Exhibit I
4846-5216-1779

IN THE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

WACO DIVISION 

UNIFICATION TECHNOLOGIES LLC, 

 Plaintiff, 

v. 

MICRON TECHNOLOGY, INC.; MICRON 

SEMICONDUCTOR PRODUCTS, INC.; AND 

MICRON TECHNOLOGY TEXAS LLC, 

 Defendants. 

Civil Action No.: 6:20-cv-500-ADA 

NON-PARTY SILICON MOTION, INC.’S RESPONSES AND OBJECTIONS TO 

SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS OR 

TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION

Pursuant to Rule 45 of the Federal Rules of Civil Procedure, Non-Party Silicon Motion, 

Inc. hereby responds and objects to the Subpoena to Produce Documents served by Plaintiff 

Unification Technologies LLC (“Plaintiff”) (the “Subpoena”) as follows: 

PRELIMINARY STATEMENT 

1. These responses and objections are based on Silicon Motion, Inc.’s interpretation 

and understanding of the Subpoena and its investigation to date, its knowledge, and its belief. 

Silicon Motion, Inc. reserves the right to amend or supplement any portion of its objections and 

responses. 

2. Silicon Motion, Inc.’s responses and objections to the Subpoena are made solely 

for the purpose of and in relation to the above-captioned action (the “Action”) and on the express 

condition that such information shall not be used or disclosed for any other purpose. To the 

extent Silicon Motion, Inc. provides any information or produces any documents in response to 
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the Subpoena, it will do so in accordance with the Stipulated Protective Order dated October 29, 

2020 (Dkt. No. 40). 

3. Silicon Motion, Inc.’s responses and objections are made without waiving or 

intending to waive any objections, privilege, or other protection and shall not be considered a 

waiver of any objections, privilege, or other protection. 

GENERAL OBJECTIONS 

Silicon Motion, Inc. objects to the definitions, instructions, and document requests 

(“Requests”) set forth in Exhibit A to the Subpoena as follows: 

1. Silicon Motion, Inc. objects to the Subpoena in its entirety and to each and every 

individually numbered Request therein as unduly burdensome and oppressive on the grounds that 

Silicon Motion, Inc. is a non-party witness. Silicon Motion, Inc. further objects to the amount of 

notice given as unreasonable, inadequate, unduly burdensome, and oppressive given the broad 

scope of the Subpoena. Silicon Motion, Inc. further objects to this Subpoena because Silicon 

Motion, Inc. does not transact or has never transacted business with any party to this Action, 

including Defendants Micron Technology, Inc., Micron Semiconductor Products, Inc., and 

Micron Technology Texas LLC (collectively, “Micron”). 

2. Silicon Motion, Inc. objects to the deadlines set forth in the Subpoena as unduly 

burdensome and oppressive on the grounds they do not provide adequate time for Silicon Motion, 

Inc. to search for, locate, and produce relevant documents in its possession, custody, or control. 

3. Silicon Motion, Inc. objects to the Subpoena, the “Instructions,” and paragraphs 1 

through 5 of the “Instructions” in particular, to the extent they seek to impose obligations and 

demands upon Silicon Motion, Inc. beyond those contemplated by the Federal Rules of Civil 

Procedure, the applicable Local Rules, or any order or ruling by the Court in this case. 

4. Silicon Motion, Inc. objects to the Subpoena in its entirety and to each and every 

individually numbered Request therein to the extent that it seeks documents or information 

already obtained by Plaintiff or that it can obtain from sources that are more convenient, less 
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burdensome, or less expensive. In particular, Silicon Motion, Inc. objects to the extent the 

Subpoena seeks documents or information that can be obtained from the parties to this Action or 

which, by reason of public filing, prior production, or otherwise, are already in Plaintiff’s 

possession or are readily accessible to Plaintiff. 

5. Silicon Motion, Inc. objects to the Subpoena to the extent it seeks documents or 

information that is not in Silicon Motion, Inc.’s possession, custody, or control. Silicon Motion, 

Inc. further objects to the Subpoena to the extent that it purports to require Silicon Motion, Inc. 

to conduct anything beyond a reasonable and diligent search for responsive documents or 

information where such documents or information would reasonably be expected to be found. 

