Contract analysis

1. Overbreadth and Undue Burden. Redstone objects to any interrogatory or request for production that is overbroad in scope, unduly burdensome, or not proportional to the needs of this case, as required by Federal Rule of Civil Procedure 26(b)(1), considering the importance of the issues at stake, the amount in controversy, the parties' relative access to relevant information, the parties' resources, the importance o

2. Relevance. Redstone objects to any interrogatory or request for production that seeks information or documents not relevant to any party's claim or defense and not proportional to the needs of the case under Federal Rule of Civil Procedure 26(b)(1). This objection applies with particular force to requests that seek information about Redstone's business operations, products, personnel, or financial performance unre

3. Vagueness and Ambiguity. Redstone objects to any interrogatory or request for production that is vague, ambiguous, unintelligible, or susceptible to multiple reasonable interpretations, to the extent that such vagueness or ambiguity renders the request incapable of a meaningful response. Where Redstone has responded to a vague or ambiguous request, it has done so based on its own reasonable interpretation of the r

4. Attorney-Client Privilege and Work-Product Protection. Redstone objects to any interrogatory or request for production to the extent it calls for information or documents protected by the attorney-client privilege, the work-product doctrine (including both fact work product and opinion work product), or any other applicable privilege or immunity from disclosure. A privilege log has been prepared and will be produc

5. Trade Secret and Proprietary Information. Redstone objects to any interrogatory or request for production to the extent it seeks disclosure of trade secrets, proprietary business information, proprietary source code, confidential technical processes, or other confidential commercial information that is not relevant to the claims or defenses at issue in this action, or the disclosure of which would cause competitiv

6. Temporal Scope. Redstone objects to any interrogatory or request for production that is not reasonably limited in temporal scope, or that seeks information or documents outside the time period relevant to the development and release of Ironclad Dominion (approximately Q1 2020 through November 14, 2022) and the period of alleged infringement as set forth in the Complaint. Requests extending beyond these temporal bo

8. Reservation Regarding Privilege Log. Redstone states that a privilege log is being produced concurrently with these responses, identifying documents and communications withheld or redacted on the basis of attorney-client privilege and/or work-product protection. The privilege log identifies the nature of each withheld or redacted document, the date, the author, the recipient(s), and the basis for the privilege or

9. Subject to These General Objections. Each specific response set forth below incorporates and is subject to these General Objections in their entirety. The assertion of a specific objection in any particular response shall not be construed as a waiver of any General Objection not specifically restated therein. DEFINITIONS AND INTERPRETIVE NOTES Redstone has reviewed the definitions and instructions set forth in Pla