

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`Case 1:18-cv-01363-CFC Document 39 Filed 11/27/18 Page 5 of 16 PageID #: 1226
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`particular issues in the case. Focused terms, rather than over-broad terms
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`( e.g., product and company names), shall be employed. The parties
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`acknowledge that there may be certain instances where the volume of ESI
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`is particularly high. The parties agree that in the event of a claim that a
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`particular search term or combination of terms is too burdensome, the
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`parties will exchange information showing the number of "hits" for each
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`such terrri or combination of terms, and agree to work in good faith to
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`resolve such issues on a case-by-case basis. The parties shall meet and
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`confer on any modifications to the requesting parties' proposed terms
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`(including with respect to translation issues) needed to improve their
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`efficacy in locating discoverable information and in excluding information
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`that is not proportional to the needs of the case under Fed. R. Civ. P.
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`26(b), including modifying terms where the burden or expense of the
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`proposed terms outweighs the likely benefit. The Parties shall promptly
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`cooperate to test proposed search terms prior to committing to their use.
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`Indiscriminate terms, such as the producing company's name, are
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`inappropriate unless combined with narrowing search criteria that
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`sufficiently reduce the risk of overinclusion. A conjunctive combination
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`of multiple words or phrases (e.g., "computer" and "system") narrows the
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`search and shall count as a single search term. A disjunctive combination
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`of multiple words or phrases (e.g., "computer" or "system") broadens the
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`search, and thus each word or phrase shall count as a separate search term
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`-5-
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`RLFI 20333394v.l
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`

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`Case 1:18-cv-01363-CFC Document 39 Filed 11/27/18 Page 6 of 16 PageID #: 1227
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`unless they are variants of the same word. Unless otherwise agreed-to by
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`the parties, the producing party need only search (i) the non-custodial data
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`sources identified in accordance with paragraph 5(b)(ii); and (ii) emails
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`and other ESI maintained by the custodian in accordance with paragraph
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`5(b)(ii).
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`(ii)
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`Custodians and non-custodial data sources. In addition to the inventors
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`of the Asserted Patents, by November 30, 2018, Plaintiffs shall identify
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`the 5 non-inventor custodians most likely to have potentially responsive
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`information in their possession, custody or control. By November 30,
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`2018, Defendants shall identify the 10 custodians most likely to have
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`potentially responsive information in their possession, custody or control.
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`The custodians shall be identified by name, title, role in the instant
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`dispute, and a brief description of the nature of information expected to be
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`located in the custodian's ESI. The parties shall search the emails and
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`other ESI of their respective custodians. Email and ESI of the inventors of
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`the Asserted Patents need only be searched through the issue dates of the
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`respective Asserted Patents. The Parties shall also make a good faith
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`effort to identify and search non-custodial data sources3 likely to contain
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`non-duplicative responsive information. Each Producing Party shall
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`provide a list of the non-custodial data sources that such Producing Party
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`3 That is, a system or container that stores ESI, but over which an individual custodian does not
`organize, manage or maintain the ESI in the system or container (e.g., enterprise system or
`database).
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`-6-
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`RLFI 20333394v.l
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`

