Real Patent Applications Re ARccOS and RipGuard

Case3:08-cv-04548-MHP Document428-1 Filed06/24/09 Page1 of 133
EXHIBIT A
EXHIBIT B
EXHIBIT C
EXHIBIT D
Aull, Ashley
From: Barth, Lawrence
Sent: Tuesday, October 28, 2008 5:28 PM
To: Tosh Lane, Tracy; 'Berta, Michael'
Cc: Lynch, Rebecca
Subject: RealDVD - document discovery
Mike and Tracy:
I am writing (i) to provide you with a refined version of the Studios' document requests in light of our phone conversations
to date; and (ii) to confirm our understanding of what the studios will be collecting. Based on the incredibly short time for
collection and production, we agreed to the following ground rules applicable to both sides:
A. Each party will collect documents from only a limited number of custodians who are most likely to have
responsive documents. We will share with one another the identities (by name or function) of those from whom we've
collected; if either side thinks the other side needs to collect more broadly, we will meet and confer on the subject.
B. The parties will not collect from lawyers acting solely in legal roles.
C. The parties will not prepare and exchange privilege logs, but we will share with each another the principles based
on which we have claimed privilege in sufficient detail to allow the other side to challenge such principles.
D. The parties will not search for documents on back-up media.
E. The parties will continue to work with each other as the process proceeds, e.g., each party will provide prompt "hit
reports" for keyword searches, so each of us can make further refinements as necessary, if need be.
I. Studios' Document Requests
A. Source Code for RealDVD - You indicated that Real will produce this pursuant to a protective order. We have
now sent you our revisions to the protective order and hope to finalize it with you very shortly. As you know, the judge
has ordered that documents be produced immediately (where possible), even before a protective order is executed.
Accordingly, we hope you will produce RealDVD source code at once. Without it, it will be impossible to meet our
deadlines for expert designations, reports, depositions, etc.
B. Documents referring to the design and/or development of RealDVD - Given the burden concerns that you
mentioned in our phone call, we have narrowed our request to:
1. Documents constituting architecture, technical or design specifications or documentation for RealDVD,