6. Silicon Motion, Inc. objects to the Subpoena in its entirety and to each and every 

individually numbered Request therein to the extent it seeks the production of documents or 

disclosure of information protected by any applicable privilege, including but not limited to the 

attorney-client privilege, common-interest privilege, the work-product doctrine or immunity, or 

any other applicable privilege, immunity, protection, or exemption from discovery as outlined in 

the Federal Rules of Civil Procedure, Local Rules, any order or ruling by the Court in this case, 

and applicable law. Nothing contained in these objections is intended as, or shall in any way be 

deemed, a waiver of any attorney-client privilege, any work product protection, or any other 

applicable privilege or protection. To the fullest extent allowable under Federal Rule of 

Evidence 502 and any other applicable law, inadvertent production of any such documents or 

disclosure of any such information shall not constitute a waiver of any privilege with respect to 

the documents produced or information disclosed or the subject matter thereof, or a waiver of 

Silicon Motion, Inc.’s right to object to the use of any such documents or information during trial 

or any subsequent proceeding or to demand the return of any documents or information so 

disclosed. 

7. Silicon Motion, Inc. objects to the Subpoena to the extent it seeks trade secrets, 

sensitive business information, or other information that is proprietary and/or confidential, 

including documents or information deemed confidential pursuant to a confidentiality agreement 
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or other arrangements or protected from production or disclosure pursuant to court order. Silicon 

Motion, Inc. will not disclose information or produce documents that are subject to 

confidentiality restrictions of a third party except in conformity with Silicon Motion, Inc.’s 

obligations to such third parties. 

8. Silicon Motion, Inc. objects to the Subpoena in its entirety and to each and every 

individually numbered Request therein to the extent that it purports to require Silicon Motion, 

Inc. to draw subjective or legal conclusions, or is predicated on subjective or legal conclusions or 

arguments. Subject to and without waiving any objections, Silicon Motion, Inc. states that any 

response, production of documents, or provision of information in response to the Subpoena is 

not intended to provide, and shall not constitute or be construed as providing, an admission 

concerning any of the terms used in the Subpoena. 

9. Silicon Motion, Inc. objects to the Subpoena to the extent that it contains 

inaccurate, incomplete, or misleading descriptions of the facts, persons, relationships, and/or 

events underlying this Action. Silicon Motion, Inc. further objects to the Subpoena in its entirety 

to the extent that it assumes the existence of facts that do not exist or the occurrence of events 

that did not take place. The fact that Silicon Motion, Inc. is willing to produce documents or 

provide responsive information does not constitute an admission that any Request is proper, that 

the documents or information it seeks is relevant or within the proper bounds of discovery, that 

the factual predicates stated in the Request are accurate, or that similar Requests will be treated 

in a similar fashion. 

10. Silicon Motion, Inc. objects to the Subpoena to the extent that it is overbroad, 

unduly burdensome, not reasonably calculated to lead to the discovery of admissible evidence, 

not related to any party’s claim or defense, or not proportional to the needs of the case. 

11. Silicon Motion, Inc. objects to the Subpoena in its entirety and to each Request to 

the extent that it is duplicative or cumulative, and objects to the Subpoena in its entirety and to 

each Request to the extent that it is duplicative or cumulative of other discovery. 
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12. Silicon Motion, Inc. objects to the terms “Silicon Motion, Inc.,” “You,” and 

“Your” as vague, ambiguous, overbroad, and unduly burdensome to the extent that it purports to 

encompass “any of its past and present affiliates, operating divisions, parent corporations, 

subsidiaries, directors, officers, agents, employees, representatives, and all predecessors in 

interest.” This definition goes beyond Silicon Motion, Inc. and seeks the production of 

documents and information from other entities and individuals. Silicon Motion, Inc. further 

objects to this definition to the extent it seeks information not within Silicon Motion, Inc.’s 

possession, custody, or control. The Subpoena is directed only to Silicon Motion, Inc. and if 

Plaintiff seeks information held by other entities or individuals, it should subpoena those entities. 