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`Case 1:18-cv-01363-CFC Document 39 Filed 11/27/18 Page 7 of 16 PageID #: 1228
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`represents are most likely to contain non-duplicative discoverable
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`information for preservation and production consideration, along with a
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`brief description of the nature of information expected to be located within
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`such sources, by November 30, 2018.
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`c.
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`Format. ESI and non-ESI shall be produced to the Requesting Party as text
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`searchable image files in black-and-white format, except as provided in Sections 5.d-e. When a
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`text-searchable image file is produced, the Producing Party must preserve the integrity of the
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`underlying ESI, i.e., the original formatting and metadata, to the extent such metadata exists (see
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`infra Section 5.h). The Parties shall produce their information in the following format: single
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`page TIFF images and associated multipage text files containing extracted text or OCR with
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`Concordance and Opticon load files containing all requisite information including relevant
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`metadata.
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`d.
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`Native files. The only files that should be produced in native format are files not
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`easily converted to image format, such as Excel and Access files, or files that lack utility when
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`converted to image format, such as structural data (e.g., .pdb files) or DNA sequence
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`chromatograms (e.g., .abi files). A Receiving Party may request that a file be produced in native
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`format, and if that request imposes an unreasonable or undue burden on the Producing Party, the
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`Producing Party shall notify the Receiving Party of the objection and the parties shall meet and
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`confer about the issue.
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`e.
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`Appearance and Content. Subject to any necessary redaction, each Document's
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`TIFF image file shall contain the same information and same physica, representation as the
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`Document did in its original format, whether paper or electronic, consistent with the processing
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`-7-
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`RLFI 20333394v. l
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`

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`Case 1:18-cv-01363-CFC Document 39 Filed 11/27/18 Page 8 of 16 PageID #: 1229
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`specifications set forth in Paragraph c. If a produced Document presents imaging or formatting
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`problems that the Producing Party was not able to resolve at the time of production, the
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`Receiving Party, upon discovery, may request a replacement copy from the Producing Party of
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`the problematic Document and such requests shall not be unreasonably denied and shall be
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`promptly satisfied.
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`f.
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`Color. The parties agree to produce TIFFs in black-and-white format, except
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`that (a) documents that are illegible in black-and-white shall be reproduced in color upon request
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`and (b) a Producing Party that intends to rely upon a color version of the document in any filing,
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`discovery response, deposition, or trial must produce the document in color as a single page
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`TIFF image, PDF, JPEG, or native file (at the producing party's discretion). In addition, a
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`Receiving Party may make reasonable, good faith, and proportional requests for color versions of
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`documents by notifying the Producing Party of the Bates number of the documents that it
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`reasonably anticipates may be needed for filing, discovery response, deposition, or trial, or that it
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`contends is illegible in black-and-white. In response to reasonable, good faith, and proportional
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`requests, a producing party shall produce the requested color documents as a single page TIFF
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`image, JPEG, or native file (at the producing party's discretion) within five (5) business days of
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`the request or within a timeframe that is mutually agreeable to the parties.
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`g.
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`Document Numbering and Confidentiality Designation for TIFF Images.
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`Each page of a Document produced in TIFF file format shall have a legible, unique numeric
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`identifier ("Document Number;" a/k/a Bates number) not less than eight (8) digits electronically
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`"burned" onto the image at a place on the Document that does not obscure, conceal or interfere
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`with any information originally appearing on the Document. The Document Number for each
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`- 8 -
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`RLFI 20333394v.l
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`

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`Case 1:18-cv-01363-CFC Document 39 Filed 11/27/18 Page 9 of 16 PageID #: 1230
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`Document shall be created so as to identify the Producing Party and the Document Number ( e.g.,
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`"AMGKAN00000000"). Each Plaintiff and Defendant shall have a unique identifying name.
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`The confidentiality designation, if any, should also be electronically "burned" onto the image at a
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`place on the Document that does not obscure, conceal, or interfere with any information
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`originally appearing on the document.
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`h.
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`Metadata fields. The Parties are obligated to provide the following metadata for
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`all ESI produced ( or the equivalent thereof), to the extent such metadata exists: Custodian, File
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`Path, Email subject, Conversation Index, From, To, CC, BCC, Date Sent, Time Sent, Date
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`Received, Time Received, Filename, File Extension, Author, Date Created, Date Last Modified,
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`MD5 Hash or SHA Hash, File Size, File Extension, Control Number Begin, Control Number
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`End, Attachment Range, Attachment Begin, Attachment End, Redaction, Confidentiality, and
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`Basis for Withholding.
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`i.
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`Redactions. The Producing Party may redact, from any TIFF image, metadata
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`field, and/or native file, information that is protected from disclosure by any applicable privilege
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`or immunity law or regulation, including but not limited to information protected by attorney(cid:173)
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`client privilege, work product doctrine, joint defense work product doctrine, individually
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`identifiable health information, personal identifying information, or confidential information that
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`does not relate to trastuzumab, any biosimilar version oftrastuzumab, or the patents-in-suit and
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`that is otherwise non-responsive to a discovery request.
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`j.
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`Production Rules. Due to the contextual relationship of electronic documents,
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`the Parties will maintain family relationships for electronic data. If any document in a document
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`family is responsive (e.g., an attachment to an email), the cover email in the family shall be
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`-9-
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`RLFI 20333394v. I
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`

