Exhibit H
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IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

WACO DIVISION 

UNIFICATION TECHNOLOGIES LLC, ) 

 ) 

 Plaintiff, ) Civil Action No. 6:20-cv-500-ADA

v. ) 

 ) 

MICRON TECHNOLOGY, INC., MICRON ) 

SEMICONDUCTOR PRODUCTS, INC, AND ) 

MICRON TECHNOLOGY TEXAS, LLC, )

 )

 Defendants. ) 

 ) 

NON-PARTY PHISON TECHNOLOGY INC.’S OBJECTIONS AND 

RESPONSES TO PLAINTIFFS’ REQUESTS FOR PRODUCTION OF DOCUMENTS

Pursuant to Rule 45 of the Federal Rules of Civil Procedure (the “Federal Rules”), nonparty Phison Technology Inc. (“PTI”) hereby responds and objects to the Subpoena dated July 

27, 2021 (the “Subpoena”), served upon it by Unification Technologies LLC (“Plaintiff”), as 

follows: 

GENERAL OBJECTIONS 

As a threshold matter, PTI objects to Plaintiffs’ requests to the extent that they exceed the 

Court’s subpoena jurisdiction over PTI, a non-resident non-party that resides more than 100 

miles away from the Court. By responding to these requests, PTI preserves and does not waive 

any objections it has to the Court’s subpoena jurisdiction and the propriety of the requests being 

imposed on a non-party to the litigation.

PTI objects to Plaintiff’s requests to the extent they seek information that is equally in the 

possession, custody, or control of a party to this litigation. It is unduly burdensome and 

oppressive for a non-party such as PTI to incur the expense of responding to requests to seek 

information available through party discovery. 
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PTI objects to Plaintiff’s requests to the extent they seek disclosure of proprietary and/or 

confidential information of PTI, including, without limitation, its trade secrets and other 

intellectual property rights.

PTI objects to Plaintiff’s requests to the extent they require information from person or 

companies in which PTI does not have a controlling interest.

PTI objects to Plaintiff’s requests to the extent they seek disclosure of information 

protected under the attorney-client privilege, the work product doctrine, or any other applicable 

privilege or immunity.

PTI objects to Plaintiff’s requests to the extent they are overly broad, unduly 

burdensome, harassing, and/or oppressive to PTI, a non-party to this litigation. 

PTI objects to Plaintiff’s requests to the extent they seek information that is neither 

relevant to the subject matter of this action nor reasonably calculated to lead to the discovery of 

admissible evidence. 

PTI objects to the requests to the extent they are vague, ambiguous, do not describe the 

information sought with reasonable particularity, or otherwise require PTI to speculate as to the 

documents sought. 

PTI objects to the requests to the extent they purport to alter or place any obligations on 

PTI that are greater than those permitted by the Federal Rule of Civil Procedure or any other 

applicable rule or law.

The objections set forth are incorporated in each response below and shall be deemed to 

be continuing even if not specifically referred to in responses to individual requests. For 

particular emphasis, one or more of these General Objections may be reiterated in a specific 

response. The absence of any reiteration in a given specific response is neither intended as, nor 

shall be construed as, a limitation or waiver of any General Objection made herein. Moreover, 

the inclusion of a specific objection to a specific response is neither intended as, nor shall be 

construed as, a limitation or waiver of a General Objection or any other specific objection. 
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Any responses to these requests are made without waiver of, or prejudice to, any 

objections PTI may raise now or in the future and all such objections are hereby expressly 

preserved. PTI further reserves the right to make any motion or application to the Court to 

preserve its rights, as a non-party, from being required to respond to burdensome discovery in 

this action, in which it is a non-party.

The following responses are based on information known to PTI at this time and are 

provided without prejudice to PTI’s right to produce subsequently discovered evidence and facts, 

and to add, modify, or otherwise change or amend these responses. While PTI reserves the right 

to supplement, amend, or modify its responses, it undertakes no obligation to do so except as 

required by the Federal Rules of Civil Procedure. 

RESPONSE TO REQUESTS FOR PRODUCTION 

DOCUMENT REQUEST NO. 1:

 All source code used by the controller You provide to Micron for use in solid 

state drives (“SSD”), including, but not limited to, Micron’s P2 Series SSDs. 