Silicon Motion, Inc. further objects to this definition to the extent it seeks information protected 

by any applicable privilege, including but not limited to the attorney-client privilege, commoninterest privilege, the work-product doctrine or immunity, or any other applicable privilege, 

immunity, protection, or exemption from discovery. Silicon Motion, Inc. further objects to this 

definition to the extent it seeks information, the disclosure of which is prohibited by law, 

regulation, order of a court, or other authority of a foreign jurisdiction in which the information 

is located. Silicon Motion, Inc. further objects to the extent that the definition calls for a legal 

conclusion as to any proprietorship, joint venture, partnership, agency, employment, or affiliate 

relationship. Silicon Motion, Inc. will construe “Silicon Motion, Inc.,” “You,” and “Your” to 

mean Non-Party Silicon Motion, Inc. Silicon Motion, Inc. is responding to this Subpoena on its 

own behalf and not on behalf of any other person or entity. 

13. Silicon Motion, Inc. objects to the term “Micron” as vague, ambiguous, overbroad, 

and unduly burdensome to the extent that it purports to encompass “any of its past and present 

affiliates, operating divisions, parent corporations, subsidiaries, directors, officers, agents, 

employees, representatives, and all persons acting on its behalf.” Silicon Motion, Inc. does not 

know every affiliate, division, parent, subsidiary, director, officer, agent, employee, or 

representative Micron may have because such information is not publicly available. Silicon 

Motion, Inc. further objects to this definition to the extent it seeks information protected by any 
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applicable privilege, including but not limited to the common-interest privilege, or any other 

applicable privilege, immunity, protection, or exemption from discovery. Silicon Motion, Inc. 

further objects to the extent that the definition calls for a legal conclusion as to any agency, 

employment, or affiliate relationship. Silicon Motion, Inc. will construe “Micron” to mean 

Micron Technology, Inc. 

14. Silicon Motion, Inc. objects to the term “TRIM command” as vague, ambiguous, 

overbroad, and unduly burdensome, particularly with respect to the terms “adopted,” “entitled,” 

and “version,” the undefined terms “TRIM command,” “American National Standard for 

Information Technology,” and “ATA/ATAPI Command Set – 3 (ACS 3),” and the circular 

definition of “‘TRIM command’” as “the TRIM command.” Silicon Motion, Inc. further objects 

to the definition as overbroad and unduly burdensome on the ground that it purports to 

incorporate by reference an unknown document that has not been provided to Silicon Motion, 

Inc. 

15. Silicon Motion, Inc. objects to the term “DEALLOCATE command” as vague, 

ambiguous, overbroad, and unduly burdensome, particularly with respect to “adopted,” “entitled,” 

and “version,” the undefined terms “DEALLOCATE command,” “NVMe Express,” “NVMe 

Express Revision 1.3,” and “NVME Express interface,” and the circular definition of 

“‘DEALLOCATE command’” as “the DEALLOCATE command.” Silicon Motion, Inc. further 

objects to the definition as overbroad and unduly burdensome on the ground that it purports to 

incorporate by reference an unknown document that has not been provided to Silicon Motion, 

Inc. 

16. Silicon Motion, Inc. objects to the definition of “any references to a particular 

entity” as vague, ambiguous, overbroad, and unduly burdensome to the extent that it purports to 

encompass “that entity and all its divisions, departments, domestic and foreign subsidiaries, 

branches, parents, affiliates, domestic and foreign subsidiaries of parents, affiliates, partners, 

predecessors-in-interest, successors-in-interest, present and former officers, directors, managers, 

employees, consultants, agents, attorneys, accountants, representatives, entities acting in joint-
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venture or partnership relationship with that particular entity, and all other persons or entities 

purporting to act on behalf of or in concert with that particular entity or any of its divisions, 

departments, subsidiaries, parents, affiliates, partners, branches, predecessors-in-interest, 

successors-in-interest, present and former officers, directors, managers, employees, consultants, 

agents, attorneys, accountants, representatives.” 