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`Case 1:18-cv-01363-CFC Document 39 Filed 11/27/18 Page 10 of 16 PageID #: 1231
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`produced without regard to whether it is independently responsive (subject to the redaction
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`provisions of 5.g), but nonresponsive attachments in the family need not be produced. The
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`Parties will make relevancy and production determinations for hard copy documents at the
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`document level.
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`k.
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`Corrupt or Inaccessible Files. Certain files may be inaccessible due to
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`password protection, corruption, or unreadable document formats. If reasonable efforts to obtain
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`useful TIFF images or accessible native versions of these files are unsuccessful, such documents
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`may be withheld.
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`I.
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`De-duplication. To the extent identical copies of Documents (i.e., Documents
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`with identical hash values) appear in the files produced in this case, the Producing Party need
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`only produce one such identical copy for that source. De-duplication may be done across
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`custodians provided, however, that the name of each custodian who had the Document being de(cid:173)
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`duped shall be provided in the "Duplicate Custodian" metadata field, as known at the time of
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`production of that record. Email and their attachments shall be treated as a single file for
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`purposes of de-duplication. The Custodian field shall be supplemented on a timely basis when
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`additional duplicates are identified and not produced. The parties may de-duplicate stand-alone
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`documents against stand-alone documents and may de-duplicate top-level email documents
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`against top-level email documents using the calculated hash of the native produced file (e.g.
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`MD5 Hash Code or SHA-1). Electronic files will be de-duplicated based upon the calculated
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`hash values for binary file content (e.g. MD5 Hash Code or SHA-1). File contents will only be
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`used for hash value calculation and will not include operating system metadata values.
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`m.
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`Parent-Child Relationships. Parent-child relationships (the association between
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`- 10 -
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`RLFI 20333394v.l
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`

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`Case 1:18-cv-01363-CFC Document 39 Filed 11/27/18 Page 11 of 16 PageID #: 1232
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`an attachment and its parent document) shall be preserved and reflected in the ProdBegAttach /
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`ProdEndAttach metadata fields. Original document orientation shall be maintained (i.e., portrait
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`to portrait and landscape to landscape).
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`n.
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`Third-Party Software. To the extent that Documents produced pursuant to this
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`Document Production Protocol cannot be rendered or viewed without the use of proprietary non(cid:173)
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`commercially available third-party software or software developed by the Parties, the Parties
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`shall meet and confer to minimize any expense or burden associated with the production of such
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`Documents in an acceptable format and review of the Documents by the Receiving Party,
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`including issues as may arise with respect to obtaining access to any such software and operating
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`manuals which are the property of a third party or the Parties.
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`o.
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`Processing Specifications. The Producing Party shall use the following
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`specifications when converting ESI from its Native Format into TIFF image files prior to its
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`production:
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`(i)
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`Tracked changes, author comments, hidden columns and hidden rows
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`shall be turned "on" before production.
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`(ii)
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`Presenter notes will be made visible and Microsoft PowerPoint files shall
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`be produced in notes view.
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`(iii) Compressed Files. Compression file types (i.e., .CAB, .GZ, .TAR, .Z,
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`.ZIP) shall be decompressed in a reiterative manner to ensure that a zip
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`within a zip is decompressed into the lowest possible compression
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`resulting in individual folders and/or files.
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`p.
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`Manner of Service:
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`- 11 -
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`RLFI 20333394v.l
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`