including all drafts or versions of specifications or documentation.
2. Proposals, planning documents and test cases relating to RealDVD.
Note that, as with source code, we need these documents asap if our experts are to be prepared in a timely
fashion.
C. All documents referring to any proposed or actual functionality of RealDVD, including the ability to add additional
computers to RealDVD accounts - Based on our discussion last week, we have crafted keyword searches to take the
place of our original formulation:
1. Documents containing the terms: RealDVD & ("share" "cop!" "security" "encrypt!")
2. Documents containing the terms: "playback" or (play! /3 cop!)
3. Documents containing the terms: "authenticat!"
4. Documents containing the terms: "CGMS" or "CopyNever"
1
5. Documents containing the terms: ("five" or "5") /10 cop!
6. Documents containing the terms: "CPR_MAI" or "CPRMAI"
7. Documents containing the terms: "edf"
8. Documents containing the terms: "file rip!" or "file cop!"
9. Documents containing the terms: "ISO rip!" or "ISO cop!" or "ISO image!"
10. Documents containing the terms: "lead-in" or "lead in" or "leadin"
11. Documents containing the terms: "sector header!"
12. Documents containing the terms: ("disc" or "disk") /2 key
13. Documents containing the terms: "bus encrypt!"
14. Documents containing the terms: ("bad" or "unreadable") /3 ("sector" or "data")
15. Documents containing the terms: "Macrovision" or "Ripguard" or "Arccoss" or "X-Protect" or "Flux" or
"Fortium"
D. Documents containing the terms “CSS” and “License”. You found this acceptable.
E. Documents constituting or referring to marketing, promotional or advertising plans for RealDVD. You found this
acceptable.
F. Documents containing the terms “Streambox” and “RealDVD”. You found this acceptable.
G. Documents containing the terms “MacTheRipper,” “DeCSS,” “DVD X,” “Slysoft,” “Plato” “Handbrake” or “rip!”.
You found this acceptable, but warned us that the "rip!" term might result in Real's identifying a large population of
documents; we asked you to test that and, if it does, we will work to narrow it.
H. Documents containing the terms “rent!” or “borrow!” and “RealDVD”. You found this acceptable.
I. Documents containing the terms “backup cop!” and “RealDVD”. You found this acceptable.
J. Documents containing the terms “DVD CCA” or “CCA”. You found this acceptable.
K. Documents containing the terms “Kaleidescape”. You found this acceptable.
L. Documents sent to or received from the DVD CCA. You found this acceptable.
M. Pleadings in RealNetworks v. Streambox. You found this acceptable.
N. Documents relating to proposed amendments to the CSS license agreement from [January 1,] 2007 to the
present regarding (i) whether a DVD must be present in the DVD drive during playback, or (ii) prohibiting copying of DVD
content. You found this acceptable.
O. Multiple copies of RealDVD software in a form that will allow our experts to work with all of its functions. I know
that the technical issues are the subject of other emails between our firms, and appreciate your looking into this issue. As
I've explained, we need the software immediately if we are to meet our deadlines for expert designation, reports,
depositions, etc.
II. Studios' Collection of Documents
A. Documents comprising or referring to communications (i) within a studio (ii) between or among studios; (iii)
between a studio (or studios) and the DVD CCA; and (iv) between a studio (or studios) and any member(s) of the Board
of Directors of the DVDCCA or CPAC discussing:
1. negotiation and development of the DVD CCA CSS license agreement; and
2
2. proposed amendments to the DVD CCA license agreement from [January 1,] 2007 to the present
regarding
a. whether a DVD must be physically present in the DVD drive during playback; or
b. prohibiting or permitting copying of DVD content.
Two notes here: First, we have spelled out the term "DVD CCA CSS license agreement" to make clear that the
studios are not going to go back to the period before the formation of the DVD CCA and search, for example, for
documents concerning licenses given by Toshiba and Matsushita or other entities that may have given licenses before
the formation of the DVD CCA.
Second, I have inserted a time limitation in A.2. and used the conjunction "and" between A.2.a. and A.2.b. to
make clear that the studios will be collecting documents relating only to the amendment that I take to be of principal
concern to you.
B. Documents discussing the extent to which the DVD CCA CCS license does or does not prevent copying content
from DVDs.
As with your warnings to us, I must reiterate the warning that this may prove overbroad when it comes to
conducting actual searches.
C. Documents discussing actual or potential harm/injury/damage as a result of RealDVD.
As I mentioned on the phone today, we are not planning to collect from individuals whose only responsive
documents (i) were generated after the execution of the tolling agreement, at a time when litigation was plainly
anticipated; and (ii) would thus be work product. If there are any such documents that are not work product, we will
collect and produce them.
D. Reports/analyses/studies/presentations regarding harm caused by Kaleidescape.
E. Documents comparing Real or RealDVD with Kaleidescape.
In addition to those categories, to which we have agreed, you asked for:
F. High level reports/presentations regarding

1. copying by buyers, borrowers or renters of DVDs
2. the extent to which renters or borrowers do not buy DVDs
3. the extent to which illegal copiers of DVDs do not buy DVDs
4. the extent to which persons who buy or rent do not also purchase digital copies
5. calculations/estimates of losses due to piracy/illegal copying of DVDs and other forms of content
6. bases/methodologies for such calculations/estimtes
7. characteristics of persons who engage in piracy/illegal copying of DVDS and other forms of content
8. consumer perception of piracy or illegal copying of digital content
We appreciate your narrowing your request from "documents" to "high level reports/presentations" but, as we
tried to explain on the phone, we believe that the request remains so broad that the studios could not possibly collect,
review and produce responsive documents within the time we have. Moreover, we shared with you our relevancy
concerns regarding many of the documents in this category. If you want to try to narrow the request, we will reconsider it
in good faith, as we have others. I urge you to do so just as soon as possible, though, as we are beginning a collection
procedure, and hope to avoid (as I know you hope to avoid) the need to circle back to custodians whose documents
already have been collected. NB to Tracy: I just received your email attempting to narrow these, and we discussed some
concepts on the phone. I will get back to you about those.
G. Documents filed in legal proceedings where studios have invoked 3rd party beneficiary rights under the DVD
CCA CSS license.
We will produce any such filed documents that are not sealed.
H. Testimony from studio witnesses in The Cartoon Network v. CSC Holdings
I am checking on protective orders and confidentiality concerns. Subject to what I learn, we are inclined to
provide responsive materials.
3
Please correct any misunderstandings immediately. As with all of our previous exchanges of such document requests,
we make these without prejudice to seeking any other documents or information later in the proceedings.
Lawrence C. Barth
Munger, Tolles & Olson LLP
355 South Grand Avenue, 35th Floor
Los Angeles, California 90071
(213) 683-9274 - phone

