Contract analysis

I. PRELIMINARY STATEMENT Plaintiff Genome Dx Therapeutics Inc. ("GenomeDx"), pursuant to Federal Rules of Civil Procedure 26(b) and 34, and the applicable provisions of the Local Rules of the United States District Court for the Northern District of California, hereby requests that Defendant Helios Precision Diagnostics, Inc. ("Helios") produce the documents and electronically stored information ("ESI") described in

II. INSTRUCTIONS A. General Instructions

1. Helios shall produce all responsive documents in its possession, custody, or control. As used herein, "possession, custody, or control" means that Helios has physical possession of the document, has a right to obtain the document from a third party (including any agent, attorney, accountant, consultant, or representative), or has the practical ability to obtain the document from a third party.

2. Without limiting the foregoing, Helios shall produce responsive documents held by its current and former officers, directors, employees, agents, consultants, representatives, attorneys (to the extent not protected by the attorney-client privilege or work-product doctrine), accountants, independent contractors, and any other persons or entities acting or purporting to act on Helios's behalf.

3. Helios shall produce responsive documents held by its parent companies, subsidiaries, affiliates, divisions, and majority investors, to the extent such documents are within Helios's possession, custody, or control. This instruction encompasses, without limitation, documents held by or shared with Corinth Ventures Fund III, LP, its general partner, and any related entities or personnel, including Managing Director

4. Helios shall produce all responsive documents regardless of the medium in which they are stored, whether paper, electronic, audio, video, photographic, or any other form or medium.

5. If any document responsive to these Requests has been destroyed, discarded, lost, overwritten, or is otherwise no longer available, Helios shall: (a) identify the document by type, author, recipient, date, and general subject matter to the best of its knowledge, information, and belief; (b) describe the contents of the document; (c) state the date on or about which the document was destroyed, discarded, lost, or b

6. If Helios objects to any Request, it shall state the objection with specificity, including the legal and factual bases therefor, and shall produce all documents responsive to the non-objectionable portions of the Request. A general or boilerplate objection shall not relieve Helios of its obligation to produce responsive documents.

7. No document shall be withheld or redacted solely on the basis that it contains information both responsive and non-responsive to a particular Request. If a document is responsive in part, it shall be produced in its entirety unless a specific and well-founded privilege or protection applies to the non-responsive portion. B. Form of Production

1. Helios shall produce ESI in native format or as single-page TIFF images (300 dpi minimum resolution) with accompanying load files containing extracted text (or OCR text for image-only documents) and all associated metadata, consistent with the parties' ESI Protocol agreed upon on November 14, 2025 (Dkt. No. 37).

2. Helios shall produce documents as they are kept in the ordinary course of business, organized by custodian. Each custodian's documents shall be clearly identified and segregated. If documents have been collected from shared drives, databases, or other repositories not associated with a single custodian, such documents shall be organized and labeled by their source.

3. Helios shall produce complete copies of all responsive documents, including all attachments, enclosures, cover letters, and any other documents physically or electronically appended or affixed thereto.

4. For each document withheld in whole or in part on the grounds of attorney-client privilege, work-product protection, or any other privilege or immunity, Helios shall provide a privilege log entry in compliance with Federal Rule of Civil Procedure 26(b)(5)(A) and Local Rule 37-1. Each privilege log entry shall identify, at a minimum: (i) the date of the document or communication; (ii) the author(s) or speaker(s); (

5. Helios shall produce a privilege log within thirty (30) days of the date of production of documents, or at such other time as ordered by the Court or agreed upon by the parties. C. Time Period Unless otherwise specified in a particular Request, each Request covers the period from January 1, 2019 (the year of Helios's founding and incorporation in the State of Delaware) through the date of production. GenomeDx rese

III. DEFINITIONS As used in these Requests for Production, the following terms shall have the meanings set forth below: 1. "Helios" or "You" or "Your" means Helios Precision Diagnostics, Inc., a Delaware corporation with its principal place of business at 9830 Mesa Rim Road, Suite 140, San Diego, California 92121, including its current and former officers, directors, employees, agents, representatives, consultants, p

IV. REQUESTS FOR PRODUCTION Category A: ProstaSignal™ Design, Development, and Technical Documentation REQUEST FOR PRODUCTION NO. 1: All Documents Relating to the conception, design, research, and development of the ProstaSignal™ Genomic Classifier, including but not limited to project plans, project charters, timelines, Gantt charts, milestone trackers, research proposals, grant applications, laboratory notebooks, e

V. SIGNATURE Dated: January 27, 2026 Respectfully submitted, CALDERWOOD & HARKNESS LLP By: ________ Catherine Bloom (CA Bar No. 247189) Responsible Partner Peter Vassiliev (CA Bar No. 312054) Lead Associate CALDERWOOD & HARKNESS LLP 555 Mission Street, Suite 3100 San Francisco, California 94105 Telephone: (415) 773-6200 Facsimile: (415) 773-6201 Email: cbloom@calderwoodharkness.com Email: pvassiliev@calderwoodharknes