Contract analysis

I. INTRODUCTORY STATEMENT Plaintiff Optiwave Semiconductor Corp. ("OWS" or "Plaintiff"), by and through its attorneys of record, Calderwood & Harkness LLP, hereby responds and objects to Defendant Lumos Photonics, Inc.'s ("Lumos" or "Defendant") First Set of Requests for Production of Documents (Nos. 1–98), served on Plaintiff on November 7, 2022, pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure. O

II. GENERAL OBJECTIONS The following General Objections apply to each and every one of Lumos's Requests for Production of Documents, Nos. 1 through 98, and are incorporated by reference into each specific response set forth below as if stated in full therein. The assertion of these General Objections shall not be deemed a waiver of any other objection, whether general or specific, that OWS may assert. General Objecti

III. DEFINITIONS AND INTERPRETATIONS For purposes of these Responses and Objections, OWS interprets Lumos's defined terms and instructions as follows, and responds accordingly: 1. "Document" and "Documents": OWS interprets these terms to mean any writing, recording, or electronically stored information as defined by Federal Rule of Civil Procedure 34(a)(1)(A), including correspondence, memoranda, reports, presentatio

IV. SPECIFIC RESPONSES AND OBJECTIONS OWS sets forth below its specific responses and objections to each of Lumos's Requests for Production of Documents, Nos. 1 through 98. The General Objections set forth in Section II above are incorporated by reference into each specific response below, and OWS's decision to respond to any individual Request notwithstanding a General Objection does not waive that or any other obje