(213) 683-5174 - fax
lawrence.barth@mto.com
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4
EXHIBIT E
Aull, Ashley
From: Barth, Lawrence
Sent: Thursday, November 06, 2008 11:08 AM
To: Tosh Lane, Tracy; mberta@wsgr.com
Cc: ~REALDVD; Lambert, Mark F.; Steer, Reginald; Dan Robbins@mpaa.org
Subject: Protective Order and Document Discovery Issues
Importance: High
Tracy and Mike:
The following is an attempt to memorialize those issues on which we have agreed, and those on which we have agreed to
disagree, so that we may bring the latter category to the Court's attention immediately.
I. Protective Order -- I believe we have no remaining disagreements except for the following:
A. Definition of "outside counsel"
The studios are free to retain counsel of their choice, and they have chosen to retain Messrs. Robbins and
Goeckner in this case, along with lawyers from Munger Tolles and Mitchell Silberberg. The MPAA (including its legal staff)
regularly provides legal services to its member studios. Thus, for many decades, at least one MPAA lawyer has served as
counsel to the studios. Messrs. Robbins and Goeckner have personally represented the MPAA's member studios
continuously over the course of at least 12 years. As I mentioned to Mike on the phone, your firm is certainly aware of this
prior history with the studios, as Colleen Bal worked with Dan Robbins -- in his role as counsel for the studios -- in the
Sigma case. She never raised an objection to his role in that case. As you will see from the documents we are producing
regarding the other CSS cases, Mr. Robbins has served as counsel in each of them. I can tell you that, in prior litigation,
no court ever has found that Messr. Robbins and Goeckner were not in an attorney-client relationship with member
studios of the MPAA.
Your version of Paragraph 2.9 would exclude Messrs. Goeckner and Robbins from the definition of "Outside Counsel,"
notwithstanding the fact that they are properly of record in this case. In light of the facts we have shared with you, we urge
you to agree to our version of Paragraph 2.9. If you insist on your most recent version of Paragraph 2.9, which would
exclude Messrs. Robbins and Goeckner, you should consider that we are at impasse and we will take it up with the Court.
B. Definition of "house counsel"
You originally proposed a definition (in Paragraph 2.10) that would include only lawyers who are "employees of a
party." I explained that, the way the studios are organized, some in-house lawyers who are working on this case are
formally employed by affiliated entities who are not the "parties" in the caption. Based on that fact, we proposed that the
definition be expanded to "employees of a party or affiliated entity." I understand the concerns you expressed on the
phone the other day regarding the possibility of that allowing us to share Real's confidential information with any lawyer at
any affiliate of a party. I told you that certainly wasn't our intent -- that we plan to go on sharing information only with the
lawyers who are involved in this litigation (whether or not their paychecks match the names in the caption). With your
concern in mind, however, I proposed the following: "House Counsel: attorneys who are employees of a Party or an
affiliate of a Party who (i) who are actively involved in this litigation on behalf of a Party; and (ii) to whom disclosure is
reasonably necessary for purposes of this litigation." Please let me know today if that is acceptable. If you insist on
sticking with your "employees of a party" formulation, you should consider that we are at impasse.
C. Definition of "expert"
We cannot agree to your attempt to disqualify all studio employees as consultants or experts. As I tried to
explain, there is no basis on which to prohibit the studios from consulting with employees who have extensive expertise in
the relevant technologies. In view of the deadlines under which we are operating, such a prohibition would only serve to
prevent the studios from preparing their case. If the studios wish to share information with such persons, they will be
obliged to give you notice and an opportunity to object. In light of that protection, there is simply no basis for a blanket
prohibition on such consultation. If you insist on language disqualifying all such persons, we are at impasse.
D. Source Code
1
We are in agreement with counsel for the DVD CCA on this issue, and you should consider his communications
to reflect our views, as well.
II. Studios' Requests to Real -- Except as noted, the numbering below refers to my email to you dated Oct. 28
(5.28 pm). The following is, of course, subject to the bilateral protocols to which we agreed in earlier emails, and is
without prejudice to positions we may take in discovery following a PI hearing.
A. Source Code
We repeatedly have asked you to provide source code immediately. You agreed to advise us, by no later than
today, of your position on source code so that we can bring it to the attention of the Court promptly if need be.
B. Documents referring to the design and/or development of RealDVD
Based on early discussions, we agreed to narrow our request as follows:
1. Documents constituting architecture, technical or design specifications or documentation for RealDVD,