17. Silicon Motion, Inc. objects to the definition of “and,” “and/or,” and “or” as 

vague, ambiguous, overbroad, unduly burdensome, and to the extent they impose obligations on 

Silicon Motion, Inc. that are different or broader than those set forth in the Federal Rules of Civil 

Procedure, applicable Local Rules, or any order or ruling by the Court in this case. Silicon 

Motion, Inc. will construe “and,” “and/or,” and “or” to have their normal meaning. 

18. Silicon Motion, Inc. objects to the definition of “any” as vague, ambiguous, 

overbroad, unduly burdensome, particularly with respect to the phrase, “not so as to permit the 

option of providing some requested documents, things, or information instead of others,” and to 

the extent they impose obligations on Silicon Motion, Inc. that are different or broader than those 

set forth in the Federal Rules of Civil Procedure, applicable Local Rules, or any order or ruling 

by the Court in this case. Silicon Motion, Inc. will construe “any” to have its normal meaning. 

19. Silicon Motion, Inc. objects to the definition of “relating to” as vague, ambiguous, 

overbroad, and unduly burdensome. Silicon Motion, Inc. further objects to the extent this 

definition purports to impose any obligations on Silicon Motion, Inc. that are different or broader 

than those set forth in the Federal Rules of Civil Procedure, applicable Local Rules, or any order 

or ruling by the Court in this case. Silicon Motion, Inc. will construe “relating to” to have its 

normal meaning. 

20. Silicon Motion, Inc. provides the following specific objections and responses 

subject to, and without waiving the foregoing General Objections, which are incorporated by 

reference into each response below: 
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RESPONSES AND OBJECTIONS TO DOCUMENTS REQUESTED 

REQUEST NO. 1 

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

drives (“SSDs”), including, but not limited to, Micron's 2100, 2100 AT, 2210, BX500, MX500, 

P 1, X6, and X8 Series SSDs. 

RESPONSE TO REQUEST NO. 1 

Silicon Motion, Inc. hereby incorporates by reference its Preliminary Statement and 

General Objections. Silicon Motion, Inc. objects to this Request on the grounds that it seeks 

documents or information that Plaintiff can obtain from sources that are more convenient, less 

burdensome, or less expensive. In particular, Silicon Motion, Inc. objects to the Request on the 

grounds that it seeks documents or information that can be obtained from the parties to this 

Action, namely Defendant Micron, instead of Non-Party Silicon Motion, Inc. Silicon Motion, 

Inc. further objects to this Request on the grounds that it is overbroad, unduly burdensome, not 

relevant to any party’s claim or defense, and not proportional to the needs of the case because 

Silicon Motion, Inc. is not a party to this Action and does not transact or has ever transacted 

business with any party to this Action, including Micron. Silicon Motion, Inc. further objects to 

this Request on the grounds that it is overly broad and unduly burdensome, as it necessitates a 

review that would take an unreasonable amount of time and money that is not proportional to the 

needs of the case. Silicon Motion, Inc. further objects to this Request as vague and ambiguous, 

particularly with respect to the terms “source code,” “controllers,” “provide,” “use,” and “solid 

state drives.” Silicon Motion, Inc. further objects to this Request on the grounds it seeks trade 

secrets, sensitive business information, and other information that is proprietary and/or 

confidential. Silicon Motion, Inc.’s product development is confidential and constitutes a trade 

secret and all documents related to its product development are highly proprietary and have 

always been treated as trade secrets by Silicon Motion, Inc. Disclosure of any such information 

would directly and severely harm Silicon Motion, Inc. 
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Subject to and without waiving these objections, Silicon Motion, Inc. responds that it has 

conducted a reasonable and diligent search for responsive documents or information where such 

documents or information would reasonably be expected to be found and has not found any such 

documents or information. 

REQUEST NO. 2 

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

TRIM command. 

