EXHIBIT 7

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IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF DELAWARE

GOOGLE LLC,

Plaintiff(s),

v.

BP FUNDING TRUST,

Defendant(s).

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C.A. No. 21-MC-440-UNA

OBJECTION TO SUBPOENA TO PRODUCE DOCUMENTS, 

INFORMATION, OR OBJECTS OR TO PERMIT INSPECTION OF 

PREMISES IN CIVIL ACTION

TO: ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

PLEASE TAKE NOTICE THAT non-party witness BP Funding Trust

(“Responding Party”), pursuant to Fed. R. Civ. P. 45(d)(B), hereby objects to the 

subpoena to produce documents, information, or objects or to permit inspection of 

premises in a civil action as follows:

GENERAL OBJECTIONS

Responding Party makes the following General Objections to the Subpoena 

to Produce Documents, Information, or Objects or To Permit Inspection of 

Premises in a Civil Action, Request Nos. 1-27. These General Objections are 

incorporated into the specific objections to each Request. The assertion of the same 

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or additional objections to any individual Request does not waive other General 

Objections that are not repeated in the specific objections. The objections and 

responses set forth below are based on information currently available to 

Responding Party: 

1. Responding Party objects to each and every Request to the extent that it 

seeks information protected by the attorney-client privilege, attorney work product 

doctrine, joint defense agreement and/or taxpayer/tax return privilege. 

2. Responding Party further objects to each request to the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. 

3. Responding Party objects to each request to the extent that it seeks 

production of documents that are neither relevant to the subject matter of this 

action nor reasonably calculated to lead to the discovery of admissible evidence.

4. Responding Party objects to each request to the extent that the 

information sought can be obtained through party discovery or other sources 

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without the need to seek documents from non-party witness Responding Party. 

Google LLC (“Propounding Party”) failed to take reasonable steps to avoid 

imposing undue burden or expense on Responding Party in violation of Federal 

Rules of Civil Procedure, Rule 45(d)(1).

5. Responding Party objects to each of Propounding Party’s definitions as 

overbroad, oppressive, unduly burdensome, unnecessarily expensive, and not 

proportional to the needs of the case, considering the importance of the issues at 

stake in the action, the amount in controversy, the parties’ relative access to 

relevant information, the importance of the discovery in resolving the issues, and 

whether the burden or expense of the proposed discovery outweighs its likely 

benefits. Responding Party further objects to the extent that any definition attempts 

to impose any obligations upon Responding Party greater than those authorized by 

the Federal Rules of Civil Procedure, Local Rules, or any other applicable law, and 

also as, vague, ambiguous, unclear, or unintelligible. 

6. Nothing herein is intended to waive the following objections, which are 

expressly reserved: All objections as to competency, relevancy, materiality and 

admissibility of the subject matter of the discovery requests; all objections as to 

vagueness, ambiguity, or undue burden; all objections on any ground as to the use 

of any information provided in response to these discovery requests; and all 

objections on any ground to any request for further responses to these or other 

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discovery requests.

7. Responding Party does not waive any right to make and preserves any 

objections to the questions asked at deposition or to instruct a witness not to 

answer any question.

8. Responding Party objects to the definition of “Responding Party Trust” to 

include the various different entities referenced in the definition. The only 

appropriate entity for anything related to WSOU is “Responding Party Trust, 

Series SPL-VI.”

9. Responding Party objects to Definition 4 which seeks to define various 

different entities in an overbroad fashion. Specifically, Responding Party objects 

to the part of the definition extends to include “Basepoint Administrative LLC and 

BP Funding Trust, a Delaware statutory trust; BP Funding Trust, Series SPL-VI, a 

statutory series of BP Funding Trust; and their trustees, managers, agents, 

representatives, employees, attorneys, or entities acting in conjunction, joint 

venture, or partnership with any of them including but not limited to Basepoint 

Capital LLC, Basepoint Tax Funding Trust, Venture 4th Basepoint 1, LLC, 

Basepoint Administrative LLC, Basepoint Asset Recovery LLC, or any other 

“Basepoint” entity or related entity thereto.”

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10. Responding Party objects to Definitions 5 through 15, and 17, all of 

which seek to define various different entities in an overbroad

fashion. Specifically, Responding Party objects to the part of the definition 

extends to include “any other persons acting on behalf of any of the foregoing, and 

any other entities that own or control or are owned or controlled by or share 

common ownership or control with any of the foregoing, as well as predecessors 

and successors in interest to such entities” for each entity, and to the part of the 

definition that extends to “affiliates” of the entity, a term which is itself defined in 

overbroad fashion at number 17.

11. Responding Party objects to Definition 16 (“asserted patents”) as vague 

and overbroad, to the extent that it includes asserted patents beyond the particular 

patents specifically referenced.

12. Responding Party objects to Definitions 18 (“related application”), 19 

(“related patent”), 21 (“accused product”), and 22 (“asserted claim”) as vague and 

overbroad.

13. Responding Party objects to Definition 33 (“Other WSOU Defendants”) 

as vague and overbroad, to the extent that it includes defendants other than those 

particular defendants specifically referenced.

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14. Responding Party objects to the “Instructions” to the extent they purport 

to request anything of a non-party that goes beyond what is required or allowed 

under Federal Rule of Civil Procedure 45.

REQUESTS AND OBJECTIONS TO INDIVIDUAL REQUESTS

REQUEST FOR PRODUCTION NO. 1:

Documents concerning the formation of BP Funding Trust.

RESPONSE TO REQUEST 1:

Objection. Responding Party objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to any party’s claim or defense, nor 

proportional to the needs of the case.

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REQUEST FOR PRODUCTION NO. 2:

Documents concerning your relationship to NextPoint Acquisition Corp.

RESPONSE TO REQUEST 2:

Objection. Responding Party objects to this request on the grounds it is 

vague, ambiguous and unintelligible as to the term “your relationship”. 

Responding Party objects on the grounds this request is overly broad and unduly 

burdensome. Responding Party objects further on the grounds this request is 

oppressive, burdensome and harassing as the documents requested can be sought 

from a party or other source without the need to seek them from this non-party 

witness. Responding Party further objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

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it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 3:

Documents concerning your corporate structure.

RESPONSE TO REQUEST 3:

Objection. Responding Party objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 4:

Documents concerning your investments or interests in the asserted patents, 

including assignment, licensing, acquisition, financial interest, security interest, 

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lien, sale, transfer of rights (in whole or in part) and any other disposition of or any 

offers to buy, sell, obtain rights to, or licenses any of the asserted patents.

RESPONSE TO REQUEST 4:

Objection. Responding Party objects on the grounds this request is 

overly broad and unduly burdensome. Responding Party objects further on the 

grounds this request is oppressive, burdensome and harassing as the documents 

requested can be sought from a party or other source without the need to seek them 

from this non-party witness. Responding Party objects to this request to the extent 

it seeks information protected from disclosure by the attorney-client privilege 

and/or attorney work product doctrine. Responding Party further objects to the

extent it calls for the disclosure of non-public, private, personal, confidential, 

proprietary information, or trade secret information that has been maintained in 

confidence and/or is legally required to be maintained in confidence, including, but 

not limited to, documents that are shielded from production by statutory or 

decisional law of the United States and each of its jurisdictions, statutory or 

decisional law of any foreign country, the right of privacy under the United States 

Constitution, and all other applicable laws or privileges. Responding Party further 

objects to the extent it seeks information that is not relevant to the relevant to any 

party’s claim or defense, nor proportional to the needs of the case.

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REQUEST FOR PRODUCTION NO. 5:

Documents concerning discussions with NextPoint Acquisition Corp. 

regarding any asserted patent, a portfolio including an asserted patent, assignment 

of any interest in any asserted patent or a portfolio including an asserted patent, or 

the acquisition or potential acquisition of any portfolio that might have included an 

asserted patent.

RESPONSE TO REQUEST 5:

Objection. Responding Party objects on the grounds this request is 

overly broad and unduly burdensome. Responding Party objects further on the 

grounds this request is oppressive, burdensome and harassing as the documents 

requested can be sought from a party or other source without the need to seek them 

from this non-party witness. Responding Party objects to this request to the extent 

it seeks information protected from disclosure by the attorney-client privilege 

and/or attorney work product doctrine. Responding Party further objects to the

extent it calls for the disclosure of non-public, private, personal, confidential, 

proprietary information, or trade secret information that has been maintained in 

confidence and/or is legally required to be maintained in confidence, including, but 

not limited to, documents that are shielded from production by statutory or 

decisional law of the United States and each of its jurisdictions, statutory or 

decisional law of any foreign country, the right of privacy under the United States 

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Constitution, and all other applicable laws or privileges. Responding Party further 

objects to the extent it seeks information that is not relevant to the relevant to any 

party’s claim or defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 6:

Documents concerning discussions with Terrier regarding any asserted 

patent, a portfolio including an asserted patent, assignment of any interest in any 

asserted patent or a portfolio including an asserted patent, or the acquisition or 

potential acquisition of any portfolio that might have included an asserted patent.

RESPONSE TO REQUEST 6:

Objection. Responding Party objects on the grounds this request is 

overly broad and unduly burdensome. Responding Party objects further on the 

grounds this request is oppressive, burdensome and harassing as the documents 

requested can be sought from a party or other source without the need to seek them 

from this non-party witness. Responding Party objects to this request to the extent 

it seeks information protected from disclosure by the attorney-client privilege 

and/or attorney work product doctrine. Responding Party further objects to the

extent it calls for the disclosure of non-public, private, personal, confidential, 

proprietary information, or trade secret information that has been maintained in 

confidence and/or is legally required to be maintained in confidence, including, but 

not limited to, documents that are shielded from production by statutory or 

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decisional law of the United States and each of its jurisdictions, statutory or 

decisional law of any foreign country, the right of privacy under the United States 

Constitution, and all other applicable laws or privileges. Responding Party further 

objects to the extent it seeks information that is not relevant to the relevant to any 

party’s claim or defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 7:

Agreements with Terrier concerning any potential or actual transaction 

regarding any asserted patent, a portfolio including an asserted patent, or the 

acquisition or potential acquisition of any portfolio that might have included an 

asserted patent.

RESPONSE TO REQUEST 7:

Objection. Responding Party objects on the grounds this request is 

overly broad and unduly burdensome. Responding Party objects further on the 

grounds this request is oppressive, burdensome and harassing as the documents 

requested can be sought from a party or other source without the need to seek them 

from this non-party witness. Responding Party objects to this request to the extent 

it seeks information protected from disclosure by the attorney-client privilege 

and/or attorney work product doctrine. Responding Party further objects to the

extent it calls for the disclosure of non-public, private, personal, confidential, 

proprietary information, or trade secret information that has been maintained in 

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confidence and/or is legally required to be maintained in confidence, including, but 

not limited to, documents that are shielded from production by statutory or 

decisional law of the United States and each of its jurisdictions, statutory or 

decisional law of any foreign country, the right of privacy under the United States 

Constitution, and all other applicable laws or privileges. Responding Party further 

objects to the extent it seeks information that is not relevant to the relevant to any 

party’s claim or defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 8:

Agreements with the named inventor(s) of any of the asserted patents, 

including assignment agreements, consulting agreements, employment agreements 

and any agreements pertaining to litigation involving the asserted patents or any 

related patents.