including all drafts or versions of specifications or documentation.
You agreed to produce documents referring to the design and/or development of the final version of RealDVD,
but indicated that you would not produce documents "constituting architecture, technical or design specifications or
documentation" of prior versions of the software, if any. We cannot agree. To the extent the architecture or design of the
product changed during its development, such changes would be highly relevant. In light of our agreement to restrict our
request only to documents constituting architecture, specificiation or documentation, we do not believe the burden would
outweigh such relevancy.
2. Proposals, planning documents and test cases relating to RealDVD
Here again, you told us you would not produce "drafts." We are not, at this juncture, asking for all documents
(including emails) concerning these subject matters, but only proposals, planning documents and test cases themselves.
If those documents changed over time, we think that previous versions are (i) relevant; and (ii) you have not indicated
they would be hard to find and collect. The terms we used are ones that we got from engineers, who told us they should
call for only a narrow universe of docs. We stand on our request.
With respect both to B.1. and B.2, we requested early production of such documents as you can collect from the
most likely person to have them and those reporting to him (we are prepared to take your representation as to whether
that person is Mr. Buzzard or someone else). Will you kindly advise me today whether you are willing to make such an
early production?
D. Documents containing the terms “CSS” and “License”
You represented that you have identified between 50,000- 60,000 documents in the possession of your target
custodians containing these terms. If you will confirm that those are unique hits (i.e., that they are de-duped across and
within custodians) and that they do not contain a very high percentage of easy-to-identify non-responsive documents
(using readily available IT tools that we discussed), we will be willing to tailor our search accordingly. Please advise.
G. Documents containing the terms “MacTheRipper,” “DeCSS,” “DVD X,” “Slysoft,” “Plato” “Handbrake” or “rip!”
As above, you represented that the inclusion of the term "rip" resulted in your identifying approximately 60,000
documents from targeted custodians. Again, If you will confirm that those are unique hits and that they do not contain a
very high percentage of easy-to-identify non-responsive documents, we will be willing to tailor our search accordingly,
e.g., we may be willing to consider "rip" w/5 "movie" or "DVD." Please advise.
H. Documents containing the terms “rent!” or “borrow!” and “RealDVD”.
You represented that this search yielded some 30,000-40,000 documents from targeted custodians. Obviously,
these terms are of real significance, and we ask you to (i) de-dupe them; and (ii) have a look at a few hundred randomly-
chosen documents so as to let us know why the yield is so high. Once we understand the facts, we will be pleased to
tailor the search, if need be.
J. Documents containing the terms “DVD CCA” or “CCA”.

2
You represented that this search resulted in approximately 10,000-15,000 documents. Please de-dupe them and
let us know a count. You were going to consider ways of narrowing this. We look forward to your thoughts today.
Priority Requests -- We have requested that you produce source code, fully functional RealDVD software,
and priority B.1. and B.2. documents immediately, and explained that without them our experts cannot hope to
complete their work within the time allotted. You agreed to advise us of your position by today, so that we may
bring this issue to the Court's attention promptly, if need be.
III. Real's Requests to the Studios -- This supplements my my email to you dated Oct. 28 (5.28 pm), and the
numbering remains the same. Once again, the following is subject to the bilateral protocols to which we agreed in earlier
emails, and iswithout prejudice to positions we may take in discovery following a PI hearing.
A. Docments comprising or referring to communications (i) within a studio (ii) between or among studios; (iii)
between a studio (or studios) and the DVD CCA; and (iv) between a studio (or studios) and any member(s) of the Board
of Directors of the DVDCCA or CPAC discussing:
1. negotiation and development of the DVD CCA CSS license agreement; and
2. proposed amendments to the DVD CCA license agreement from January 1, 2007 to the present
regarding
a. whether a DVD must be physically present in the DVD drive during playback; or
b. prohibiting or permitting copying of DVD content
First, we clarified that the term "and" at the end of A.1. should be changed to "and/or." We also agreed that the
term "or" at the end of A.2.a. should be changed to "and." Next, I told you I would confirm that the January 1, 2007 date
was appropriate to capture all of the "disc-in-tray" amendments you said you were concerned with, and I can confirm that
it is. Finally, you asked that we add to this request any pre-DVD CCA CSS licenses. We will do so.
C. Documents discussing actual or potential harm/injury/damage as a result of RealDVD.
I confirmed for you that we are not planning to collect from individuals whose only responsive documents (i) were
generated after the execution of the tolling agreement, at the direction of counsel, and at a time when litigation was plainly
anticipated ; and (ii) would thus be work product.
F. High level reports/presentations regarding