RESPONSE TO REQUEST NO. 2 

Silicon Motion, Inc. hereby incorporates by reference its Preliminary Statement and 

General Objections. Silicon Motion, Inc. objects to this Request on the grounds that it seeks 

documents or information that Plaintiff can obtain from sources that are more convenient, less 

burdensome, or less expensive. In particular, Silicon Motion, Inc. objects to the Request on the 

grounds that it seeks documents or information that can be obtained from the parties to this 

Action, namely Defendant Micron, instead of Non-Party Silicon Motion, Inc. Silicon Motion, 

Inc. further objects to this Request on the grounds that it is overbroad, unduly burdensome, not 

relevant to any party’s claim or defense, and not proportional to the needs of the case because 

Silicon Motion, Inc. is not a party to this Action and does not transact or has ever transacted 

business with any party to this Action, including Micron. Silicon Motion, Inc. further objects to 

this Request on the grounds that it is overly broad and unduly burdensome, as it necessitates a 

review that would take an unreasonable amount of time and money that is not proportional to the 

needs of the case. Silicon Motion, Inc. further objects to this Request as vague and ambiguous, 

particularly with respect to the terms “sufficient,” “controllers,” “provide,” and “implement.” 

Silicon Motion, Inc. further objects to this Request on the grounds it seeks trade secrets, sensitive 

business information, and other information that is proprietary and/or confidential. Silicon 

Motion, Inc.’s product development is confidential and constitutes a trade secret and all 

documents related to its product development are highly proprietary and have always been 
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treated as trade secrets by Silicon Motion, Inc. Disclosure of any such information would 

directly and severely harm Silicon Motion, Inc. 

Subject to and without waiving these objections, Silicon Motion, Inc. responds that it has 

conducted a reasonable and diligent search for responsive documents or information where such 

documents or information would reasonably be expected to be found and has not found any such 

documents or information. 

REQUEST NO. 3 

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

DEALLOCATE command. 

RESPONSE TO REQUEST NO. 3 

Silicon Motion, Inc. hereby incorporates by reference its Preliminary Statement and 

General Objections. Silicon Motion, Inc. objects to this Request on the grounds that it seeks 

documents or information that Plaintiff can obtain from sources that are more convenient, less 

burdensome, or less expensive. In particular, Silicon Motion, Inc. objects to the Request on the 

grounds that it seeks documents or information that can be obtained from the parties to this 

Action, namely Defendant Micron, instead of Non-Party Silicon Motion, Inc. Silicon Motion, 

Inc. further objects to this Request on the grounds that it is overbroad, unduly burdensome, not 

relevant to any party’s claim or defense, and not proportional to the needs of the case because 

Silicon Motion, Inc. is not a party to this Action and does not transact or has ever transacted 

business with any party to this Action, including Micron. Silicon Motion, Inc. further objects to 

this Request on the grounds that it is overly broad and unduly burdensome, as it necessitates a 

review that would take an unreasonable amount of time and money that is not proportional to the 

needs of the case. Silicon Motion, Inc. further objects to this Request as vague and ambiguous, 

particularly with respect to the terms “sufficient,” “controllers,” “provide,” and “implement.” 

Silicon Motion, Inc. further objects to this Request on the grounds it seeks trade secrets, sensitive 

business information, and other information that is proprietary and/or confidential. Silicon 
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Motion, Inc.’s product development is confidential and constitutes a trade secret and all 

documents related to its product development are highly proprietary and have always been 

treated as trade secrets by Silicon Motion, Inc. Disclosure of any such information would 

directly and severely harm Silicon Motion, Inc. 

Subject to and without waiving these objections, Silicon Motion, Inc. responds that it has 

conducted a reasonable and diligent search for responsive documents or information where such 

documents or information would reasonably be expected to be found and has not found any such 

documents or information. 

REQUEST NO. 4 

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

RESPONSE TO REQUEST NO.4 

Silicon Motion, Inc. hereby incorporates by reference its Preliminary Statement and 

General Objections. Silicon Motion, Inc. objects to this Request on the grounds that it seeks 

documents or information that Plaintiff can obtain from sources that are more convenient, less 

burdensome, or less expensive. In particular, Silicon Motion, Inc. objects to the Request on the 

grounds that it seeks documents or information that can be obtained from the parties to this 

Action, namely Defendant Micron, instead of Non-Party Silicon Motion, Inc. Silicon Motion, 

Inc. further objects to this Request on the grounds that it is overbroad, unduly burdensome, and 

not proportional to the needs of the case because Silicon Motion, Inc. is not a party to this Action 

and does not transact or has ever transacted business with any party to this Action, including 

