Contract analysis

1. Each interrogatory shall be answered separately and fully in writing, under oath, in accordance with Rule 33(b) of the Federal Rules of Civil Procedure. Each answer shall include all information within the FTC's knowledge, possession, custody, or control, including information known to or reasonably available to the FTC's Commissioners, staff members, agents, consultants, and retained experts, whether located at t

2. If the FTC objects to any interrogatory or any part thereof, the FTC shall state with specificity the grounds for each objection, including the particular privilege or protection asserted, and shall answer the interrogatory to the fullest extent not objectionable. An objection to any part of an interrogatory shall not be deemed a basis for refusing to answer the remainder of the interrogatory.

3. If the FTC's answer to any interrogatory requires reference to or identification of documents, the FTC shall identify each such document with sufficient particularity consistent with the definition of "Identify" set forth above, and shall produce such documents in response to Defendants' concurrent First Set of Requests for Production of Documents, served on even date herewith, or as otherwise required by the Fede

4. If the FTC contends that any interrogatory is vague, ambiguous, or otherwise unclear, the FTC is instructed to contact undersigned counsel at Calderwood & Harkness LLP to discuss the interrogatory prior to interposing any objection. Defendants are committed to resolving any good-faith disputes regarding the scope or clarity of these interrogatories through the meet-and-confer process.

5. These interrogatories are continuing in nature pursuant to Federal Rule of Civil Procedure 26(e). The FTC is obligated to seasonably supplement its answers if additional or corrective information becomes available at any time prior to or during the evidentiary hearing scheduled for September 8, 2025, and thereafter as required by the Federal Rules of Civil Procedure.

6. The total number of interrogatories served herein is twenty-five (25), consistent with the presumptive limit set forth in Federal Rule of Civil Procedure 33(a)(1) and any applicable Local Rules of the Western District of Washington or orders of this Court. Each discrete subpart of an interrogatory is not intended to constitute a separate interrogatory, but rather is intended to delineate the categories of informat