RESPONSE TO REQUEST 8:

Objection. Responding Party objects on the grounds this request is 

overly broad and unduly burdensome. Responding Party objects further on the 

grounds this request is oppressive, burdensome and harassing as the documents 

requested can be sought from a party or other source without the need to seek them 

from this non-party witness. Responding Party objects to this request to the extent 

it seeks information protected from disclosure by the attorney-client privilege 

and/or attorney work product doctrine. Responding Party further objects to the

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extent it calls for the disclosure of non-public, private, personal, confidential, 

proprietary information, or trade secret information that has been maintained in 

confidence and/or is legally required to be maintained in confidence, including, but 

not limited to, documents that are shielded from production by statutory or 

decisional law of the United States and each of its jurisdictions, statutory or 

decisional law of any foreign country, the right of privacy under the United States 

Constitution, and all other applicable laws or privileges. Responding Party further 

objects to the extent it seeks information that is not relevant to the relevant to any 

party’s claim or defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 9:

Compensation, cost-sharing, or profit sharing agreements with any of the 

named inventor(s) of the asserted patent(s).

RESPONSE TO REQUEST 9:

Objection. Responding Party objects on the grounds this request is 

vague, ambiguous and unintelligible as to the phrases/terms “Compensation, costsharing, or profit sharing agreements.” Responding Party objects further on the 

grounds this request is oppressive, burdensome and harassing as the documents 

requested can be sought from a party or other source without the need to seek them 

from this non-party witness. Responding Party objects to this request to the extent 

it seeks information protected from disclosure by the attorney-client privilege 

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and/or attorney work product doctrine. Responding Party further objects to the

extent it calls for the disclosure of non-public, private, personal, confidential, 

proprietary information, or trade secret information that has been maintained in 

confidence and/or is legally required to be maintained in confidence, including, but 

not limited to, documents that are shielded from production by statutory or 

decisional law of the United States and each of its jurisdictions, statutory or 

decisional law of any foreign country, the right of privacy under the United States 

Constitution, and all other applicable laws or privileges. Responding Party further 

objects to the extent it seeks information that is not relevant to the relevant to any 

party’s claim or defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 10:

Documents regarding the assignment, licensing, acquisition, financial 

interest, security interest, lien, sale, transfer of rights (in whole or in part) and any 

other disposition of or any offers to buy, sell, obtain rights to, or licenses any of the 

asserted patents.

RESPONSE TO REQUEST 10:

Objection. Responding Party objects on the grounds this request is vague,

ambiguous and unintelligible as to the phrases/terms “Compensation, cost-sharing, 

or profit sharing agreements.” Responding Party objects further on the grounds 

this request is oppressive, burdensome and harassing as the documents requested 

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can be sought from a party or other source without the need to seek them from this 

non-party witness. Responding Party objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 11:

Documents concerning the nature and scope of any rights you had in the past 

or currently have in each of the asserted patents, related applications or related 

patents from the time each alleged invention was conceived through the present, 

including the right to control any portion of litigation, future royalties, payment for 

licenses, contingent rights, or payments depending on the outcome of litigation.

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RESPONSE TO REQUEST 11:

Objection. Responding Party objects on the grounds this request is overly 

broad and unduly burdensome. Responding Party objects further on the grounds 

this request is oppressive, burdensome and harassing as the documents requested 

can be sought from a party or other source without the need to seek them from this 

non-party witness. Responding Party objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 12:

Documents regarding agreements relating to each of the asserted patents (or 

any portfolio including any of the asserted patents), including assurances, 

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covenants not to sue and understandings not to assert any of the asserted patents 

against potential licensees.

RESPONSE TO REQUEST 12:

Objection. Responding Party objects on the grounds this request is overly 

broad and unduly burdensome. Responding Party objects further on the grounds 

this request is oppressive, burdensome and harassing as the documents requested 

can be sought from a party or other source without the need to seek them from this 

non-party witness. Responding Party objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

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REQUEST FOR PRODUCTION NO. 13:

Documents regarding agreements between you and WSOU, Allied Security 

Trust, AQUA Licensing, LLC, RPX Corporation, Fortress Credit Co., LLC, 

Houlihan, Orange Holdings, Wade and Company, Omega Credit Opportunities 

Master Fund, Terrier, Juniper Capital Partners, Coast Asset Management, or 

WCFT Cayman, regarding any asserted patent, a portfolio including an asserted 

patent, or the acquisition or potential acquisition of any portfolio that might have 

included an asserted patent, including any amendment, modification, 

supplementation, abrogation, or termination of any such agreements.

RESPONSE TO REQUEST 13:

Objection. Responding Party objects on the grounds this request is 

overly broad and unduly burdensome. Responding Party objects further on the 

grounds this request is oppressive, burdensome and harassing as the documents 

requested can be sought from a party or other source without the need to seek them 

from this non-party witness. Responding Party objects to this request to the extent 

it seeks information protected from disclosure by the attorney-client privilege 

and/or attorney work product doctrine. Responding Party further objects to the

extent it calls for the disclosure of non-public, private, personal, confidential, 

proprietary information, or trade secret information that has been maintained in 

confidence and/or is legally required to be maintained in confidence, including, but 

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not limited to, documents that are shielded from production by statutory or 

decisional law of the United States and each of its jurisdictions, statutory or 

decisional law of any foreign country, the right of privacy under the United States 

Constitution, and all other applicable laws or privileges. Responding Party further 

objects to the extent it seeks information that is not relevant to the relevant to any 

party’s claim or defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 14:

Documents regarding agreements with Nokia or other WSOU Defendants 

regarding an asserted patent or a portfolio including an asserted patent.

RESPONSE TO REQUEST 14:

Objection. Responding Party objects on the grounds this request is overly 

broad and unduly burdensome. Responding Party objects further on the grounds 

this request is oppressive, burdensome and harassing as the documents requested 

can be sought from a party or other source without the need to seek them from this 

non-party witness. Responding Party objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

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to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 15:

Communications with Nokia, Allied Security Trust, AQUA, RPX 

Corporation, Fortress Credit Co., LLC, Houlihan, WSOU, Orange Holdings, Wade 

and Company, Omega Credit Opportunities Master Fund, Terrier, Juniper Capital 

Partners, Coast Asset Management, or WCFT Cayman regarding an asserted 

patent, a portfolio including an asserted patent, or actual or potential litigation 

relating to an asserted patent.

RESPONSE TO REQUEST 15:

Objection. Responding Party objects on the grounds this request is overly 

broad and unduly burdensome. Responding Party objects further on the grounds 

this request is oppressive, burdensome and harassing as the documents requested 

can be sought from a party or other source without the need to seek them from this 

non-party witness. Responding Party objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

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attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 16:

Documents concerning communications with any of the named inventors 

regarding any of the asserted patents, this litigation or Google.

RESPONSE TO REQUEST 16:

Objection. Responding Party objects on the grounds this request is vague, 

ambiguous and unintelligible. Responding Party further objects on the grounds 

that this request overly broad and unduly burdensome. Responding Party objects 

on the grounds this request is oppressive, burdensome and harassing as the 

documents requested can be sought from a party or other source without the need 

to seek them from this non-party witness. Responding Party objects to this request 

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to the extent it seeks information protected from disclosure by the attorney-client 

privilege and/or attorney work product doctrine. Responding Party further objects 

to the extent it calls for the disclosure of non-public, private, personal, confidential, 

proprietary information, or trade secret information that has been maintained in 

confidence and/or is legally required to be maintained in confidence, including, but 

not limited to, documents that are shielded from production by statutory or 

decisional law of the United States and each of its jurisdictions, statutory or 

decisional law of any foreign country, the right of privacy under the United States 

Constitution, and all other applicable laws or privileges. Responding Party further 

objects to the extent it seeks information that is not relevant to the relevant to any 

party’s claim or defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 17:

Communications with WSOU regarding the asserted patent, related patents, 

this litigation or Google.

RESPONSE TO REQUEST 17:

Objection. Responding Party objects on the grounds this request is vague, 

ambiguous and unintelligible. Responding Party further objects on the grounds 

that this request overly broad and unduly burdensome. Responding Party objects 

on the grounds this request is oppressive, burdensome and harassing as the 

documents requested can be sought from a party or other source without the need 

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to seek them from this non-party witness. Responding Party objects to this request 

to the extent it seeks information protected from disclosure by the attorney-client 

privilege and/or attorney work product doctrine. Responding Party further objects 

to the extent it calls for the disclosure of non-public, private, personal, confidential, 

proprietary information, or trade secret information that has been maintained in 

confidence and/or is legally required to be maintained in confidence, including, but 

not limited to, documents that are shielded from production by statutory or 

decisional law of the United States and each of its jurisdictions, statutory or

decisional law of any foreign country, the right of privacy under the United States 

Constitution, and all other applicable laws or privileges. Responding Party further 

objects to the extent it seeks information that is not relevant to the relevant to any

party’s claim or defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 18:

Documents concerning communications between you and any other entity 

relating to the possibility of patent litigation regarding the asserted patent and 

related patents, including any actual or potential patent litigation against Google 

and the WSOU v. Google Litigations.

RESPONSE TO REQUEST 18:

Objection. Responding Party objects on the grounds this request is overly 

broad and unduly burdensome. Responding Party objects further on the grounds 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 25 of 129
25

this request is oppressive, burdensome and harassing as the documents requested 

can be sought from a party or other source without the need to seek them from this 

non-party witness. Responding Party objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 19:

Documents concerning any contemplated acquisition of patents or rights in 

patents from Nokia.

RESPONSE TO REQUEST 19:

Objection. Responding Party objects on the grounds this request is

oppressive, burdensome and harassing as the documents requested can be sought 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 26 of 129
26

from a party or other source without the need to seek them from this non-party 

witness. Responding Party objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 20:

Documents sufficient to show any interests (current or prior) in WSOU.

RESPONSE TO REQUEST 20:

Objection. Responding Party objects on the grounds this request is 

oppressive, burdensome and harassing as the documents requested can be sought 

from a party or other source without the need to seek them from this non-party 

witness. Responding Party objects to this request to the extent it seeks 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 27 of 129
27

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 21:

Documents sufficient to show any actual, contingent, or potential (1) right to 

license or sublicense any asserted patent, (2) right to control the licensing of any 

asserted patent, or (3) right to control or be involved in the resolution of any 

litigation involving any asserted patent.

RESPONSE TO REQUEST 21:

Objection. Responding Party objects on the grounds this request is

oppressive, burdensome and harassing as the documents requested can be sought 

from a party or other source without the need to seek them from this non-party 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 28 of 129
28

witness. Responding Party objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 22:

Documents sufficient to show your relationship with Stuart A. Shanus, Eric 

Schneider, Andrew Neuberger, Marc Wade, or Craig Etchegoyen, Orange 

Holdings, WSOU, Uniloc USA, Inc., WCFT Cayman, Omega Credit Opportunities 

Master Fund, Wade and Company, and Terrier, or any entity associated with the 

foregoing.

RESPONSE TO ERQUEST 22:

Objection. Responding Party objects on the grounds this request is 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 29 of 129
29

oppressive, burdensome and harassing as the documents requested can be sought 

from a party or other source without the need to seek them from this non-party 

witness. Responding Party objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 23

Documents concerning communications with Omega Credit Opportunities 

Master Fund.