Micron. Silicon Motion, Inc. further objects to this Request on the grounds that it is overly broad 

and unduly burdensome, as it necessitates a review that would take an unreasonable amount of 

time and money that is not proportional to the needs of the case. Silicon Motion, Inc. further 

objects to this Request as vague and ambiguous, particularly with respect to the terms 

“correspondence.” Silicon Motion, Inc. further objects to this definition to the extent it purports 

to include information protected by any applicable privilege, including but not limited to the 
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attorney-client privilege, common-interest privilege, the work-product doctrine or immunity, or 

any other applicable privilege, immunity, protection, or exemption from discovery. 

Subject to and without waiving these objections, Silicon Motion, Inc. responds that it has 

conducted a reasonable and diligent search for responsive documents or information where such 

documents or information would reasonably be expected to be found and has not found any such 

documents or information. 

REQUEST NO. 5 

All correspondence with Micron related to the Litigation. 

RESPONSE TO REQUEST NO. 5 

Silicon Motion, Inc. hereby incorporates by reference its Preliminary Statement and 

General Objections. Silicon Motion, Inc. objects to this Request on the grounds that it seeks 

documents or information that Plaintiff can obtain from sources that are more convenient, less 

burdensome, or less expensive. In particular, Silicon Motion, Inc. objects to the Request on the 

grounds that it seeks documents or information that can be obtained from the parties to this 

Action, namely Defendant Micron, instead of Non-Party Silicon Motion, Inc. Silicon Motion, 

Inc. further objects to this Request on the grounds that it is overbroad, unduly burdensome, and 

not proportional to the needs of the case because Silicon Motion, Inc. is not a party to this Action 

and does not transact or has ever transacted business with any party to this Action, including 

Micron. Silicon Motion, Inc. further objects to this Request on the grounds that it is overly broad 

and unduly burdensome, as it necessitates a review that would take an unreasonable amount of 

time and money that is not proportional to the needs of the case. Silicon Motion, Inc. further 

objects to this Request as vague and ambiguous, particularly with respect to the terms 

“correspondence.” Silicon Motion, Inc. further objects to this definition to the extent it purports 

to include information protected by any applicable privilege, including but not limited to the 

attorney-client privilege, common-interest privilege, the work-product doctrine or immunity, or 

any other applicable privilege, immunity, protection, or exemption from discovery. 
13 

4846-5216-1779

Subject to and without waiving these objections, Silicon Motion, Inc. responds that it has 

conducted a reasonable and diligent search for responsive documents or information where such 

documents or information would reasonably be expected to be found and has not found any such 

documents or information. 

REQUEST NO. 6 

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

RESPONSE TO REQUEST NO. 6 

Silicon Motion, Inc. hereby incorporates by reference its Preliminary Statement and 

General Objections. Silicon Motion, Inc. objects to this Request on the grounds that it seeks 

documents or information that Plaintiff can obtain from sources that are more convenient, less 

burdensome, or less expensive. In particular, Silicon Motion, Inc. objects to the Request on the 

grounds that it seeks documents or information that can be obtained from the parties to this 

Action, namely Defendant Micron, instead of Non-Party Silicon Motion, Inc. Silicon Motion, 

Inc. further objects to this Request on the grounds that it is overbroad, unduly burdensome, and 

not proportional to the needs of the case because Silicon Motion, Inc. is not a party to this Action 

and does not transact or has ever transacted business with any party to this Action, including 

Micron. Silicon Motion, Inc. further objects to this Request on the grounds that it is overly broad 

and unduly burdensome, as it necessitates a review that would take an unreasonable amount of 

time and money that is not proportional to the needs of the case. Silicon Motion, Inc. further 

objects to this Request as vague and ambiguous, particularly with respect to the terms “sufficient” 

and “aware.” Silicon Motion, Inc. further objects to this definition to the extent it purports to 

include information protected by any applicable privilege, including but not limited to the 

attorney-client privilege, common-interest privilege, the work-product doctrine or immunity, or 

any other applicable privilege, immunity, protection, or exemption from discovery. 

