Case 1:23-cv-00758-JLH-SRF Document 143-2 Filed 09/11/24 Page 1 of 10 PageID #: 3285
`Case 1:23-cv-00758-JLH-SRF Document 143-2 Filed 09/11/24 Page 1 of 10 PagelD #: 3285
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`EXHIBIT B
`EXHIBIT B
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`Case 1:23-cv-00758-JLH-SRF Document 143-2 Filed 09/11/24 Page 2 of 10 PageID #: 3286
`Case 2:12-cv-03496-CBM-CW Document 84 Filed 01/02/13 Page 1 of 9 Page ID #:885
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`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF CALIFORNIA
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`NO. CV 12-3496 CBM (FMOx)
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`ORDER Re: DISCOVERY MOTION
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`)))))))))))
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`MARKETLINX, INC.,
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`Plaintiff,
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`v.
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`INDUSTRY ACCESS INCORPORATED,
`et al.,
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`Defendants.
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`The court has reviewed all the briefing filed with respect to plaintiff’s “Motion to Compel as
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`to Defendant Concepts in Data Management Incorporated d/b/a Instanet Solutions” (“Motion” or
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`“Joint Stip.”) and concludes that oral argument is not necessary to resolve this matter. See Fed.
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`R. Civ. P. 78; Local Rule 7-15; Willis v. Pac. Mar. Ass’n, 244 F.3d 675, 684 n. 2 (9th Cir. 2001).
`INTRODUCTION
`MarketLinx (“plaintiff”) is a provider of real estate information technology solutions. (Joint
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`Stip. at 1). One of plaintiff’s products, Document and Transaction Manager, provides “a simple
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`and intuitive platform to allow real estate professional[s], such as realtors, to share and manage
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`real estate documents online.” (Id.). Instanet (“defendant”) offers and sells a product called
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`Transaction Desk, which it describes on its website as “[t]he Complete Transaction Management
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`Solution.” (Id.).
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`On June 23, 2011, plaintiff filed a complaint against defendant, alleging claims of patent
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`infringement involving U.S. Patent No. 7,343,348 (“the ‘348 patent”), which covers plaintiff’s
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`Document and Transaction Manager product. (Joint Stip. at 1). Plaintiff accuses defendant of
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`directly and indirectly infringing the ‘348 patent by using, selling, and offering to sell its Transaction
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`Desk product and by inducing its customers to infringe the ‘348 patent. (Id.).
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`On July 6, 2012, plaintiff served its first set of document requests, as well as a first set of
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`interrogatories, on defendant. (Joint Stip. at 1). On July 26, 2012, plaintiff served a second set
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`of document requests on defendant. (Id.).
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`Defendant responded with objections to plaintiff’s first and second set of discovery requests
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`on August 9, 2012, and August 29, 2012, respectively. (Joint Stip. at 1-2 & 4). The parties’
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`subsequent attempts to resolve their discovery disputes failed. (See id. at 2-3). On December
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`5, 2012, plaintiff filed the instant Motion requesting the court to compel defendant to provide
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`further responses to the discovery requests in dispute. (Id. at 3 & 7).
`DISCUSSION
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`I.
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`STANDARD OF REVIEW.
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`A party can discover any nonprivileged information that is relevant to the claims or defenses
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`of any other party. Fed. R. Civ. P. 26(b)(1). Relevant information does not have to be admissible
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`so long as it appears calculated to lead to the discovery of admissible evidence. Id. “Relevancy
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`is broadly construed, and a request for discovery should be considered relevant if there is any
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`possibility that the information sought may be relevant to the claim or defense of any party. A
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`request for discovery should be allowed unless it is clear that the information sought can have no
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`possible bearing on the claim or defense of a party.” McCormick v. City of Lawrence, Kansas,
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`2005 WL 1606595, at *5 (D. Kan. 2005) (internal citations omitted); see also Surfvivor Media, Inc.