1. copying by buyers, borrowers or renters of DVDs
2. the extent to which renters or borrowers do not buy DVDs
3. the extent to which illegal copiers of DVDs do not buy DVDs
4. the extent to which persons who buy or rent do not also purchase digital copies
5. calculations/estimates of losses due to piracy/illegal copying of DVDs and other forms of content
6. bases/methodologies for such calculations/estimtes
[You withdrew your requests nos. F.7. and F.8.]
We will agree to go to one appropriate high-level person in the home video division or department of each
studio and collect high level reports and presentations that are in active files (we will not to search dead storage, off-site
storage, etc.) concerning consumer behavior on topics F.1. through F.4. To go beyond that would, based on the
information provided to us, entail searches that are not possible in the time available, and would likely yield documents
that could not be reviewed in the time available. With respect to F.5. and F.6., we have considered your arguments and
believe that any potential relevancy would be marginal in this setting, that it is outweighed by burden concerns in the short
time frame available to us, and that the request is beyond the Court's instruction to seek discovery of that which the
parties really need at the PI stage.
G. Documents filed in legal proceedings where studios have invoked 3rd party beneficiary rights under the DVD
CCA CSS license.
Please see my email dated Thursday 10/30/2008 at 12:00 PM. We should have these documents ready to
produce to you very shortly.
3
H. Testimony from studio witnesses in The Cartoon Network v. CSC Holdings
Please see my email dated Wednesday, 10/29/2008 at 6:35 PM. We await word from you as to whether you
really want us to go down the road of giving notice to necessary parties in that case, and providing them with an
opportunity to object and intervene in this case. I'm sure you understand that, if you ask us to follow that course, there
can be no assurances that documents will be produced within the deadlines we have been discussing.
B.-E. We are in the process of collecting and filtering, and will give you information regarding key-word hits as soon as
possible.
Let me now turn to your additional requests first set forth in an email dated October 28 (2:45 pm).
High level reports or presentations, including SWOT analysis (strengths, weaknesses, opportunities, threats),
relating to "Managed Copy," "Digital Copy" and "Burn-to-DVD" as those terms are used in the Declaration of Michael
Dunn.
We will agree to go to one appropriate high-level person in the home video division or department of each studio
and collect high level reports and presentations that are in active files (we will not to search dead storage, off-site storage,
etc.) concerning the topics you list. Again, to go beyond that would, based on the information provided to us, entail
searches that are not possible in the time available, and would likely yield documents that could not be reviewed in the
time available.
Documents relating to the pricing of "Managed Copy," "Digital Copy" and "Burn-to-DVD" as those terms are used
in the Declaration of Michael Dunn.
We will agree to go to one appropriate high-level person in the home video division or department of each studio
and collect high level reports and presentations that are in active files (we will not to search dead storage, off-site storage,
etc.) concerning the topics you list. Again, to go beyond that would, based on the information provided to us, entail
searches that are not possible in the time available, and would likely yield documents that could not be reviewed in the
time available.
Documents related to the CSS License Agreement and "Managed Copy", "Digital Copy" or "Burn-to-DVD" as
those terms are used in the Declaration of Michael Dunn, including the implementation of "Managed Copy", "Digital
Copy" or "Burn-to-DVD" under the CSS License Agreement or the relationship between "Managed Copy", "Digital Copy"
or "Burn-to-DVD" and the CSS License Agreement.
We have considered your arguments, and believe that this request goes well beyond the subject matters that
need to be discovered at this juncture. Moreover, as I explained to you, the burden of collection and review would be
great, as the issue of Managed Copy in the context of the CSS license has been the subject of considerable discussion
for a significant period of time. As a compromise, we propose to produce (or work with the DVD CCA in producing) any
actual proposed amendments dealing with the subjects you discuss in this request and the following request.
Documents related to any proposed or contemplated amendments to the CSS License Agreement relating to
"Managed Copy", "Digital Copy" or "Burn-to-DVD" as those terms are used in the Declaration of Michael Dunn.
See above.
Documents sufficient to explain the technology underlying "Managed Copy", "Digital Copy" and "Burn-to-DVD" as
those terms are used in the Declaration of Michael Dunn, including technical specifications, schematics, design and
development documents.
We do not believe that the technologies involved in Managed Copy, Digital Copy or Burn-to-DVD have anything to
do with this case. To the extent there might be some relevancy argument, we further believe that such technologies are
at most tangential, and that the burden of collection and production far outweighs any current need. Accordingly, and are
not prepared to search for or produce such documents..
Please let me know if I have misstated anything we discussed, or if you have any questions.
Lawrence C. Barth
Munger, Tolles & Olson LLP
355 South Grand Avenue, 35th Floor
4
Los Angeles, California 90071
(213) 683-9274 - phone