RESPONSE TO REQUEST 23:

Objection. Responding Party objects on the grounds this request is 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 30 of 129
30

oppressive, burdensome and harassing as the documents requested can be sought 

from a party or other source without the need to seek them from this non-party 

witness. Responding Party objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 24:

Documents concerning the “Patent Security Agreement” recorded at USPTO 

Reel 09235 Frame 0068, signed May 16, 2019, the circumstances of this 

agreement, and any related agreements.

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 31 of 129
31

RESPONSE TO REQUEST 24:

Objection. Responding Party objects on the grounds this request is 

oppressive, burdensome and harassing as the documents requested can be sought 

from a party or other source without the need to seek them from this non-party 

witness. Responding Party objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 25:

Documents concerning the value of, any valuations of or attempts to value 

any asserted patent, related patent, or related application, whether individually or 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 32 of 129
32

in combination with any other patents or applications, including any portfolio 

containing any asserted patent or related patent.

RESPONSE TO REQUEST 25:

Objection. Responding Party objects on the grounds this request is 

oppressive, burdensome and harassing as the documents requested can be sought 

from a party or other source without the need to seek them from this non-party 

witness. Responding Party objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 33 of 129
33

REQUEST FOR PRODUCTION NO. 26:

Documents concerning any evaluation or analysis of any asserted patent, any 

related patent, or any related application, whether individually or in combination 

with any other patents or applications, including any evaluation or analysis of 

infringement, validity, or commercialization.

RESPONSE TO REQUEST 26:

Objection. Responding Party objects on the grounds this request is overly 

broad and unduly burdensome. Responding Party objects further on the grounds 

this request is oppressive, burdensome and harassing as the documents requested 

can be sought from a party or other source without the need to seek them from this 

non-party witness. Responding Party objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 34 of 129
34

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 27:

Documents produced in response to a subpoena served by any other WSOU 

Defendant.

RESPONSE TO REQUEST 27:

Objection. Responding Party objects on the grounds this request is overly 

broad and unduly burdensome. Responding Party objects further on the grounds 

this request is oppressive, burdensome and harassing as the documents requested 

can be sought from a party or other source without the need to seek them from this 

non-party witness. Responding Party objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 35 of 129
35

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

Date: October 19, 2021 /s/ Morgan E. Pietz

Morgan E. Pietz (CA Bar #260629)*

Pietz & Shahriari, LLP

9454 Wilshire Blvd., Suite 310

Beverly Hills, CA 90212

Counsel for BP Funding Trust

Sean J. Bellew (#4072)

Bellew LLC

2961 Centerville Road, Suite 302

Wilmington, Delaware 19808

Telephone: (302) 353-4951

sjbellew@bellewllc.com

Counsel for BP Funding Trust

*Pro Hac Vice application is forthcoming.

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 36 of 129
IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF DELAWARE

GOOGLE LLC,

Plaintiff(s),

v.

BP FUNDING TRUST,

Defendant(s).

:

:

:

:

:

:

:

:

:

:

:

:

C.A. No. 1:21-mc- -UNA

OBJECTION TO SUBPOENA TO TESTIFY AT A DEPOSITION IN A 

CIVIL ACTION

TO: ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

PLEASE TAKE NOTICE THAT non-party witness BP Funding Trust 

(“Responding Party”), pursuant to Fed. R. Civ. P. 45(d)(B), hereby objects to the 

subpoena to testify at a deposition in a civil action as follows:

GENERAL OBJECTIONS

Responding Party makes the following General Objections to the Subpoena 

to Testify at a Deposition in a Civil Action, Topics for Deposition Nos. 1-29. 

These General Objections are incorporated into the specific objections to each 

topic. The assertion of the same or additional objections to any individual Topic

does not waive other General Objections that are not repeated in the specific 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 37 of 129
objections. The objections and responses set forth below are based on information 

currently available to Responding Party: 

1. Responding Party objects to each and every Topic to the extent that it 

seeks information protected by the attorney-client privilege, attorney work product 

doctrine, joint defense agreement and/or taxpayer/tax return privilege. 

2. Responding Party further objects to each topic to the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. 

3. Responding Party objects to each topic to the extent that it seeks 

production of information that is neither relevant to the subject matter of this action 

nor reasonably calculated to lead to the discovery of admissible evidence. Google 

LLC (“Propounding Party”) failed to take reasonable steps to avoid imposing 

undue burden or expense on Responding Party in violation of Federal Rules of 

Civil Procedure, Rule 45(d)(1).

4. Responding Party objects to each topic to the extent that it the 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 38 of 129
information sought can be obtained through party discovery or other sources 

without the need to seek information from non-party witness Responding Party. 

5. Responding Party objects to each of Propounding Party’s definitions as 

overbroad, oppressive, unduly burdensome, unnecessarily expensive, and not 

proportional to the needs of the case, considering the importance of the issues at 

stake in the action, the amount in controversy, the parties’ relative access to 

relevant information, the importance of the discovery in resolving the issues, and 

whether the burden or expense of the proposed discovery outweighs its likely 

benefits. Responding Party further objects to the extent that any definition attempts 

to impose any obligations upon Responding Party greater than those authorized by 

the Federal Rules of Civil Procedure, Local Rules, or any other applicable law, and 

also as, vague, ambiguous, unclear, or unintelligible. 

6. Nothing herein is intended to waive the following objections, which are 

expressly reserved: All objections as to competency, relevancy, materiality and 

admissibility of the subject matter of the discovery topics; all objections as to 

vagueness, ambiguity, or undue burden; all objections on any ground as to the use 

of any information provided in response to these discovery topics; and all 

objections on any ground to any topic for further responses to these or other 

discovery topics.

7. Responding Party does not waive any right to make and preserves any 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 39 of 129
objections to the questions asked at deposition or to instruct a witness not to 

answer any question.

8. Responding Party objects to the definition of “Responding Party Trust” to 

include the various different entities referenced in the definition. The only 

appropriate entity for anything related to WSOU is “Responding Party Trust, 

Series SPL-VI.”

9. Responding Party objects to Definition 4 which seeks to define various 

different entities in an overbroad fashion. Specifically, Responding Party objects 

to the part of the definition extends to include “Basepoint Administrative LLC and 

BP Funding Trust, a Delaware statutory trust; BP Funding Trust, Series SPL-VI, a 

statutory series of BP Funding Trust; and their trustees, managers, agents, 

representatives, employees, attorneys, or entities acting in conjunction, joint 

venture, or partnership with any of them including but not limited to Basepoint 

Capital LLC, Basepoint Tax Funding Trust, Venture 4th Basepoint 1, LLC, 

Basepoint Administrative LLC, Basepoint Asset Recovery LLC, or any other 

“Basepoint” entity or related entity thereto.”

10. Responding Party objects to Definitions 5 through 15, and 17, all of 

which seek to define various different entities in an overbroad

fashion. Specifically, Responding Party objects to the part of the definition 

extends to include “any other persons acting on behalf of any of the foregoing, and 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 40 of 129
any other entities that own or control or are owned or controlled by or share 

common ownership or control with any of the foregoing, as well as predecessors 

and successors in interest to such entities” for each entity, and to the part of the 

definition that extends to “affiliates” of the entity, a term which is itself defined in 

overbroad fashion at number 17.

11. Responding Party objects to Definition 16 (“asserted patents”) as vague 

and overbroad, to the extent that it includes asserted patents beyond the particular 

patents specifically referenced.

12. Responding Party objects to Definitions 18 (“related application”), 19 

(“related patent”), 21 (“accused product”), and 22 (“asserted claim”) as vague and 

overbroad.

13. Responding Party objects to Definition 33 (“Other WSOU Defendants”) 

as vague and overbroad, to the extent that it includes defendants other than those 

particular defendants specifically referenced.

14. Responding Party objects to the “Instructions” to the extent they purport 

to request anything of a non-party that goes beyond what is required or allowed 

under Federal Rule of Civil Procedure 45.

SPECIFIC OBJECTIONS TO INDIVIDUAL TOPICS FOR DEPOSITION

1. Objection. Responding Party objects on the grounds this topic is overly 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 41 of 129
broad and unduly burdensome. Responding Party objects further on the grounds 

this topic is oppressive, burdensome and harassing as the information can be 

sought from a party or other source without the need to seek information from this 

non-party witness. Responding Party objects to this topic to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

2. Objection. Responding Party objects on the grounds this topic is overly 

broad and unduly burdensome. Responding Party objects further on the grounds 

this topic is oppressive, burdensome and harassing as the information can be 

sought from a party or other source without the need to seek information from this 

non-party witness. Responding Party objects to this topic to the extent it seeks 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 42 of 129
information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

3. Objection. Responding Party objects to this topic on the grounds it is 

overly broad and unduly burdensome. Responding Party objects to this topic to the 

extent it seeks information protected from disclosure by the attorney-client 

privilege and/or attorney work product doctrine. Responding Party further objects 

the extent it calls for the disclosure of non-public, private, personal, confidential, 

proprietary information, or trade secret information that has been maintained in 

confidence and/or is legally required to be maintained in confidence, including, but 

not limited to, information that is shielded from production by statutory or 

decisional law of the United States and each of its jurisdictions, statutory or 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 43 of 129
decisional law of any foreign country, the right of privacy under the United States 

Constitution, and all other applicable laws or privileges. Responding Party further 

objects to the extent it seeks information that is not relevant to the relevant to any 

party’s claim or defense, nor proportional to the needs of the case.

4. Objection. Responding Party objects to this topic on the grounds it is 

vague, ambiguous and unintelligible as to the term “your relationship”. 

Responding Party objects on the grounds this topic is overly broad and unduly 

burdensome. Responding Party objects further on the grounds this topic is 

oppressive, burdensome and harassing as the information can be sought from a 

party or other source without the need to seek information from this non-party 

witness. Responding Party further objects to this topic to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 44 of 129
it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

5. Objection. Responding Party objects to this topic to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

6. Objection. Responding Party objects on the grounds this topic is overly 

broad and unduly burdensome. Responding Party objects further on the grounds 

this topic is oppressive, burdensome and harassing as the information can be 

sought from a party or other source without the need to seek information from this 

non-party witness. Responding Party objects to this topic to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 45 of 129
attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

7. Objection. Responding Party objects on the grounds this topic is overly 

broad and unduly burdensome. Responding Party objects further on the grounds 

this topic is oppressive, burdensome and harassing as the information can be 

sought from a party or other source without the need to seek information from this 

non-party witness. Responding Party objects to this topic to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 46 of 129
to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

8. Objection. Responding Party objects on the grounds this topic is overly

broad and unduly burdensome. Responding Party objects further on the grounds 

this topic is oppressive, burdensome and harassing as the information can be 

sought from a party or other source without the need to seek information from this 

non-party witness. Responding Party objects to this topic to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 47 of 129
it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

9. Objection. Responding Party objects on the grounds this topic is overly

broad and unduly burdensome. Responding Party objects further on the grounds 

this topic is oppressive, burdensome and harassing as the information can be 

sought from a party or other source without the need to seek information from this 

non-party witness. Responding Party objects to this topic to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

10. Objection. Responding Party objects on the grounds this topic is overly

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 48 of 129
broad and unduly burdensome. Responding Party objects further on the grounds 

this topic is oppressive, burdensome and harassing as the information can be 

sought from a party or other source without the need to seek information from this 

non-party witness. Responding Party objects to this topic to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

