Contract analysis

I. PRELIMINARY STATEMENT Plaintiff Genome Dx Therapeutics Inc. ("GenomeDx" or "Plaintiff"), by and through its undersigned attorneys at Calderwood & Harkness LLP, hereby responds and objects to Defendant Helios Precision Diagnostics, Inc.'s ("Helios" or "Defendant") First Set of Requests for Production of Documents, Nos. 1 through 52, served on January 27, 2026, pursuant to Federal Rules of Civil Procedure 26 and 34

II. GENERAL OBJECTIONS GenomeDx makes the following General Objections, each of which is incorporated by reference into each specific response to each individual Request for Production, as though fully set forth therein. General Objection No. 1 — Scope and Proportionality GenomeDx objects to each Request to the extent it is overly broad, unduly burdensome, or not proportional to the needs of this case as required by

III. IDENTIFICATION OF CUSTODIANS AND DOCUMENT COLLECTION In connection with this litigation, GenomeDx has identified eleven (11) custodians for purposes of document collection and review. These custodians were selected based on their roles within GenomeDx, their involvement in the conception, development, prosecution, and commercialization of the patents-in-suit and the Decipher® Prostate genomic classifier test, an

1. Dr. Rajan Mehta — Chief Technology Officer and Named Inventor on all three patents-in-suit (the '271 Patent, the '893 Patent, and the '647 Patent);

2. Dr. Kevin Ostrowski — Vice President, intellectual Property and Named Inventor on the '647 Patent;

3. Dr. Miriam Langford — Chief Executive Officer;

4. Victoria Sung — General Counsel;

5. Thomas Brennan — Chief Financial Officer;

6. Dr. Carolyn Xu — Former Principal Scientist and Named Inventor on the '271 Patent and the '893 Patent (departed GenomeDx in 2023; currently employed at Cascadia Genomics, Inc.);

7. Dr. Priya Shah — Senior Scientist and Named Inventor on the '647 Patent;

8. Director of Laboratory Operations (identified by functional description to protect individual privacy);

9. Senior Director of Commercial Strategy (identified by functional description);

10. Director of Regulatory Affairs (identified by functional description); and

11. Senior Bioinformatics Scientist (identified by functional description). Documents were collected from these custodians' email accounts, local and network drives, cloud storage repositories, and relevant enterprise IT systems, including GenomeDx's laboratory information management system (LIMS), document management system, and shared departmental drives. In total, approximately 482,000 documents comprising approxi

IV. SPECIFIC RESPONSES AND OBJECTIONS TO REQUESTS FOR PRODUCTION NOS. 1–52 GenomeDx responds to each of Defendant's Requests for Production of Documents as set forth below. Each response incorporates by reference all General Objections stated in Section II above as though fully set forth in each individual response. The assertion of specific objections in response to any individual Request is in addition to, and does