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`Case 1:18-cv-01363-CFC Document 39 Filed 11/27/18 Page 12 of 16 PageID #: 1233
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`(i)
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`Pursuant to Fed. R. Civ. P. 5(b)(2)(E), all discovery requests shall be
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`served by Email in .pdfformat accompanied by a Word version for use by
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`the Receiving Party.
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`(ii)
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`All responses and objections thereto (but not necessarily Documents
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`produced pursuant to any such request) shall be served by Email in a
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`searchable .pdf format.
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`(iii) All discovery requests, responses, and objections served by Email shall
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`constitute timely service on that day.
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`(iv) All produced Documents shall be served either by .ftp site or by hand
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`delivery or by Federal Express (or similar means) for next day delivery.
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`When serving produced Documents by hand delivery or next day delivery,
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`such delivery shall be made on electronic media with encryption or other
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`similar means of security. Where service is made by next day delivery,
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`service shall be effective on the day sent.
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`(v)
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`For service of discovery requests, discovery responses and objections, and
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`Documents by .ftp, the parties designate the following counsel to receive
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`ftp instructions and passwords at the Email addresses identified below.
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`For hand delivery or overnight delivery of Documents, the parties
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`designate the following counsel to receive the Documents at the addresses
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`identified below with a copy of production cover letters to be sent to the
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`Email addresses identified below.
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`- 12 -
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`RLFI 20333394v.l
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`

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`Case 1:18-cv-01363-CFC Document 39 Filed 11/27/18 Page 13 of 16 PageID #: 1234
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`Party
`
`Gen en tech
`
`Samsung Bioepis
`
`Service by E-mail
`
`Service by Hand/Overnight
`Mail
`WHGNE-
`Anita Gulino
`SamsungHerce12tinServiceLis Wilmer Hale
`t@wilmerhale.com
`60 State St.
`Boston, MA 02109
`Dimitrios Drivas
`Amit Thakore
`( ddrivas@whitecase.com)
`White & Case LLP
`1221 A venue of the Americas
`Scott W eingaertner
`( scott. weingaertner@whiteca New York, NY 10020
`se.com)
`Amit Thakore
`( athakore@whitecase.com)
`Holly Tao
`<hollv .taotmwhitecase.com)
`
`6.
`
`Miscellaneous Provisions
`
`a.
`
`Original Documents. Nothing in this Document Production Protocol shall
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`eliminate or alter any Party's obligation to retain: (1) Documents in Native Format, including
`
`associated metadata, of all ESI produced in the Litigation pursuant to Paragraph C; and (2)
`
`original hard copy Documents for all Paper Discovery produced in the Litigation pursuant to
`
`Paragraph C.2.
`
`b.
`
`City of Hope. Notwithstanding anything to the contrary herein, except upon a
`
`showing of good cause, City of Hope shall not be obligated to produce documents in this
`
`litigation, except for documents previously produced in one or more litigations relating to U.S.
`
`Patent No. 6,331,415 and/or U.S. Patent No. 7,923,221.
`
`c.
`
`Modification. This Document Production Protocol may be modified by a
`
`Stipulated Order of the Parties or by the Court for good cause shown.
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`- 13 -
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`RLFI 20333394v.l
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`