11. Objection. Responding Party objects on the grounds this topic is 

vague, ambiguous and unintelligible as to the phrases/terms “Compensation, costsharing, or profit sharing agreements.” Responding Party objects further on the 

grounds this topic is oppressive, burdensome and harassing as the information can 

be sought from a party or other source without the need to seek information from 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 49 of 129
this non-party witness. Responding Party objects to this topic to the extent it 

seeks information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

12. Objection. Responding Party objects on the grounds this topic is 

vague, ambiguous and unintelligible as to the phrases/terms “Compensation, costsharing, or profit sharing agreements.” Responding Party objects further on the 

grounds this topic is oppressive, burdensome and harassing as the information can 

be sought from a party or other source without the need to seek information from 

this non-party witness. Responding Party objects to this topic to the extent it 

seeks information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 50 of 129
for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

13. Objection. Responding Party objects on the grounds this topic is overly 

broad and unduly burdensome. Responding Party objects further on the grounds 

this topic is oppressive, burdensome and harassing as the information can be 

sought from a party or other source without the need to seek information from this 

non-party witness. Responding Party objects to this topic to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 51 of 129
the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

14. Objection. Responding Party objects on the grounds this topic is overly 

broad and unduly burdensome. Responding Party objects further on the grounds 

this topic is oppressive, burdensome and harassing as the information can be 

sought from a party or other source without the need to seek information from this 

non-party witness. Responding Party objects to this topic to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 52 of 129
it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

15. Objection. Responding Party objects on the grounds this topic is overly 

broad and unduly burdensome. Responding Party objects further on the grounds 

this topic is oppressive, burdensome and harassing as the information can be 

sought from a party or other source without the need to seek information from this 

non-party witness. Responding Party objects to this topic to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

16. Objection. Responding Party objects on the grounds this topic is overly 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 53 of 129
broad and unduly burdensome. Responding Party objects further on the grounds 

this topic is oppressive, burdensome and harassing as the information can be 

sought from a party or other source without the need to seek information from this 

non-party witness. Responding Party objects to this topic to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

17. Objection. Responding Party objects on the grounds this topic is 

overly broad and unduly burdensome. Responding Party objects further on the 

grounds this topic is oppressive, burdensome and harassing as the information can 

be sought from a party or other source without the need to seek information from 

this non-party witness. Responding Party objects to this topic to the extent it 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 54 of 129
seeks information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

18. Objection. Responding Party objects on the grounds this topic is vague, 

ambiguous and unintelligible. Responding Party further objects on the grounds 

that this topic overly broad and unduly burdensome. Responding Party objects on 

the grounds this topic is oppressive, burdensome and harassing as the information

can be sought from a party or other source without the need to seek information

from this non-party witness. Responding Party objects to this topic to the extent it 

seeks information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 55 of 129
information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

19. Objection. Responding Party objects on the grounds this topic is 

vague, ambiguous and unintelligible. Responding Party further objects on the 

grounds that this topic overly broad and unduly burdensome. Responding Party

objects on the grounds this topic is oppressive, burdensome and harassing as the 

information can be sought from a party or other source without the need to seek 

information from this non-party witness. Responding Party objects to this topic to 

the extent it seeks information protected from disclosure by the attorney-client 

privilege and/or attorney work product doctrine. Responding Party further objects 

the extent it calls for the disclosure of non-public, private, personal, confidential, 

proprietary information, or trade secret information that has been maintained in 

confidence and/or is legally required to be maintained in confidence, including, but 

not limited to, information that is shielded from production by statutory or 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 56 of 129
decisional law of the United States and each of its jurisdictions, statutory or 

decisional law of any foreign country, the right of privacy under the United States 

Constitution, and all other applicable laws or privileges. Responding Party further 

objects to the extent it seeks information that is not relevant to the relevant to any 

party’s claim or defense, nor proportional to the needs of the case.

20. Objection. Responding Party objects on the grounds this topic is overly 

broad and unduly burdensome. Responding Party objects further on the grounds 

this topic is oppressive, burdensome and harassing as the information can be 

sought from a party or other source without the need to seek information from this 

non-party witness. Responding Party objects to this topic to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 57 of 129
it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

21. Objection. Responding Party objects on the grounds this topic is 

oppressive, burdensome and harassing as the information can be sought from a 

party or other source without the need to seek information from this non-party 

witness. Responding Party objects to this topic to the extent it seeks information 

protected from disclosure by the attorney-client privilege and/or attorney work 

product doctrine. Responding Party further objects the extent it calls for the 

disclosure of non-public, private, personal, confidential, proprietary information, or 

trade secret information that has been maintained in confidence and/or is legally 

required to be maintained in confidence, including, but not limited to, information 

that is shielded from production by statutory or decisional law of the United States 

and each of its jurisdictions, statutory or decisional law of any foreign country, the 

right of privacy under the United States Constitution, and all other applicable laws 

or privileges. Responding Party further objects to the extent it seeks information 

that is not relevant to the relevant to any party’s claim or defense, nor proportional 

to the needs of the case.

22. Objection. Responding Party objects on the grounds this topic is 

oppressive, burdensome and harassing as the information can be sought from a 

party or other source without the need to seek information from this non-party 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 58 of 129
witness. Responding Party objects to this topic to the extent it seeks information 

protected from disclosure by the attorney-client privilege and/or attorney work 

product doctrine. Responding Party further objects the extent it calls for the 

disclosure of non-public, private, personal, confidential, proprietary information, or 

trade secret information that has been maintained in confidence and/or is legally 

required to be maintained in confidence, including, but not limited to, information 

that is shielded from production by statutory or decisional law of the United States 

and each of its jurisdictions, statutory or decisional law of any foreign country, the 

right of privacy under the United States Constitution, and all other applicable laws 

or privileges. Responding Party further objects to the extent it seeks information 

that is not relevant to the relevant to any party’s claim or defense, nor proportional 

to the needs of the case.

23. Objection. Responding Party objects on the grounds this topic is 

oppressive, burdensome and harassing as the information can be sought from a 

party or other source without the need to seek information from this non-party 

witness. Responding Party objects to this topic to the extent it seeks information 

protected from disclosure by the attorney-client privilege and/or attorney work 

product doctrine. Responding Party further objects the extent it calls for the 

disclosure of non-public, private, personal, confidential, proprietary information, or 

trade secret information that has been maintained in confidence and/or is legally 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 59 of 129
required to be maintained in confidence, including, but not limited to, information 

that is shielded from production by statutory or decisional law of the United States 

and each of its jurisdictions, statutory or decisional law of any foreign country, the 

right of privacy under the United States Constitution, and all other applicable laws 

or privileges. Responding Party further objects to the extent it seeks information 

that is not relevant to the relevant to any party’s claim or defense, nor proportional 

to the needs of the case.

24. Objection. Responding Party objects on the grounds this topic is 

oppressive, burdensome and harassing as the information can be sought from a 

party or other source without the need to seek information from this non-party 

witness. Responding Party objects to this topic to the extent it seeks information 

protected from disclosure by the attorney-client privilege and/or attorney work 

product doctrine. Responding Party further objects the extent it calls for the 

disclosure of non-public, private, personal, confidential, proprietary information, or 

trade secret information that has been maintained in confidence and/or is legally 

required to be maintained in confidence, including, but not limited to, information 

that is shielded from production by statutory or decisional law of the United States 

and each of its jurisdictions, statutory or decisional law of any foreign country, the 

right of privacy under the United States Constitution, and all other applicable laws 

or privileges. Responding Party further objects to the extent it seeks information 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 60 of 129
that is not relevant to the relevant to any party’s claim or defense, nor proportional 

to the needs of the case.

25. Objection. Responding Party objects on the grounds this topic is 

oppressive, burdensome and harassing as the information can be sought from a 

party or other source without the need to seek information from this non-party 

witness. Responding Party objects to this topic to the extent it seeks information 

protected from disclosure by the attorney-client privilege and/or attorney work 

product doctrine. Responding Party further objects the extent it calls for the 

disclosure of non-public, private, personal, confidential, proprietary information, or 

trade secret information that has been maintained in confidence and/or is legally 

required to be maintained in confidence, including, but not limited to, information 

that is shielded from production by statutory or decisional law of the United States 

and each of its jurisdictions, statutory or decisional law of any foreign country, the 

right of privacy under the United States Constitution, and all other applicable laws 

or privileges. Responding Party further objects to the extent it seeks information 

that is not relevant to the relevant to any party’s claim or defense, nor proportional 

to the needs of the case.

26. Objection. Responding Party objects on the grounds this topic is 

oppressive, burdensome and harassing as the information can be sought from a 

party or other source without the need to seek information from this non-party 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 61 of 129
witness. Responding Party objects to this topic to the extent it seeks information 

protected from disclosure by the attorney-client privilege and/or attorney work 

product doctrine. Responding Party further objects the extent it calls for the 

disclosure of non-public, private, personal, confidential, proprietary information, or 

trade secret information that has been maintained in confidence and/or is legally 

required to be maintained in confidence, including, but not limited to, information 

that is shielded from production by statutory or decisional law of the United States 

and each of its jurisdictions, statutory or decisional law of any foreign country, the 

right of privacy under the United States Constitution, and all other applicable laws 

or privileges. Responding Party further objects to the extent it seeks information 

that is not relevant to the relevant to any party’s claim or defense, nor proportional 

to the needs of the case.

27. Objection. Responding Party objects on the grounds this topic is 

oppressive, burdensome and harassing as the information can be sought from a 

party or other source without the need to seek information from this non-party 

witness. Responding Party objects to this topic to the extent it seeks information 

protected from disclosure by the attorney-client privilege and/or attorney work 

product doctrine. Responding Party further objects the extent it calls for the 

disclosure of non-public, private, personal, confidential, proprietary information, or 

trade secret information that has been maintained in confidence and/or is legally 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 62 of 129
required to be maintained in confidence, including, but not limited to, information 

that is shielded from production by statutory or decisional law of the United States 

and each of its jurisdictions, statutory or decisional law of any foreign country, the 

right of privacy under the United States Constitution, and all other applicable laws 

or privileges. Responding Party further objects to the extent it seeks information 

that is not relevant to the relevant to any party’s claim or defense, nor proportional 

to the needs of the case.

28. Objection. Responding Party objects on the grounds this topic is 

overly broad and unduly burdensome. Responding Party objects further on the 

grounds this topic is oppressive, burdensome and harassing as the information can 

be sought from a party or other source without the need to seek information from 

this non-party witness. Responding Party objects to this topic to the extent it 

seeks information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 63 of 129
other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

29. Objection. Responding Party objects on the grounds this topic is overly 

broad and unduly burdensome. Responding Party objects further on the grounds 

this topic is oppressive, burdensome and harassing as the information can be 

sought from a party or other source without the need to seek information from this 

non-party witness. Responding Party objects to this topic to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 64 of 129
foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

Date: October 19, 2021 /s/ Morgan E. Pietz

Morgan E. Pietz (CA Bar #260629)*

Pietz & Shahriari, LLP

9454 Wilshire Blvd., Suite 310

Beverly Hills, CA 90212

Counsel for BP Funding Trust

Sean J. Bellew (#4072)

Bellew LLC

2961 Centerville Road, Suite 302

Wilmington, Delaware 19808

Telephone: (302) 353-4951

sjbellew@bellewllc.com

Counsel for BP Funding Trust

*Pro Hac Vice application is forthcoming.

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 65 of 129
1

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF DELAWARE

GOOGLE LLC,

Plaintiff(s),

v.