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`v. Survivor Prods., 406 F.3d 625, 635 (9th Cir. 2005) (“Litigants may obtain discovery regarding
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`any matter, not privileged, that is relevant to the claim or defense of any party. Relevant
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`information for purposes of discovery is information reasonably calculated to lead to the discovery
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`of admissible evidence.”) (internal quotation marks and citations omitted). “The party who resists
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`discovery has the burden to show discovery should not be allowed, and has the burden of
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`clarifying, explaining, and supporting its objections.” Superior Commc’ns v. Earhugger, Inc., 257
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`F.R.D. 215, 217 (C.D. Cal. 2009); Keith H. v. Long Beach Unified Sch. Dist., 228 F.R.D. 652, 655-
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`56 (C.D. Cal. 2005); see also Blankenship v. Hearst Corp., 519 F.2d 418, 429 (9th Cir. 1975)
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`(“Under the liberal discovery principles of the Federal Rules defendants were required to carry a
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`heavy burden of showing why discovery was denied.”).
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`II.
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`THE DISPUTED DISCOVERY.
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`As noted above, the burden is on the party who resists discovery to establish why discovery
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`should not be allowed. The resisting party has the burden to clarify, explain and justify its
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`objections. As such, the court will focus its discussion on defendant’s various objections and note
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`the discovery requests to which the objections apply.
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`First, “it is well-settled that all grounds for objection must be stated with specificity.”
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`Ramirez v. County of Los Angeles, 231 F.R.D. 407, 409 (C.D. Cal. 2005); accord Davis v. Fendler,
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`650 F.2d 1154, 1160 (9th Cir. 1981). “One who objects to part of an item or category should
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`specify to which the objection is directed.” 8B Wright & Miller, Federal Practice and Procedure §
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`2213 (3d ed. 2012). Here, many of defendant’s objections are too general to merit consideration
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`and are therefore waived. See Ramirez, 231 F.R.D. at 409; Casson Constr. Co. v. Armco Steel
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`Corp., 91 F.R.D. 376, 379 (D. Kan. 1980); In re Folding Carton Antitrust Litig., 83 F.R.D. 260, 264
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`(N.D. Ill. 1979). The parties can assume that the court has determined that any objection not
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`discussed in this Order has been overruled because it is too general to merit consideration. See
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`Ramirez, 231 F.R.D. at 409 (“Most of defendants’ objections are too general to merit consideration
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`and are therefore waived.”); Allianz Ins. Co. v. Surface Specialities, Inc., 2005 WL 44534, at *2
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`(D. Kan. 2005) (“The familiar litany of general objections, including overly broad, burdensome, or
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`oppressive, will not alone constitute a successful objection to an interrogatory, nor will a general
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`objection fulfill the objecting party’s burden to explain its objections.”).
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`Second, objections that were raised in response to a particular discovery request, but were
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`not argued in the Joint Stipulation, are deemed waived. See Cotracom Commodity Trading Co.
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`v. Seaboard Corp., 189 F.R.D. 655, 662 (D. Kan. 1999) (“When ruling upon a motion to compel,
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`the court generally considers those objections which have been timely asserted and relied upon
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`in response to the motion. It generally deems objections initially raised but not relied upon in
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`response to the motion as abandoned.”). The parties can assume that any objection not
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`discussed in this Order has been overruled because it: (1) was not raised in response to the
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`original discovery request and is therefore waived; or (2) has been waived by not arguing it in the
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`Joint Stipulation. See Ramirez, 231 F.R.D. at 409-10; Cotracom Commodity Trading Co., 189
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`F.R.D. at 662; Allianz Ins. Co., 2005 WL 44534, at *2.