RESPONSE TO DOCUMENT REQUEST NO. 1:

PTI incorporates the foregoing General Objections by reference. PTI further objects to 

this request to the extent it requires PTI to produce its trade secrets and other proprietary and 

confidential information. After diligent search and a reasonable inquiry has been made in an 

effort to comply with this Request, there are no responsive documents within PTI’s possession, 

custody, or control. 

DOCUMENT REQUEST NO. 2:

Documents sufficient to show how the controllers You provide to Micron implement the 

TRIM command. 

RESPONSE TO DOCUMENT REQUEST NO. 2:

PTI incorporates the foregoing General Objections by reference. PTI further objects to 

this request to the extent it requires PTI to produce its trade secrets and other proprietary and 
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confidential information. After diligent search and a reasonable inquiry has been made in an 

effort to comply with this Request, there are no responsive documents within PTI’s possession, 

custody, or control.

DOCUMENT REQUEST NO. 3:

Documents sufficient to show how the controller You provide to Micron implement the 

DEALLOCATE command.

RESPONSE TO DOCUMENT REQUEST NO. 3:

PTI incorporates the foregoing General Objections by reference. PTI further objects to 

this request to the extent it requires PTI to produce its trade secrets and other proprietary and 

confidential information. After diligent search and a reasonable inquiry has been made in an 

effort to comply with this Request, there are no responsive documents within PTI’s possession, 

custody, or control. 

DOCUMENT REQUEST NO. 4:

All correspondence with Micron related to the patent-in-suit. 

RESPONSE TO DOCUMENT REQUEST NO. 4:

PTI incorporates the foregoing General Objections by reference. PTI further objects to 

this request to the extent it requires PTI to produce its trade secrets and other proprietary and 

confidential information. PTI further objects to Plaintiff’s request to the extent it seeks

information that is equally in the possession, custody, or control of a party to this litigation. After 

diligent search and a reasonable inquiry has been made in an effort to comply with this Request, 

there are no responsive documents within PTI’s possession, custody, or control. 

DOCUMENT REQUEST NO. 5:

All correspondence with Micron related to the Litigation. 

RESPONSE TO DOCUMENT REQUEST NO. 5: 

PTI incorporates the foregoing General Objections by reference. PTI further objects to 

this request to the extent it requires PTI to produce its trade secrets and other proprietary and 
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confidential information. PTI further objects to Plaintiff’s request to the extent they seek 

disclosure of information protected under the attorney-client privilege, the work product 

doctrine, or any other applicable privilege or immunity. PTI objects to Plaintiff’s request to the 

extent it seeks information that is equally in the possession, custody, or control of a party to this 

litigation. After diligent search and a reasonable inquiry has been made in an effort to comply 

with this Request, there are no responsive documents within PTI’s possession, custody, or 

control. 

DOCUMENT REQUEST NO. 6:

Documents sufficient to show the date You first became aware of the patent-in-suit. 

RESPONSE TO DOCUMENT REQUEST NO.6: 

PTI incorporates the foregoing General Objections by reference. PTI first became aware 

of the patent in suit after it received the Subpoena on or about July 29, 2021. Other than the

Subpoena, PTI does not have any responsive documents within its possession, custody, or 

control. 
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DOCUMENT REQUEST NO. 7: 

API and user guides related to the controllers You provide to Micron. 

RESPONSE TO DOCUMENT REQUEST NO. 7: 

PTI incorporates the foregoing General Objections by reference. PTI further objects to 

this request to the extent it requires PTI to produce its trade secrets and other proprietary and 

confidential information. PTI objects to Plaintiff’s request to the extent it seeks information that 

is equally in the possession, custody, or control of a party to this litigation. After diligent search 

and a reasonable inquiry has been made in an effort to comply with this Request, there are no 

responsive documents within PTI’s possession, custody, or control. 

Dated: September 7, 2021 

By: 

Brian Y. Lee, Esq. 

Counsel for Phison Technology Inc. 

303 Twin Dolphin Drive, Suite 600 

Redwood City, CA 94065 

Phone: (650) 251-4200