TERRIER SSC, LLC,

Defendant(s).

:

:

:

:

:

:

:

:

:

:

:

:

C.A. No. 1:21-mc-419-UNA

OBJECTION TO SUBPOENA TO TESTIFY AT A DEPOSITION IN A 

CIVIL ACTION

TO: ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

PLEASE TAKE NOTICE THAT non-party witness Terrier SSC, LLC

(“Responding Party”), pursuant to Fed. R. Civ. P. 45(d)(B), hereby objects to the 

subpoena to testify at a deposition in a civil action as follows:

GENERAL OBJECTIONS

Responding Party makes the following General Objections to the Subpoena 

to Testify at a Deposition in a Civil Action, Topics for Deposition Nos. 1-30. 

These General Objections are incorporated into the specific objections to each 

topic. The assertion of the same or additional objections to any individual Topic

does not waive other General Objections that are not repeated in the specific 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 66 of 129
2

objections. The objections and responses set forth below are based on information 

currently available to Responding Party: 

1. Responding Party objects to each and every Topic to the extent that it 

seeks information protected by the attorney-client privilege, attorney work product 

doctrine, joint defense agreement and/or taxpayer/tax return privilege. 

2. Responding Party further objects to each topic to the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. 

3. Responding Party objects to each topic to the extent that it seeks 

production of information that is neither relevant to the subject matter of this action 

nor reasonably calculated to lead to the discovery of admissible evidence. Google 

LLC (“Propounding Party”) failed to take reasonable steps to avoid imposing 

undue burden or expense on Responding Party in violation of Federal Rules of 

Civil Procedure, Rule 45(d)(1).

4. Responding Party objects to each topic to the extent that it the 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 67 of 129
3

information sought can be obtained through party discovery or other sources 

without the need to seek information from non-party witness Responding Party. 

5. Responding Party objects to each of Propounding Party’s definitions as 

overbroad, oppressive, unduly burdensome, unnecessarily expensive, and not

proportional to the needs of the case, considering the importance of the issues at 

stake in the action, the amount in controversy, the parties’ relative access to 

relevant information, the importance of the discovery in resolving the issues, and 

whether the burden or expense of the proposed discovery outweighs its likely 

benefits. Responding Party further objects to the extent that any definition attempts 

to impose any obligations upon Responding Party greater than those authorized by 

the Federal Rules of Civil Procedure, Local Rules, or any other applicable law, and 

also as, vague, ambiguous, unclear, or unintelligible. 

6. Nothing herein is intended to waive the following objections, which are 

expressly reserved: All objections as to competency, relevancy, materiality and 

admissibility of the subject matter of the discovery topics; all objections as to 

vagueness, ambiguity, or undue burden; all objections on any ground as to the use 

of any information provided in response to these discovery topics; and all 

objections on any ground to any topic for further responses to these or other 

discovery topics.

7. Responding Party does not waive any right to make and preserves any 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 68 of 129
4

objections to the questions asked at deposition or to instruct a witness not to 

answer any question.

8. Responding Party objects to the definition of “Responding Party Trust” to 

include the various different entities referenced in the definition. The only 

appropriate entity for anything related to WSOU is “Responding Party Trust, 

Series SPL-VI.”

9. Responding Party objects to Definitions 4 through 15, and 17, all of 

which seek to define various different entities in an overbroad 

fashion. Specifically, Responding Party objects to the part of the definition 

extends to include “any other persons acting on behalf of any of the foregoing, and 

any other entities that own or control or are owned or controlled by or share 

common ownership or control with any of the foregoing, as well as predecessors 

and successors in interest to such entities” for each entity, and to the part of the 

definition that extends to “affiliates” of the entity, a term which is itself defined in 

overbroad fashion at number 17.

10. Responding Party objects to Definition 16 (“asserted patents”) as vague 

and overbroad, to the extent that it includes asserted patents beyond the particular 

patents specifically referenced.

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 69 of 129
5

11. Responding Party objects to Definitions 18 (“related application”), 19 

(“related patent”), 21 (“accused product”), and 22 (“asserted claim”) as vague and 

overbroad.

12. Responding Party objects to Definition 33 (“Other WSOU Defendants”) 

as vague and overbroad, to the extent that it includes defendants other than those 

particular defendants specifically referenced.

13. Responding Party objects to the “Instructions” to the extent they purport 

to request anything of a non-party that goes beyond what is required or allowed 

under Federal Rule of Civil Procedure 45.

SPECIFIC OBJECTIONS TO INDIVIDUAL TOPICS FOR DEPOSITION

1. Objection. Responding Party objects to this topic on the grounds it is

overly broad and unduly burdensome. Responding Party objects further on the 

grounds this topic is oppressive, burdensome and harassing as the information can 

be sought from a party or other source without the need to seek information from 

this non-party witness. Responding Party objects to this topic to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 70 of 129
6

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

2. Objection. Responding Party objects to this topic on the grounds it is 

overly broad and unduly burdensome. Responding Party objects further on the 

grounds this topic is oppressive, burdensome and harassing as the information can 

be sought from a party or other source without the need to seek information from 

this non-party witness. Responding Party objects to this topic to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 71 of 129
7

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

3. Objection. Responding Party objects to this topic on the grounds it is 

overly broad and unduly burdensome. Responding Party objects to this topic to the 

extent it seeks information protected from disclosure by the attorney-client 

privilege and/or attorney work product doctrine. Responding Party further objects 

the extent it calls for the disclosure of non-public, private, personal, confidential,

proprietary information, or trade secret information that has been maintained in 

confidence and/or is legally required to be maintained in confidence, including, but 

not limited to, information that is shielded from production by statutory or 

decisional law of the United States and each of its jurisdictions, statutory or 

decisional law of any foreign country, the right of privacy under the United States 

Constitution, and all other applicable laws or privileges. Responding Party further 

objects to the extent it seeks information that is not relevant to the relevant to any 

party’s claim or defense, nor proportional to the needs of the case.

4. Objection. Responding Party objects to this topic on the grounds it is 

overly broad and unduly burdensome. Responding Party objects further on the 

grounds this topic is oppressive, burdensome and harassing as the information can 

be sought from a party or other source without the need to seek information from 

this non-party witness. Responding Party further objects to this topic to the extent 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 72 of 129
8

it seeks information protected from disclosure by the attorney-client privilege 

and/or attorney work product doctrine. Responding Party further objects the extent 

it calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

5. Objection. Responding Party objects to this topic on the grounds it is 

overly broad and unduly burdensome. Responding Party objects to this topic to the 

extent it seeks information protected from disclosure by the attorney-client 

privilege and/or attorney work product doctrine. Responding Party further objects 

the extent it calls for the disclosure of non-public, private, personal, confidential, 

proprietary information, or trade secret information that has been maintained in 

confidence and/or is legally required to be maintained in confidence, including, but 

not limited to, information that is shielded from production by statutory or 

decisional law of the United States and each of its jurisdictions, statutory or 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 73 of 129
9

decisional law of any foreign country, the right of privacy under the United States 

Constitution, and all other applicable laws or privileges. Responding Party further 

objects to the extent it seeks information that is not relevant to the relevant to any 

party’s claim or defense, nor proportional to the needs of the case.

6. Objection. Responding Party objects on the grounds this topic is overly 

broad and unduly burdensome. Responding Party objects to this topic to the extent 

it seeks information protected from disclosure by the attorney-client privilege 

and/or attorney work product doctrine. Responding Party further objects the extent 

it calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

7. Objection. Responding Party objects on the grounds this topic is overly 

broad and unduly burdensome. Responding Party objects further on the grounds 

this topic is oppressive, burdensome and harassing as the information can be 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 74 of 129
10

sought from a party or other source without the need to seek information from this 

non-party witness. Responding Party objects to this topic to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

8. Objection. Responding Party objects on the grounds this topic is overly

broad and unduly burdensome. Responding Party objects further on the grounds 

this topic is oppressive, burdensome and harassing as the information can be 

sought from a party or other source without the need to seek information from this 

non-party witness. Responding Party objects to this topic to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 75 of 129
11

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

9. Objection. Responding Party objects on the grounds this topic is overly

broad and unduly burdensome. Responding Party objects further on the grounds 

this topic is oppressive, burdensome and harassing as the information can be 

sought from a party or other source without the need to seek information from this 

non-party witness. Responding Party objects to this topic to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 76 of 129
12

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

10. Objection. Responding Party objects on the grounds this topic is overly

broad and unduly burdensome. Responding Party objects further on the grounds 

this topic is oppressive, burdensome and harassing as the information can be 

sought from a party or other source without the need to seek information from this 

non-party witness. Responding Party objects to this topic to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 77 of 129
13

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

11. Objection. Responding Party objects on the grounds this topic is 

vague, ambiguous and unintelligible as to the phrases/terms “Compensation, costsharing, or profit sharing agreements.” Responding Party objects further on the 

grounds this topic is oppressive, burdensome and harassing as the information can 

be sought from a party or other source without the need to seek information from 

this non-party witness. Responding Party objects to this topic to the extent it 

seeks information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

12. Objection. Responding Party objects on the grounds this topic is 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 78 of 129
14

vague, ambiguous and unintelligible as to the phrases/terms “Compensation, costsharing, or profit sharing agreements.” Responding Party objects further on the 

grounds this topic is oppressive, burdensome and harassing as the information can 

be sought from a party or other source without the need to seek information from 

this non-party witness. Responding Party objects to this topic to the extent it 

seeks information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

13. Objection. Responding Party objects on the grounds this topic is overly 

broad and unduly burdensome. Responding Party objects further on the grounds 

this topic is oppressive, burdensome and harassing as the information can be 

sought from a party or other source without the need to seek information from this 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 79 of 129
15

non-party witness. Responding Party objects to this topic to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

14. Objection. Responding Party objects on the grounds this topic is overly 

broad and unduly burdensome. Responding Party objects further on the grounds 

this topic is oppressive, burdensome and harassing as the information can be 

sought from a party or other source without the need to seek information from this 

non-party witness. Responding Party objects to this topic to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 80 of 129
16

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

15. Objection. Responding Party objects on the grounds this topic is overly 

broad and unduly burdensome. Responding Party objects further on the grounds 

this topic is oppressive, burdensome and harassing as the information can be 

sought from a party or other source without the need to seek information from this 

non-party witness. Responding Party objects to this topic to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 81 of 129
17

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

16. Objection. Responding Party objects on the grounds this topic is overly 

broad and unduly burdensome. Responding Party objects further on the grounds 

this topic is oppressive, burdensome and harassing as the information can be 

sought from a party or other source without the need to seek information from this 

non-party witness. Responding Party objects to this topic to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 82 of 129
18

17. Objection. Responding Party objects on the grounds this topic is 

overly broad and unduly burdensome. Responding Party objects further on the 

grounds this topic is oppressive, burdensome and harassing as the information can 

be sought from a party or other source without the need to seek information from 

this non-party witness. Responding Party objects to this topic to the extent it 

seeks information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

18. Objection. Responding Party objects on the grounds this topic is vague, 

ambiguous and unintelligible. Responding Party further objects on the grounds 

that this topic overly broad and unduly burdensome. Responding Party objects on 

the grounds this topic is oppressive, burdensome and harassing as the information

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 83 of 129
19

can be sought from a party or other source without the need to seek information

from this non-party witness. Responding Party objects to this topic to the extent it 

seeks information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

19. Objection. Responding Party objects on the grounds this topic is 

vague, ambiguous and unintelligible. Responding Party further objects on the 

grounds that this topic overly broad and unduly burdensome. Responding Party

objects on the grounds this topic is oppressive, burdensome and harassing as the 

information can be sought from a party or other source without the need to seek 

information from this non-party witness. Responding Party objects to this topic to 

the extent it seeks information protected from disclosure by the attorney-client 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 84 of 129
20

privilege and/or attorney work product doctrine. Responding Party further objects 

the extent it calls for the disclosure of non-public, private, personal, confidential, 

proprietary information, or trade secret information that has been maintained in 

confidence and/or is legally required to be maintained in confidence, including, but 

not limited to, information that is shielded from production by statutory or 

decisional law of the United States and each of its jurisdictions, statutory or 

decisional law of any foreign country, the right of privacy under the United States 

Constitution, and all other applicable laws or privileges. Responding Party further 

objects to the extent it seeks information that is not relevant to the relevant to any 

party’s claim or defense, nor proportional to the needs of the case.