(213) 683-5174 - fax
lawrence.barth@mto.com
5
EXHIBIT F
Page 1 of 1
Aull, Ashley
From: Singla, Rohit

Sent: Friday, April 10, 2009 5:02 PM
To: 'Tosh Lane, Tracy'; 'Cunningham, Leo'
Cc: 'Steer, Reginald'; Klaus, Kelly; Pomerantz, Glenn
Subject: FW: open discovery issues
Tracy & Leo --
I am writing to follow-up on a few open discovery issues. Could you let us know the status of
these:
1. Mr. Basche's testified that he had found a "back-up" of his documents relating to RealDVD, but
we have never seen those to our knowledge. Can you please let us know whether and when Real
will produce those?
2. Recently Real produced what appears to be a selected excerpt of documents relating to Ms.
Hamilton. Can you let us know whether Real will produce all documents it has relating to Ms.
Hamilton's hiring, termination, reviews, correspondence with her since her termination, and the
patent applications that she testified about?
3. Mr. Bielman mentioned records kept by the QA group relating to testing of Facet on
ARccOS/RipGuard protected disks, including testing of a version of Facet that used "DVD Walk" to
copy all DVDs. Mike Berta said he would look into those records, but we have not (to my memory)
heard anything further about them. Can you let us know whether and when Real will provide
those?
4. Mr. Dixon offered to provide a number of documents, including documents that he had provided
you. Can you please provide those promptly?
Thanks
6/23/2009

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Case3:08-cv-04548-MHP Document428-1 Filed06/24/09 Page1 of 133

Mike and Tracy:

D. The parties will not search for documents on back-up media.

I. Studios' Document Requests

1. Documents constituting architecture, technical or design specifications or documentation for RealDVD,

2. Proposals, planning documents and test cases relating to RealDVD.

2. Documents containing the terms: "playback" or (play! /3 cop!)

3. Documents containing the terms: "authenticat!"

4. Documents containing the terms: "CGMS" or "CopyNever"

6. Documents containing the terms: "CPR_MAI" or "CPRMAI"

7. Documents containing the terms: "edf"

8. Documents containing the terms: "file rip!" or "file cop!"

10. Documents containing the terms: "lead-in" or "lead in" or "leadin"

11. Documents containing the terms: "sector header!"

12. Documents containing the terms: ("disc" or "disk") /2 key

13. Documents containing the terms: "bus encrypt!"

14. Documents containing the terms: ("bad" or "unreadable") /3 ("sector" or "data")

K. Documents containing the terms “Kaleidescape”. You found this acceptable.

M. Pleadings in RealNetworks v. Streambox. You found this acceptable.

II. Studios' Collection of Documents

b. prohibiting or permitting copying of DVD content.

C. Documents discussing actual or potential harm/injury/damage as a result of RealDVD.

D. Reports/analyses/studies/presentations regarding harm caused by Kaleidescape.

E. Documents comparing Real or RealDVD with Kaleidescape.

In addition to those categories, to which we have agreed, you asked for:

F. High level reports/presentations regarding

H. Testimony from studio witnesses in The Cartoon Network v. CSC Holdings

(213) 683-9274 - phone

Tracy and Mike:

A. Definition of "outside counsel"

B. Definition of "house counsel"

B. Documents referring to the design and/or development of RealDVD

Based on early discussions, we agreed to narrow our request as follows:

1. Documents constituting architecture, technical or design specifications or documentation for RealDVD,

2. Proposals, planning documents and test cases relating to RealDVD

D. Documents containing the terms “CSS” and “License”

H. Documents containing the terms “rent!” or “borrow!” and “RealDVD”.

J. Documents containing the terms “DVD CCA” or “CCA”.

b. prohibiting or permitting copying of DVD content

C. Documents discussing actual or potential harm/injury/damage as a result of RealDVD.

F. High level reports/presentations regarding

(213) 683-9274 - phone

From: Singla, Rohit

Tracy & Leo --

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