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`Third, defendant agreed to supplement its responses to Request Nos. 2, 3, 16 and 38, and
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`Interrogatory Nos. 4 & 5,1 (see Joint Stip. at 8-11, 16-17 & 23-25) (indicating that it would
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`supplement its responses “[t]o the extent that any [documents] are responsive to th[e]s[e]
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`request[s,]” and/or “as . . . facts[/information] become available”), and defendant indicated that it
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`has fully responded to Request No. 30 and Interrogatory No. 3. (See id. at 14 & 22). Accordingly,
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`to the extent defendant objects to Request Nos. 2, 3, 16, 30 & 38 and Interrogatory Nos. 3, 4 &
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`5, (see id. at 8-11, 14, 16-17 & 22-25), these objections are deemed waived.2 See Capacchione
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`v. Charlotte-Mecklenburg Schools, 182 F.R.D. 486, 492 (W.D.N.C. 1998) (when an objection to
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`a discovery request accompanies an answer to the discovery request, the objection is generally
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`deemed waived); Meese v. Eaton Manufacturing Co., 35 F.R.D. 162, 166 (N.D. Ohio 1964)
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`(same). Further, defendant’s reliance on “an exhaustive demonstration” it provided to plaintiff’s
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`attorneys and representatives as to “how to use the Accused product,” (see, e.g., Joint Stip. at 9-
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`10), is unpersuasive. Defendant has not provided a copy of the demonstration nor is there any
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`indication that the demonstration was recorded. (See Plaintiff’s Supplemental Memorandum in
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` 1 With respect to Request No. 3, defendant’s contention that it “disagrees that customer
`support services referenced by [plaintiff] falls within the scope of the request[,]” (Joint Stip. at 10),
`is unpersuasive. Support logs, manuals, training materials, customer support tickets, and other
`similar documents related to defendant’s “online chat support, email support, and online phone
`support on use of its products[,]” (id. at 10), fall within the category of “[a]ll documents and things
`relating to the use of the Accused Products[.]” (Id. at 9).
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` 2 Moreover, defendant’s objections that “[Request No. 30] is over broad, vague and unduly
`burdensome[,]” (Joint Stip. at 14), are “too general to merit consideration and are therefore
`waived.” Ramirez, 231 F.R.D. at 409 (“Most of defendants’ objections are too general to merit
`consideration and are therefore waived.”); see Roesberg, 85 F.R.D. at 296-97 (the responding
`party “must show specifically how . . . each [request] is . . . overly broad[]”).
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`Support of MarketLinx’s Motion to Compel Defendant Concepts in Data Management Incorporated
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`d/b/a Instanet Solutions (“Plaintiff’s Supp. Memo.”) at 3). Without a printed or recorded version
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`of the demonstration, plaintiff has no evidence relating to how the Accused product has been or
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`can be used.
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`Fourth, defendant objects to Request Nos. 27, 51 & 53 on the ground that these requests
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`are “overly broad” and/or “unduly burdensome[.]” (Joint Stip. at 12 & 19-21). With respect to
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`Request Nos. 51 & 53, which seek information concerning (1) “the volume of the Accused
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`Products that have been sold or offered for sale . . . since June 2005[,]” (id. at 19) (Request No.
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`51); and (2) defendant’s “profits and profit margins . . . since June 2005[,]” (id. at 20) (Request No.
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`53), defendant claims that it “seeks a protective order relieving it of its obligation to produce
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`documents before March 11, 2008[,]” because such “information presumably relate[s] to damages
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`before the issue date of the ‘348 patent, March 11, 2008.” (Id. at 19-21). With respect to Request
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`No. 27, which requests “[t]he source code for . . . each version of the Accused Product since June
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`2005[,]” (id. at 12), defendant asserts that plaintiff “offers no explanation for the request for source
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`code dating back to 2005.” (Id.). However, contrary to defendant’s assertion, the burden is on
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`defendant – the party resisting discovery – to show grounds for failing to provide the requested
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`discovery. See Superior Commc’ns, 257 F.R.D. at 217 (“The party who resists discovery has the
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`burden to show discovery should not be allowed, and has the burden of clarifying, explaining, and
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`supporting its objections.”); Bible v. Rio Properties, Inc., 246 F.R.D. 614, 618 (C.D. Cal. 2007)
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`(same); Sullivan v. Prudential Ins. Co., 233 F.R.D. 573, 575 (C.D. Cal. 2005) (same). The party
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`resisting discovery cannot simply invoke generalized objections; rather, with respect to each of
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`the propounding party’s discovery requests, the responding party
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`must show specifically how, despite the broad and liberal construction
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`afforded the federal discovery rules, each [request] is . . . overly broad,
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`burdensome or oppressive by submitting affidavits or offering evidence
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`revealing the nature of the burden.
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`Roesberg v. Johns-Manville Corp., 85 F.R.D. 292, 296-97 (E.D. Pa. 1980) (internal citations
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`omitted).