20. Objection. Responding Party objects on the grounds this topic is overly 

broad and unduly burdensome. Responding Party objects further on the grounds 

this topic is oppressive, burdensome and harassing as the information can be 

sought from a party or other source without the need to seek information from this 

non-party witness. Responding Party objects to this topic to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 85 of 129
21

to, information that is shielded from production by statutory or decisional law of

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

21. Objection. Responding Party objects on the grounds this topic is 

oppressive, burdensome and harassing as the information can be sought from a 

party or other source without the need to seek information from this non-party 

witness. Responding Party objects to this topic to the extent it seeks information 

protected from disclosure by the attorney-client privilege and/or attorney work 

product doctrine. Responding Party further objects the extent it calls for the 

disclosure of non-public, private, personal, confidential, proprietary information, or 

trade secret information that has been maintained in confidence and/or is legally 

required to be maintained in confidence, including, but not limited to, information 

that is shielded from production by statutory or decisional law of the United States 

and each of its jurisdictions, statutory or decisional law of any foreign country, the 

right of privacy under the United States Constitution, and all other applicable laws 

or privileges. Responding Party further objects to the extent it seeks information 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 86 of 129
22

that is not relevant to the relevant to any party’s claim or defense, nor proportional 

to the needs of the case.

22. Objection. Responding Party objects on the grounds this topic is 

oppressive, burdensome and harassing as the information can be sought from a 

party or other source without the need to seek information from this non-party 

witness. Responding Party objects to this topic to the extent it seeks information 

protected from disclosure by the attorney-client privilege and/or attorney work 

product doctrine. Responding Party further objects the extent it calls for the 

disclosure of non-public, private, personal, confidential, proprietary information, or 

trade secret information that has been maintained in confidence and/or is legally 

required to be maintained in confidence, including, but not limited to, information 

that is shielded from production by statutory or decisional law of the United States 

and each of its jurisdictions, statutory or decisional law of any foreign country, the 

right of privacy under the United States Constitution, and all other applicable laws 

or privileges. Responding Party further objects to the extent it seeks information 

that is not relevant to the relevant to any party’s claim or defense, nor proportional 

to the needs of the case.

23. Objection. Responding Party objects on the grounds this topic is 

oppressive, burdensome and harassing as the information can be sought from a 

party or other source without the need to seek information from this non-party 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 87 of 129
23

witness. Responding Party objects to this topic to the extent it seeks information 

protected from disclosure by the attorney-client privilege and/or attorney work 

product doctrine. Responding Party further objects the extent it calls for the 

disclosure of non-public, private, personal, confidential, proprietary information, or 

trade secret information that has been maintained in confidence and/or is legally 

required to be maintained in confidence, including, but not limited to, information 

that is shielded from production by statutory or decisional law of the United States 

and each of its jurisdictions, statutory or decisional law of any foreign country, the 

right of privacy under the United States Constitution, and all other applicable laws 

or privileges. Responding Party further objects to the extent it seeks information 

that is not relevant to the relevant to any party’s claim or defense, nor proportional 

to the needs of the case.

24. Objection. Responding Party objects on the grounds this topic is 

oppressive, burdensome and harassing as the information can be sought from a 

party or other source without the need to seek information from this non-party 

witness. Responding Party objects to this topic to the extent it seeks information 

protected from disclosure by the attorney-client privilege and/or attorney work 

product doctrine. Responding Party further objects the extent it calls for the 

disclosure of non-public, private, personal, confidential, proprietary information, or 

trade secret information that has been maintained in confidence and/or is legally 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 88 of 129
24

required to be maintained in confidence, including, but not limited to, information 

that is shielded from production by statutory or decisional law of the United States 

and each of its jurisdictions, statutory or decisional law of any foreign country, the 

right of privacy under the United States Constitution, and all other applicable laws 

or privileges. Responding Party further objects to the extent it seeks information 

that is not relevant to the relevant to any party’s claim or defense, nor proportional 

to the needs of the case.

25. Objection. Responding Party objects on the grounds this topic is 

oppressive, burdensome and harassing as the information can be sought from a 

party or other source without the need to seek information from this non-party 

witness. Responding Party objects to this topic to the extent it seeks information 

protected from disclosure by the attorney-client privilege and/or attorney work 

product doctrine. Responding Party further objects the extent it calls for the 

disclosure of non-public, private, personal, confidential, proprietary information, or 

trade secret information that has been maintained in confidence and/or is legally 

required to be maintained in confidence, including, but not limited to, information 

that is shielded from production by statutory or decisional law of the United States 

and each of its jurisdictions, statutory or decisional law of any foreign country, the 

right of privacy under the United States Constitution, and all other applicable laws 

or privileges. Responding Party further objects to the extent it seeks information 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 89 of 129
25

that is not relevant to the relevant to any party’s claim or defense, nor proportional 

to the needs of the case.

26. Objection. Responding Party objects on the grounds this topic is 

oppressive, burdensome and harassing as the information can be sought from a 

party or other source without the need to seek information from this non-party 

witness. Responding Party objects to this topic to the extent it seeks information 

protected from disclosure by the attorney-client privilege and/or attorney work 

product doctrine. Responding Party further objects the extent it calls for the 

disclosure of non-public, private, personal, confidential, proprietary information, or 

trade secret information that has been maintained in confidence and/or is legally 

required to be maintained in confidence, including, but not limited to, information 

that is shielded from production by statutory or decisional law of the United States 

and each of its jurisdictions, statutory or decisional law of any foreign country, the 

right of privacy under the United States Constitution, and all other applicable laws 

or privileges. Responding Party further objects to the extent it seeks information 

that is not relevant to the relevant to any party’s claim or defense, nor proportional 

to the needs of the case.

27. Objection. Responding Party objects on the grounds this topic is 

oppressive, burdensome and harassing as the information can be sought from a 

party or other source without the need to seek information from this non-party 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 90 of 129
26

witness. Responding Party objects to this topic to the extent it seeks information 

protected from disclosure by the attorney-client privilege and/or attorney work 

product doctrine. Responding Party further objects the extent it calls for the 

disclosure of non-public, private, personal, confidential, proprietary information, or 

trade secret information that has been maintained in confidence and/or is legally 

required to be maintained in confidence, including, but not limited to, information 

that is shielded from production by statutory or decisional law of the United States 

and each of its jurisdictions, statutory or decisional law of any foreign country, the 

right of privacy under the United States Constitution, and all other applicable laws 

or privileges. Responding Party further objects to the extent it seeks information 

that is not relevant to the relevant to any party’s claim or defense, nor proportional 

to the needs of the case.

28. Objection. Responding Party objects on the grounds this topic is 

overly broad and unduly burdensome. Responding Party objects further on the 

grounds this topic is oppressive, burdensome and harassing as the information can 

be sought from a party or other source without the need to seek information from 

this non-party witness. Responding Party objects to this topic to the extent it 

seeks information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 91 of 129
27

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

29. Objection. Responding Party objects on the grounds this topic is overly 

broad and unduly burdensome. Responding Party objects further on the grounds 

this topic is oppressive, burdensome and harassing as the information can be 

sought from a party or other source without the need to seek information from this 

non-party witness. Responding Party objects to this topic to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 92 of 129
28

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

30. Objection. Responding Party objects on the grounds this topic is overly 

broad and unduly burdensome. Responding Party objects further on the grounds 

this topic is oppressive, burdensome and harassing as the information can be 

sought from a party or other source without the need to seek information from this 

non-party witness. Responding Party objects to this topic to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, information that is shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 93 of 129
29

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

Date: October 19, 2021 /s/ Morgan E. Pietz

Morgan E. Pietz (CA Bar #260629)*

Pietz & Shahriari, LLP

9454 Wilshire Blvd., Suite 310

Beverly Hills, CA 90212

Counsel for Terrier SSC, LLC

Sean J. Bellew (#4072)

Bellew LLC

2961 Centerville Road, Suite 302

Wilmington, Delaware 19808

Telephone: (302) 353-4951

sjbellew@bellewllc.com

Counsel for Terrier SSC, LLC

*Pro Hac Vice application is forthcoming.

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 94 of 129
1

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF DELAWARE

GOOGLE LLC,

Plaintiff(s),

v.

TERRIER SSC, LLC,

Defendant(s).

:

:

:

:

:

:

:

:

:

:

:

:

C.A. No. 21-MC-419UNA

OBJECTION TO SUBPOENA TO PRODUCE DOCUMENTS, 

INFORMATION, OR OBJECTS OR TO PERMIT INSPECTION OF 

PREMISES IN CIVIL ACTION

TO: ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

PLEASE TAKE NOTICE THAT non-party witness Terrier SSC, LLC

(“Responding Party”), pursuant to Fed. R. Civ. P. 45(d)(B), hereby objects to the 

subpoena to produce documents, information, or objects or to permit inspection of 

premises in a civil action as follows:

GENERAL OBJECTIONS

Responding Party makes the following General Objections to the Subpoena 

to Produce Documents, Information, or Objects or To Permit Inspection of 

Premises in a Civil Action, Request Nos. 1-28. These General Objections are 

incorporated into the specific objections to each Request. The assertion of the same 

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or additional objections to any individual Request does not waive other General 

Objections that are not repeated in the specific objections. The objections and 

responses set forth below are based on information currently available to 

Responding Party: 

1. Responding Party objects to each and every Request to the extent that it 

seeks information protected by the attorney-client privilege, attorney work product 

doctrine, joint defense agreement and/or taxpayer/tax return privilege. 

2. Responding Party further objects to each request to the extent it calls 

for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. 

3. Responding Party objects to each request to the extent that it seeks 

production of documents that are neither relevant to the subject matter of this 

action nor reasonably calculated to lead to the discovery of admissible evidence.

4. Responding Party objects to each request to the extent that the 

information sought can be obtained through party discovery or other sources 

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without the need to seek documents from non-party witness Responding Party. 

Google LLC (“Propounding Party”) failed to take reasonable steps to avoid 

imposing undue burden or expense on Responding Party in violation of Federal 

Rules of Civil Procedure, Rule 45(d)(1).