Subject to and without waiving these objections, Silicon Motion, Inc. responds that it has 

conducted a reasonable and diligent search for responsive documents or information where such 
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documents or information would reasonably be expected to be found and has not found any such 

documents or information. 

REQUEST NO. 7 

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

RESPONSE TO REQUEST NO. 7 

Silicon Motion, Inc. hereby incorporates by reference its Preliminary Statement and 

General Objections. Silicon Motion, Inc. objects to this Request on the grounds that it seeks 

documents or information that Plaintiff can obtain from sources that are more convenient, less 

burdensome, or less expensive. In particular, Silicon Motion, Inc. objects to the Request on the 

grounds that it seeks documents or information that can be obtained from the parties to this 

Action, namely Defendant Micron, instead of Non-Party Silicon Motion, Inc. Silicon Motion, 

Inc. further objects to this Request on the grounds that it is overbroad, unduly burdensome, not 

relevant to any party’s claim or defense, and not proportional to the needs of the case because 

Silicon Motion, Inc. is not a party to this Action and does not transact or has ever transacted 

business with any party to this Action, including Micron. Silicon Motion, Inc. further objects to 

this Request on the grounds that it is overly broad and unduly burdensome, as it necessitates a 

review that would take an unreasonable amount of time and money that is not proportional to the 

needs of the case. Silicon Motion, Inc. further objects to this Request as vague and ambiguous, 

particularly with respect to the terms “API,” “user guides,” “controllers,” and “provide.” Silicon 

Motion, Inc. further objects to this Request on the grounds it seeks trade secrets, sensitive 

business information, and other information that is proprietary and/or confidential. Silicon 

Motion, Inc.’s product development is confidential and constitutes a trade secret and all 

documents related to its product development are highly proprietary and have always been 

treated as trade secrets by Silicon Motion, Inc. Disclosure of any such information would 

directly and severely harm Silicon Motion, Inc. 
15 

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Subject to and without waiving these objections, Silicon Motion, Inc. responds that it has 

conducted a reasonable and diligent search for responsive documents or information where such 

documents or information would reasonably be expected to be found and has not found any such 

documents or information. 

Dated: August 6, 2021 Respectfully submitted, 

By: /s/ David J. Tsai 

David J. Tsai 

Pillsbury Winthrop Shaw Pittman LLP 

4 Embarcadero Center, 22nd Floor 

San Francisco, CA 94111 

Telephone: 415.983.1000 

Facsimile: 415.983.1200 

Email: david.tsai@pillsburylaw.com 

Counsel for Non-Party Silicon Motion, Inc. 

 
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CERTIFICATE OF SERVICE 

I hereby certify that on 6th day of August 2021, true and correct copies of the foregoing 

document was served via email on: 

Edward Nelson III (ed@nbafirm.com) 

Robert A. Delafield II (bobby@nbafirm.com) 

Jonathan H. Rastegar (jon@nbafirm.com)

NELSON BUMGARDNER ALBRITTON PC 

3131 West 7th Street, Suite 300 

Fort Worth, TX 76107 

Timothy E. Grochocinski (tim@nbafirm.com)

NELSON BUMGARDNER ALBRITTON PC 

15020 S. Ravinia Avenue, Suite 29 

Orland Park, IL 60462 

COUNSEL FOR PLAINTIFF 

UNIFICATION TECHNOLOGIES LLC

Katherine Kelly Vidal (kvidal@winston.com) 

Michael R. Rueckheim (mrueckheim@winston.com)

Winston & Strawn LLP

275 Middlefield Road, Suite 205 

Menlo Park, CA 94025 

Natalie Terhune Arbaugh (narbaugh@winston.com) 

Qi (Peter) Tong (ptong@winston.com) 

Thomas M. Melsheimer (tmelsheimer@winston.com) 

Winston & Strawn LLP

2121 N. Pearl St, Suite 900 

Dallas, TX 75201 

Vivek V. Krishnan (vkrishnan@winston.com) 

Winston & Strawn LLP

35 W. Wacker Drive 

Chicago, IL 60601 

COUNSEL FOR DEFENDANTS 

/s/ David J. Tsai 

David J. Tsai