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`Here, other than stating in a conclusory manner that information predating the patent issue
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`date of 2008 is “overly broad” and “unduly burdensome[,]” (see Joint Stip. at 12 & 19-21),
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`defendant made no effort to explain how each document request is overly broad or unduly
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`burdensome. (See, generally, id.). Further, courts generally allow discovery to extend to events
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`before the period of actual liability so as to provide context. See, e.g., Owens v. Sprint/United
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`Mgmt. Co., 221 F.R.D. 649, 655 (D. Kan. 2004) (“discovery of information both before and after
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`the liability period . . . may be relevant and/or reasonably calculated to lead to the discovery of
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`admissible evidence and courts commonly extend the scope of discovery to a reasonable number
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`of years both prior to and following such period”); Empire Volkswagen, Inc. v. World-Wide
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`Volkswagen Corp., 95 F.R.D. 398, 399 (S.D.N.Y. 1982) (discovery “routinely goes beyond the
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`statutory period” (i.e., the period within the statute of limitations), and plaintiffs are generally
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`entitled to discovery “for a reasonable period of time antedating the earliest possible date of the
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`actionable wrong”) (internal quotation marks omitted). The cases appear to suggest a
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`presumptive five-year discovery period. See Miller v. Hygrade Food Prods. Corp., 89 F.Supp.2d
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`643, 657 (E.D. Pa. 2000) (collecting cases that establish a presumptive five-year discovery
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`period). In short, defendant’s overbroad and unduly burdensome objections are overruled.
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`Fifth, with respect to Request No. 39, seeking the disclosure of “[a]ll documents and things
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`relating to any testing of the Accused Products[,]” (Joint Stip. at 17), defendant objects that
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`“[plaintiff] has never indicated the relevancy of the requested documents or how the request is
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`reasonably calculated to lead to admissible evidence.” (Id. at 18). Similarly, defendant objects
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`to Request No. 45, which seeks “[a]ll documents and things relating to any license or other
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`agreement regarding the Accused Product[,]” (id.), on the ground that “[defendant] is at a loss as
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`to how ‘other agreements’ such as web hosting agreements or programming agreements identified
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`by [plaintiff], to the extent they exist, would have any bearing on the issues in this case.” (Id. at
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`19). However, as noted above, the burden is on defendant to show that the requested discovery
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`is not relevant to any claims or defenses in this case and/or, at a minimum, not reasonably
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`calculated to lead to the discovery of admissible evidence. See Superior Commc’ns, 257 F.R.D.
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`at 217; Bible, 246 F.R.D. at 618; Sullivan, 233 F.R.D. at 575. In any event, as defendant
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`concedes, “the issue of infringement concerns . . . an analysis of the Accused Product[,]” (Joint
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`Stip. at 18), and information “relating to” the Accused Product is clearly relevant to the claims or
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`defenses in this case and/or, at a minimum, reasonably calculated to lead to the discovery of
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`admissible evidence.3 See Henderson v. Holiday CVS, L.L.C., 269 F.R.D. 682, 685 (S.D. Fla.
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`2010) (“Discovery is not limited to the issues raised by the pleadings because ‘discovery itself is
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`designed to help define and clarify the issues.’”) (internal citations omitted).
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`Sixth, defendant objects to Request No. 28, which seeks “[a] working account on any
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`Accused Product[,]” (Joint Stip. at 13), on the ground that “[g]iving [plaintiff] unfettered access to
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`[defendant]’s system is not justified based on [defendant]’s previous production and demonstration
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`of how the system is used.” (Id.). However, defendant does not claim that Request No. 28 seeks
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`the disclosure of privileged information or information that is not relevant to any of the claims or
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`defenses in this case. See Fed. R. Civ. P. 26(b)(1). Other than stating, in a conclusory manner,
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`that Request No. 28 is “not justified[,]” (Joint Stip. at 13), defendant makes no effort to explain why
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`this discovery request is improper. (See, generally, id.); see Superior Commc’ns, 257 F.R.D. at
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`217; Bible, 246 F.R.D. at 618; Sullivan, 233 F.R.D. at 575. Moreover, as previously noted, see
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`supra at 4-5, defendant’s reliance on its “previous production and demonstration of how the
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`system is used[,]” (see Joint Stip. at 13), is unpersuasive in light of the fact that defendant has not
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`provided a copy of the demonstration nor is there any indication that the demonstration was
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`recorded. (See Plaintiff’s Supp. Memo. at 3). In short, defendant’s objection to Request No. 28
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`is overruled.