5. Responding Party objects to each of Propounding Party’s definitions as 

overbroad, oppressive, unduly burdensome, unnecessarily expensive, and not 

proportional to the needs of the case, considering the importance of the issues at 

stake in the action, the amount in controversy, the parties’ relative access to 

relevant information, the importance of the discovery in resolving the issues, and 

whether the burden or expense of the proposed discovery outweighs its likely 

benefits. Responding Party further objects to the extent that any definition attempts 

to impose any obligations upon Responding Party greater than those authorized by 

the Federal Rules of Civil Procedure, Local Rules, or any other applicable law, and 

also as, vague, ambiguous, unclear, or unintelligible. 

6. Nothing herein is intended to waive the following objections, which are 

expressly reserved: All objections as to competency, relevancy, materiality and 

admissibility of the subject matter of the discovery requests; all objections as to 

vagueness, ambiguity, or undue burden; all objections on any ground as to the use 

of any information provided in response to these discovery requests; and all 

objections on any ground to any request for further responses to these or other 

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discovery requests.

7. Responding Party does not waive any right to make and preserves any 

objections to the questions asked at deposition or to instruct a witness not to 

answer any question.

8. Responding Party objects to the definition of “Responding Party Trust” to 

include the various different entities referenced in the definition. The only 

appropriate entity for anything related to WSOU is “Responding Party Trust, 

Series SPL-VI”

9. Responding Party objects to Definitions 4 through 15, and 17, all of 

which seek to define various different entities in an overbroad

fashion. Specifically, Responding Party objects to the part of the definition 

extends to include “any other persons acting on behalf of any of the foregoing, and 

any other entities that own or control or are owned or controlled by or share 

common ownership or control with any of the foregoing, as well as predecessors 

and successors in interest to such entities” for each entity, and to the part of the 

definition that extends to “affiliates” of the entity, a term which is itself defined in 

overbroad fashion at number 17.

10. Responding Party objects to Definition 16 (“asserted patents”) as vague 

and overbroad, to the extent that it includes asserted patents beyond the particular 

patents specifically referenced.

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11. Responding Party objects to Definitions 18 (“related application”), 19 

(“related patent”), 21 (“accused product”), and 22 (“asserted claim”) as vague and 

overbroad.

12. Responding Party objects to Definition 33 (“Other WSOU Defendants”) 

as vague and overbroad, to the extent that it includes defendants other than those 

particular defendants specifically referenced.

13. Responding Party objects to the “Instructions” to the extent they purport 

to request anything of a non-party that goes beyond what is required or allowed 

under Federal Rule of Civil Procedure 45.

REQUESTS AND OBJECTIONS TO INDIVIDUAL REQUESTS

REQUEST FOR PRODUCTION NO. 1:

Documents concerning the formation of Terrier.

RESPONSE TO REQUEST 1:

Objection. Responding Party objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

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the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to any party’s claim or defense, nor 

proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 2:

Documents concerning your formation of OT WSOU Terrier Holdings, 

LLC.

RESPONSE TO REQUEST 2:

Objection. Responding Party objects on the grounds this request is overly

broad and unduly burdensome. Responding Party objects further on the grounds 

this request is oppressive, burdensome and harassing as the documents requested 

can be sought from a party or other source without the need to seek them from this 

non-party witness.Responding Party further objects to this request to the extent it 

seeks information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

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the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 3:

Documents concerning your corporate structure.

RESPONSE TO REQUEST 3:

Objection. Responding Party objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

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REQUEST FOR PRODUCTION NO. 4:

Documents concerning your investments or interests in the asserted patents, 

including assignment, licensing, acquisition, financial interest, security interest, 

lien, sale, transfer of rights (in whole or in part) and any other disposition of or any 

offers to buy, sell, obtain rights to, or licenses any of the asserted patents.

RESPONSE TO REQUEST 4:

Objection. Responding Party objects on the grounds this request is

overly broad and unduly burdensome. Responding Party objects further on the 

grounds this request is oppressive, burdensome and harassing as the documents 

requested can be sought from a party or other source without the need to seek them 

from this non-party witness. Responding Party objects to this request to the extent 

it seeks information protected from disclosure by the attorney-client privilege 

and/or attorney work product doctrine. Responding Party further objects to the

extent it calls for the disclosure of non-public, private, personal, confidential, 

proprietary information, or trade secret information that has been maintained in 

confidence and/or is legally required to be maintained in confidence, including, but 

not limited to, documents that are shielded from production by statutory or 

decisional law of the United States and each of its jurisdictions, statutory or 

decisional law of any foreign country, the right of privacy under the United States 

Constitution, and all other applicable laws or privileges. Responding Party further 

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objects to the extent it seeks information that is not relevant to the relevant to any 

party’s claim or defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 5:

Documents concerning discussions with BP Funding Trust regarding any 

asserted patent, a portfolio including an asserted patent, assignment of any interest 

in any asserted patent or a portfolio including an asserted patent, or the acquisition 

or potential acquisition of any portfolio that might have included an asserted 

patent.

RESPONSE TO REQUEST 5:

Objection. Responding Party objects on the grounds this request is 

overly broad and unduly burdensome. Responding Party objects further on the 

grounds this request is oppressive, burdensome and harassing as the documents 

requested can be sought from a party or other source without the need to seek them 

from this non-party witness. Responding Party objects to this request to the extent 

it seeks information protected from disclosure by the attorney-client privilege 

and/or attorney work product doctrine. Responding Party further objects to the

extent it calls for the disclosure of non-public, private, personal, confidential, 

proprietary information, or trade secret information that has been maintained in 

confidence and/or is legally required to be maintained in confidence, including, but 

not limited to, documents that are shielded from production by statutory or 

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decisional law of the United States and each of its jurisdictions, statutory or 

decisional law of any foreign country, the right of privacy under the United States 

Constitution, and all other applicable laws or privileges. Responding Party further 

objects to the extent it seeks information that is not relevant to the relevant to any 

party’s claim or defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 6:

Agreements with BP Funding Trust concerning any potential or actual 

transaction regarding any asserted patent, a portfolio including an asserted patent, 

or the acquisition or potential acquisition of any portfolio that might have included 

an asserted patent.

RESPONSE TO REQUEST 6:

Objection. Responding Party objects on the grounds this request is 

overly broad and unduly burdensome. Responding Party objects further on the 

grounds this request is oppressive, burdensome and harassing as the documents 

requested can be sought from a party or other source without the need to seek them 

from this non-party witness. Responding Party objects to this request to the extent 

it seeks information protected from disclosure by the attorney-client privilege 

and/or attorney work product doctrine. Responding Party further objects to the

extent it calls for the disclosure of non-public, private, personal, confidential, 

proprietary information, or trade secret information that has been maintained in 

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confidence and/or is legally required to be maintained in confidence, including, but 

not limited to, documents that are shielded from production by statutory or 

decisional law of the United States and each of its jurisdictions, statutory or 

decisional law of any foreign country, the right of privacy under the United States 

Constitution, and all other applicable laws or privileges. Responding Party further 

objects to the extent it seeks information that is not relevant to the relevant to any 

party’s claim or defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 7:

Agreements with the named inventor(s) of any of the asserted patents, 

including assignment agreements, consulting agreements, employment agreements 

and any agreements pertaining to litigation involving the asserted patents or any 

related patents.

RESPONSE TO REQUEST 7:

Objection. Responding Party objects on the grounds this request is 

overly broad and unduly burdensome. Responding Party objects further on the 

grounds this request is oppressive, burdensome and harassing as the documents 

requested can be sought from a party or other source without the need to seek them 

from this non-party witness. Responding Party objects to this request to the extent 

it seeks information protected from disclosure by the attorney-client privilege 

and/or attorney work product doctrine. Responding Party further objects to the

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extent it calls for the disclosure of non-public, private, personal, confidential, 

proprietary information, or trade secret information that has been maintained in 

confidence and/or is legally required to be maintained in confidence, including, but 

not limited to, documents that are shielded from production by statutory or 

decisional law of the United States and each of its jurisdictions, statutory or 

decisional law of any foreign country, the right of privacy under the United States 

Constitution, and all other applicable laws or privileges. Responding Party further 

objects to the extent it seeks information that is not relevant to the relevant to any 

party’s claim or defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 8:

Compensation, cost-sharing, or profit sharing agreements with any of the 

named inventor(s) of the asserted patent(s).

RESPONSE TO REQUEST 8:

Objection. Responding Party objects on the grounds this request is 

vague, ambiguous and unintelligible as to the phrases/terms “Compensation, costsharing, or profit sharing agreements.” Responding Party objects further on the 

grounds this request is oppressive, burdensome and harassing as the documents 

requested can be sought from a party or other source without the need to seek them 

from this non-party witness. Responding Party objects to this request to the extent 

it seeks information protected from disclosure by the attorney-client privilege 

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and/or attorney work product doctrine. Responding Party further objects to the

extent it calls for the disclosure of non-public, private, personal, confidential, 

proprietary information, or trade secret information that has been maintained in 

confidence and/or is legally required to be maintained in confidence, including, but 

not limited to, documents that are shielded from production by statutory or 

decisional law of the United States and each of its jurisdictions, statutory or 

decisional law of any foreign country, the right of privacy under the United States 

Constitution, and all other applicable laws or privileges. Responding Party further 

objects to the extent it seeks information that is not relevant to the relevant to any 

party’s claim or defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 9:

Documents regarding the assignment, licensing, acquisition, financial 

interest, security interest, lien, sale, transfer of rights (in whole or in part) and any 

other disposition of or any offers to buy, sell, obtain rights to, or licenses any of the 

asserted patents.

RESPONSE TO REQUEST 9:

Objection. Responding Party objects on the grounds this request is vague,

ambiguous and unintelligible as to the phrases/terms “Compensation, cost-sharing, 

or profit sharing agreements.” Responding Party objects further on the grounds 

this request is oppressive, burdensome and harassing as the documents requested 

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can be sought from a party or other source without the need to seek them from this 

non-party witness. Responding Party objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 10:

Documents concerning the nature and scope of any rights you had in the past 

or currently have in each of the asserted patents, related applications or related 

patents from the time each alleged invention was conceived through the present, 

including the right to control any portion of litigation, future royalties, payment for 

licenses, contingent rights, or payments depending on the outcome of litigation.

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RESPONSE TO REQUEST 10:

Objection. Responding Party objects on the grounds this request is overly 

broad and unduly burdensome. Responding Party objects further on the grounds 

this request is oppressive, burdensome and harassing as the documents requested 

can be sought from a party or other source without the need to seek them from this 

non-party witness. Responding Party objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 11:

Documents regarding agreements relating to each of the asserted patents (or 

any portfolio including any of the asserted patents), including assurances, 

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covenants not to sue and understandings not to assert any of the asserted patents 

against potential licensees.

RESPONSE TO REQUEST 11:

Objection. Responding Party objects on the grounds this request is overly 

broad and unduly burdensome. Responding Party objects further on the grounds 

this request is oppressive, burdensome and harassing as the documents requested 

can be sought from a party or other source without the need to seek them from this 

non-party witness. Responding Party objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

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REQUEST FOR PRODUCTION NO. 12:

Documents regarding agreements between you and WSOU, Allied Security 

Trust, AQUA Licensing, LLC, RPX Corporation, Fortress Credit Co., LLC, 

Houlihan, Orange Holdings, Wade and Company, Omega Credit Opportunities 

Master Fund, Terrier, Juniper Capital Partners, Coast Asset Management, or 

WCFT Cayman, regarding any asserted patent, a portfolio including an asserted 

patent, or the acquisition or potential acquisition of any portfolio that might have 

included an asserted patent, including any amendment, modification, 

supplementation, abrogation, or termination of any such agreements.