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`Case 1:18-cv-01363-CFC Document 39 Filed 11/27/18 Page 14 of 16 PageID #: 1235
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`1.
`
`2.
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`3.
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`4.
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`5.
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`6.
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`7.
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`8.
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`9.
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`10.
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`11.
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`12.
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`SCHEDULE A
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`Deleted, slack, fragmented, or other data only accessible by forensics.
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`Random access memory (RAM), temporary files, or other ephemeral data that are
`difficult to preserve without disabling the operating system.
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`On-line access data such as temporary internet files, history, cache, cookies, and the like.
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`Data in metadata fields that are frequently updated automatically, such as last-opened
`dates.
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`Back-up data that are substantially duplicative of data that are more accessible elsewhere.
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`Voice messages.
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`Instant messages that are not ordinarily printed or maintained in a server dedicated to
`instant messaging.
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`Electronic mail or pin-to-pin messages sent to or from mobile devices (e.g., iPhone and
`Blackberry devices), provided that a copy of such mail is routinely saved elsewhere.
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`Other electronic data stored on a mobile device, such as calendar or contact data or notes,
`provided that a copy of such information is routinely saved elsewhere.
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`Logs of calls made from mobile devices.
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`Server, system or network logs.
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`Electronic data temporarily stored by laboratory equipment or attached electronic
`equipment, provided that such data is not ordinarily preserved as part of a laboratory
`report.
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`13.
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`Data remaining from systems no longer in use that is unintelligible on the systems in use.
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`- 14 -
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`RLFl 20333394v.1
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`Case 1:18-cv-01363-CFC Document 39 Filed 11/27/18 Page 15 of 16 PageID #: 1236
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`IT IS SO STIPULATED, through Counsel of Record.
`
`Isl Frederick L. Cottrell, Ill
`Frederick L. Cottrell, III (#2555)
`Jason J. Rawnsley (#5379)
`Alexandra M. Ewing (#6407)
`Richards, Layton & Finger, P.A.
`920 North King Street
`Wilmington, DE 19801
`(302) 651-7700
`cottrell@rlf.com
`rawnsley@rlf.com
`ewing@rlf.com
`
`Isl David E. Moore
`David E. Moore (#3983)
`Bindu Palapura (#5370)
`POTTER ANDERSON & CORROON LLP
`Hercules Plaza, 6th Floor
`1313 North Market Street
`P.O. Box 951
`Wilmington, DE 19801
`(302) 984-6000
`dmoore@potteranderson.com
`bpalapura@potteranderson.com
`
`OF COUNSEL:
`
`OF COUNSEL:
`
`William F. Lee
`Lisa J. Pirozzolo
`Emily R. Whelan
`Kevin S. Prussia
`Andrew J. Danford
`Timothy Cook
`Stephanie Neely
`Wilmer Cutler Pickering
`Hale and Dorr LLP
`60 State Street
`Boston, MA 02109
`(627) 526-6000
`william.lee@wilmerhale.com
`lisa.pirozzolo@wilmerhale.com
`emily. whelan@wilmerhale.com
`kevin.prussia@wilmerhale.com
`an drew.danford@wilmerhale.com
`tim.cook@wilmerhale.com
`
`Robert J. Gunther Jr.
`Wilmer Cutler Pickering
`Hale and Dorr LLP
`7 World Trade Center
`250 Greenwich Street
`New York, NY 10007
`(212) 230-8800
`robert.gunther@wilmerhale.com
`
`RLFI 20333394v.l
`
`Dimitrios T. Drivas
`Scott T. Weingaertner
`Amit H. Thakore
`Holly Tao
`WHITE & CASE LLP
`1221 A venue of the Americas
`New York, NY l 0020
`Tel: (212) 819-8200
`
`Attorneys for Defendant Samsung Bioepis
`Co., Ltd.
`
`- 15 -
`
`

`

`Case 1:18-cv-01363-CFC Document 39 Filed 11/27/18 Page 16 of 16 PageID #: 1237
`
`Daralyn J. Durie
`Adam R. Brausa
`Durie Tangri LLP
`217 Leidesdorff St.
`San Francisco, CA 94111
`( 415) 362-6666
`ddurie@durietangri.com
`abrausa@durietangri.com
`
`Attorneys for Plaintiffs
`Genentech, Inc. and City of Hope
`
`IT IS SO ORDERED this 2:,.f>Jay of tJ; ,e,...,tr
`
`Agreement is approved.
`
`, that the foregoing
`
`- 16 -
`
`RLFI 20333394v.1
`
`