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`Seventh, Request No. 37, which seeks the disclosure of “[a]ll documents and things relating
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`to Your competitors[,]” (Joint Stip. at 15), appears to be vague and overbroad on its face. The
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` 3 Moreover, to the extent defendant objects to Request No. 45 on the ground that “the request
`for any ‘other agreement’ regarding the Accused Product is vague and overly broad[,]” (Joint Stip.
`at 19), defendant’s conclusory objections are overruled. See Roesberg, 85 F.R.D. at 296-97 (the
`responding party “must show specifically how . . . each [request] is . . . overly broad[]”); Ramirez,
`231 F.R.D. at 409 (“Most of defendants’ objections are too general to merit consideration and are
`therefore waived.”).
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`Request fails to specify the competitors and/or the products concerned, and the court is unable
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`to discern what information plaintiff seeks to obtain through this request. (See id.).
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`Finally, a party may be required to submit an affidavit “(1) stat[ing] that after diligent search
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`there are no responsive documents in its possession, custody, or control and (2) describ[ing] its
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`efforts to locate the documents responsive to the requests.” Miller v. City of Plymouth, 2010 WL
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`1754028, at *14 (N.D. Ind. 2010); see id. (“The affidavit must fulfill these two requirements for
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`each of the document requests.”) (italics in original); Link v. Taylor, 2009 WL 127660, at *2 (N.D.
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`Ind. 2009) (“[B]ecause the Defendants claim that they have fully responded to [plaintiff]’s request
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`for production of documents, [plaintiff] is at least entitled to a response stating as much.”).
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`Accordingly, the court will order defendant to provide a supplemental response to all of the
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`discovery requests (except Request No. 37 as discussed below) according to the requirements
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`set forth below. In addition, defendant shall produce a privilege log that complies with the court’s
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`requirements set forth below.4
`This Order is not intended for publication. Nor is it intended to be included in or
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`submitted to any online service such as Westlaw or Lexis.
`Based on the foregoing, IT IS ORDERED THAT:
`1. The hearing set for January 9, 2013, is hereby vacated.
`2. Plaintiff’s Motion (Document No. 78) is granted in part and denied in part.
`3. Request for Production No. 37 contained in plaintiff’s Motion is denied.
`4. Request for Production Nos. 2, 3, 16, 27, 28, 30, 38, 39, 45, 51, and 53, and
`Interrogatory Nos. 3, 4, and 5 contained in plaintiff’s Motion are granted.
`5. No later than January 9, 2013, defendant shall – if it has not already done so – serve
`supplemental written responses and, if appropriate, responsive documents to all the discovery
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`requests listed in paragraph 4 above. In responding to the subject discovery requests, defendant
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`shall provide a certification, under penalty of perjury, that: (1) states that all relevant, non-
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`privileged information under its custody and/or control has been provided; (2) describes in detail
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` 4 Defendant may only raise the attorney-client privilege and work-product protection.
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`the efforts made by the responding party to obtain and produce the requested information; and
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`(3) states whether any further responsive information is available.
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`6. For any responsive information that is withheld on the basis of the attorney-client
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`privilege and/or work-product protection, the responding party shall provide a privilege log at the
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`time the response(s) to the subject discovery request(s) is(are) produced (i.e., the deadline set
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`forth above), or within a reasonable time thereafter provided the parties reach an agreement in
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`writing on a new date pursuant to Fed. R. Civ. P. 29 and the new date does not interfere with any
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`of the case-related deadlines (e.g., discovery cutoff, motion cutoff). The privilege log shall comply
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`with Form No. 11:A as set forth in the California Practice Guide: Federal Civil Procedure Before
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`Trial (The Rutter Group 2012). Any document that contains both protected and responsive
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`information shall be redacted to eliminate any reference to attorney-client matters and/or the work-
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`product protection.
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`Dated this 2nd day of January, 2013.
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` /s/
` Fernando M. Olguin
` United States Magistrate Judge
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