RESPONSE TO REQUEST 12:

Objection. Responding Party objects on the grounds this request is 

overly broad and unduly burdensome. Responding Party objects further on the 

grounds this request is oppressive, burdensome and harassing as the documents 

requested can be sought from a party or other source without the need to seek them 

from this non-party witness. Responding Party objects to this request to the extent 

it seeks information protected from disclosure by the attorney-client privilege 

and/or attorney work product doctrine. Responding Party further objects to the

extent it calls for the disclosure of non-public, private, personal, confidential, 

proprietary information, or trade secret information that has been maintained in 

confidence and/or is legally required to be maintained in confidence, including, but 

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not limited to, documents that are shielded from production by statutory or 

decisional law of the United States and each of its jurisdictions, statutory or 

decisional law of any foreign country, the right of privacy under the United States 

Constitution, and all other applicable laws or privileges. Responding Party further 

objects to the extent it seeks information that is not relevant to the relevant to any 

party’s claim or defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 13:

Documents regarding agreements with Nokia or other WSOU Defendants 

regarding an asserted patent or a portfolio including an asserted patent.

RESPONSE TO REQUEST 13:

Objection. Responding Party objects on the grounds this request is overly 

broad and unduly burdensome. Responding Party objects further on the grounds 

this request is oppressive, burdensome and harassing as the documents requested 

can be sought from a party or other source without the need to seek them from this 

non-party witness. Responding Party objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

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to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 14:

Communications with Nokia, Allied Security Trust, AQUA, RPX 

Corporation, Fortress Credit Co., LLC, Houlihan, WSOU, Orange Holdings, Wade 

and Company, Omega Credit Opportunities Master Fund, Terrier, Juniper Capital 

Partners, Coast Asset Management, or WCFT Cayman regarding an asserted 

patent, a portfolio including an asserted patent, or actual or potential litigation 

relating to an asserted patent.

RESPONSE TO REQUEST 14:

Objection. Responding Party objects on the grounds this request is overly 

broad and unduly burdensome. Responding Party objects further on the grounds 

this request is oppressive, burdensome and harassing as the documents requested 

can be sought from a party or other source without the need to seek them from this 

non-party witness. Responding Party objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

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attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 15:

Documents concerning communications with any of the named inventors 

regarding any of the asserted patents, this litigation or Google.

RESPONSE TO REQUEST 15:

Objection. Responding Party objects on the grounds this request is vague, 

ambiguous and unintelligible. Responding Party further objects on the grounds 

that this request overly broad and unduly burdensome. Responding Party objects 

on the grounds this request is oppressive, burdensome and harassing as the 

documents requested can be sought from a party or other source without the need 

to seek them from this non-party witness. Responding Party objects to this request 

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to the extent it seeks information protected from disclosure by the attorney-client 

privilege and/or attorney work product doctrine. Responding Party further objects 

to the extent it calls for the disclosure of non-public, private, personal, confidential, 

proprietary information, or trade secret information that has been maintained in 

confidence and/or is legally required to be maintained in confidence, including, but 

not limited to, documents that are shielded from production by statutory or 

decisional law of the United States and each of its jurisdictions, statutory or 

decisional law of any foreign country, the right of privacy under the United States 

Constitution, and all other applicable laws or privileges. Responding Party further 

objects to the extent it seeks information that is not relevant to the relevant to any 

party’s claim or defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 16:

Communications with WSOU regarding the asserted patent, related patents, 

this litigation or Google.

RESPONSE TO REQUEST 16:

Objection. Responding Party objects on the grounds this request is vague, 

ambiguous and unintelligible. Responding Party further objects on the grounds 

that this request overly broad and unduly burdensome. Responding Party objects 

on the grounds this request is oppressive, burdensome and harassing as the 

documents requested can be sought from a party or other source without the need 

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to seek them from this non-party witness. Responding Party objects to this request 

to the extent it seeks information protected from disclosure by the attorney-client 

privilege and/or attorney work product doctrine. Responding Party further objects 

to the extent it calls for the disclosure of non-public, private, personal, confidential,

proprietary information, or trade secret information that has been maintained in 

confidence and/or is legally required to be maintained in confidence, including, but 

not limited to, documents that are shielded from production by statutory or 

decisional law of the United States and each of its jurisdictions, statutory or 

decisional law of any foreign country, the right of privacy under the United States 

Constitution, and all other applicable laws or privileges. Responding Party further 

objects to the extent it seeks information that is not relevant to the relevant to any 

party’s claim or defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 17:

Documents concerning communications between you and any other entity 

relating to the possibility of patent litigation regarding the asserted patent and 

related patents, including any actual or potential patent litigation against Google 

and the WSOU v. Google Litigations.

RESPONSE TO REQUEST 17:

Objection. Responding Party objects on the grounds this request is overly 

broad and unduly burdensome. Responding Party objects further on the grounds 

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this request is oppressive, burdensome and harassing as the documents requested 

can be sought from a party or other source without the need to seek them from this 

non-party witness. Responding Party objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 18:

Documents concerning the formation of WSOU.

RESPONSE TO REQUEST 18:

Objection. Responding Party objects on the grounds this request is overly 

broad and unduly burdensome. Responding Party objects further on the grounds 

this request is oppressive, burdensome and harassing as the documents requested

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can be sought from a party or other source without the need to seek them from this 

non-party witness. Responding Party objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 19:

Documents concerning any contemplated acquisition of patents or rights in 

patents from Nokia.

RESPONSE TO REQUEST 19:

Objection. Responding Party objects on the grounds this request is

oppressive, burdensome and harassing as the documents requested can be sought 

from a party or other source without the need to seek them from this non-party 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 118 of 129
25

witness. Responding Party objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 20:

Documents sufficient to show any interests (current or prior) in WSOU.

RESPONSE TO REQUEST 20:

Objection. Responding Party objects on the grounds this request is 

oppressive, burdensome and harassing as the documents requested can be sought 

from a party or other source without the need to seek them from this non-party 

witness. Responding Party objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 119 of 129
26

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 21:

Documents sufficient to show any actual, contingent, or potential (1) right to 

license or sublicense any asserted patent, (2) right to control the licensing of any 

asserted patent, or (3) right to control or be involved in the resolution of any 

litigation involving any asserted patent.

RESPONSE TO REQUEST 21:

Objection. Responding Party objects on the grounds this request is

oppressive, burdensome and harassing as the documents requested can be sought 

from a party or other source without the need to seek them from this non-party 

witness. Responding Party objects to this request to the extent it seeks 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 120 of 129
27

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 22:

Documents sufficient to show your relationship with Stuart A. Shanus, Eric 

Schneider, Andrew Neuberger, Marc Wade, or Craig Etchegoyen, Orange 

Holdings, WSOU, Uniloc USA, Inc., WCFT Cayman, Omega Credit Opportunities 

Master Fund, Wade and Company, and Terrier, or any entity associated with the 

foregoing.

RESPONSE TO ERQUEST 22:

Objection. Responding Party objects on the grounds this request is 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 121 of 129
28

oppressive, burdensome and harassing as the documents requested can be sought 

from a party or other source without the need to seek them from this non-party 

witness. Responding Party objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 23

Documents concerning the “Patent Security Agreement” recorded at USPTO 

Reel 09235 Frame 0068, signed May 16, 2019, the circumstances of this 

agreement, and any related agreements.

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 122 of 129
29

RESPONSE TO REQUEST 23:

Objection. Responding Party objects on the grounds this request is 

oppressive, burdensome and harassing as the documents requested can be sought 

from a party or other source without the need to seek them from this non-party 

witness. Responding Party objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 24:

Documents concerning the May 16, 2019 “Patent Security Agreement” and 

any related agreements, including the circumstances surrounding the recorded 

release of your security interest regarding the “Patent Security Agreement.”

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 123 of 129
30

RESPONSE TO REQUEST 24:

Objection. Responding Party objects on the grounds this request is

oppressive, burdensome and harassing as the documents requested can be sought 

from a party or other source without the need to seek them from this non-party 

witness. Responding Party objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 25:

Documents concerning the release of your security interest, recorded June 3, 

2021, at USPTO Reel 056526 Frame 0093, the circumstances of this agreement, 

and any related agreements.

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 124 of 129
31

RESPONSE TO REQUEST 25:

Objection. Responding Party objects on the grounds this request is 

oppressive, burdensome and harassing as the documents requested can be sought 

from a party or other source without the need to seek them from this non-party 

witness. Responding Party objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 26:

Documents concerning the value of, any valuations of or attempts to value 

any asserted patent, related patent, or related application, whether individually or 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 125 of 129
32

in combination with any other patents or applications, including any portfolio 

containing any asserted patent or related patent.

RESPONSE TO REQUEST 26:

Objection. Responding Party objects on the grounds this request is 

oppressive, burdensome and harassing as the documents requested can be sought 

from a party or other source without the need to seek them from this non-party 

witness. Responding Party objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 126 of 129
33

REQUEST FOR PRODUCTION NO. 27:

Documents concerning any evaluation or analysis of any asserted patent, any 

related patent, or any related application, whether individually or in combination 

with any other patents or applications, including any evaluation or analysis of 

infringement, validity, or commercialization.

RESPONSE TO REQUEST 27:

Objection. Responding Party objects on the grounds this request is overly 

broad and unduly burdensome. Responding Party objects further on the grounds 

this request is oppressive, burdensome and harassing as the documents requested 

can be sought from a party or other source without the need to seek them from this 

non-party witness. Responding Party objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 127 of 129
34

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

REQUEST FOR PRODUCTION NO. 28:

Documents produced in response to a subpoena served by any other WSOU 

Defendant.

RESPONSE TO REQUEST 28:

Objection. Responding Party objects on the grounds this request is overly 

broad and unduly burdensome. Responding Party objects further on the grounds 

this request is oppressive, burdensome and harassing as the documents requested 

can be sought from a party or other source without the need to seek them from this 

non-party witness. Responding Party objects to this request to the extent it seeks 

information protected from disclosure by the attorney-client privilege and/or 

attorney work product doctrine. Responding Party further objects to the extent it 

calls for the disclosure of non-public, private, personal, confidential, proprietary 

information, or trade secret information that has been maintained in confidence 

and/or is legally required to be maintained in confidence, including, but not limited 

to, documents that are shielded from production by statutory or decisional law of 

the United States and each of its jurisdictions, statutory or decisional law of any 

foreign country, the right of privacy under the United States Constitution, and all 

other applicable laws or privileges. Responding Party further objects to the extent 

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 128 of 129
35

it seeks information that is not relevant to the relevant to any party’s claim or 

defense, nor proportional to the needs of the case.

Date: October 19, 2021 /s/ Morgan E. Pietz

Morgan E. Pietz (CA Bar #260629)*

Pietz & Shahriari, LLP

9454 Wilshire Blvd., Suite 310

Beverly Hills, CA 90212

Counsel for Terrier SSC, LLC

Sean J. Bellew (#4072)

Bellew LLC

2961 Centerville Road, Suite 302

Wilmington, Delaware 19808

Telephone: (302) 353-4951

sjbellew@bellewllc.com

Counsel for Terrier SSC, LLC

*Pro Hac Vice application is forthcoming.

Case 6:20-cv-00571-ADA Document 61-7 Filed 10/20/21 Page 129 of 129