Exhibit A

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Subject: Subject: MyChoice v Taiv - Follow-Up Meet and Confer re Document Requests and Source Code Review

Date: Date: Thursday, September 19, 2024 at 12:51:01PM Pacific Daylight Time

From: From: Chris Perque

To: To: Ryan Marton, Michael Gilleran, Phil Haack

CC: CC: Hector Ribera

Ryan,

Are you available for a call at 10 am PT on Monday or Tuesday of next week to

discuss open discovery issues?

The open issues are Taiv Inc. and Taiv USA, Inc.’s failure to produce relevant

documents. Taiv was required to produce technical documents and other relevant

documents long ago under the local rules and orders entered in this case but failed

to comply. MyChoice served document requests on Taiv and Taiv USA to identify

categories of relevant documents for production, and neither entity produced

documents in response thereto. In the last discovery call, counsel for Taiv was not

prepared to discuss those requests. We intend to address those requests and other

failures of Taiv to produce documents as required under the local rules and

applicable orders in this case during the call next week.

The other open discovery issue is the protocol/location for reviewing Taiv’s source

code. MyChoice objects to the production of that code and requirement to conduct

an in-person review at your offices in San Francisco as unduly burdensome. During

our last call, MyChoice requested the option to remotely reviewing that code, and

counsel for Taiv responded that MyChoice would have to cover the cost of a remote

review, which may exceed $6000 per month for unspecified hosting costs. MyChoice

has since conferred with a consultant, who had conducted remote source code

reviews in other cases using TeamViewer, which could be conducted with no

additional hosting cost. The protocol would be that a free version of TeamViewer

would be installed on the computer with Taiv’s source code stored thereon by

someone in your office. MyChoice via an external consultant would request that

someone with access to that computer turn it on at a particular date/time, open

TeamViewer, and provide an access code from TeamViewer for the consultant to use

to access the computer and review source code on that day. The consultant would

advise when the review was completed on that day so that the computer could be

turned off. This process has been used in other matters as an effective, efficient

manner to review code stored on a local computer. We can discuss this further

during the upcoming call.

Best,

Chris

Chris P. Perque

Partner

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_____________________________________________

FisherBroyles, LLP

direct: +1.504.237.5102

chris.perque@fisherbroyles.com

www.fisherbroyles.com

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