Be In, Inc. v. Google Inc. et al

Filing 81

Administrative Motion to File Under Seal Joint Statement #2 and Exhibit B Thereto filed by GOOGLE UK LTD., Google Inc., YouTube, LLC. (Attachments: # 1 Declaration of Riana S. Pfefferkorn in Support of Motion to Seal, # 2 Proposed Order, # 3 Exhibit Redacted Version of Exhibit A to Declaration, # 4 Exhibit Unredacted Version of Exhibit A to Declaration, # 5 Exhibit Redacted Version of Exhibit B to Declaration, # 6 Exhibit Unredacted Version of Exhibit B to Declaration, # 7 Exhibit Exhibit A to Joint Statement (Exh. A to Declaration))(Bal, Colleen) (Filed on 10/11/2013)

EXHIBIT A
to Joint Statement #2

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COLLEEN BAL, State Bar No. 167637
CHARLES TAIT GRAVES, State Bar No. 197923
RIANA S. PFEFFERKORN, State Bar No. 266817
WILSON SONSINI GOODRICH & ROSATI
Professional Corporation
One Market Plaza
Spear Tower, Suite 3300
San Francisco, California 94105-1126
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]

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Attorneys for Defendants
Google Inc. and Richard Robinson

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN JOSE DIVISION
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BE IN, INC., a New York corporation,

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Plaintiff,
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v.
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GOOGLE INC., a California corporation;
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RICHARD ROBINSON; and DOES 1 through 3, )
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Defendants.
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CASE NO.: 5:12-cv-03373-LHK
DEFENDANT GOOGLE INC.’S
FIRST SET OF
INTERROGATORIES TO
PLAINTIFF

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Pursuant to Federal Rules of Civil Procedure 26 and 33 and the Local Rules of the United

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States District Court for the Northern District of California, Defendant Google Inc.

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(“GOOGLE”) hereby demands that Plaintiff Be In, Inc. (“PLAINTIFF”) answer separately and

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truthfully the following interrogatories in writing under oath within thirty (30) days of service.
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DEFENDANT GOOGLE INC.’S FIRST SET OF
INTERROGATORIES TO PLAINTIFF
CASE NO.: CV-12-3373 LHK

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INTERROGATORY NO. 1:

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IDENTIFY WITH PRECISION AND SPECIFICITY EACH AND EVERY ALLEGED

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TRADE SECRET that PLAINTIFF contends GOOGLE unlawfully acquired, used, or disclosed.

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(“IDENTIFY WITH PRECISION AND SPECIFICITY EACH AND EVERY ALLEGED

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TRADE SECRET” as used herein means to provide a specific description of each such alleged

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trade secret, on an individual basis for each such alleged trade secret, in such a manner that the

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exact identity, scope, boundaries, constitutive elements, and content of each such alleged trade

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secret are fully disclosed in writing, in contrast to an agglomerated set of conclusory phrases that

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does not separately list and describe each such alleged trade secret, in contrast to a mere list of

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documents or file names, and with precision above that required by California Code of Civil

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Procedure section 2019.210.)

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INTERROGATORY NO. 2:

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For each ALLEGED TRADE SECRET that PLAINTIFF identified in response to

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Interrogatory No. 1, identify with precision and specificity the individual(s) PLAINTIFF

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contends first created each ALLEGED TRADE SECRET and the date(s) of such creation.

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INTERROGATORY NO. 3:

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For each ALLEGED TRADE SECRET that PLAINTIFF identified in response to

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Interrogatory No. 1, identify with precision and specificity every third party to whom

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PLAINTIFF has ever disclosed each such ALLEGED TRADE SECRET.

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INTERROGATORY NO. 4:

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For each ALLEGED TRADE SECRET that PLAINTIFF identified in response to

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Interrogatory No. 1, identify with precision and specificity the circumstances under which

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PLAINTIFF contends GOOGLE received or otherwise obtained each ALLEGED TRADE

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SECRET, including but not limited to the date(s) when PLAINTIFF contends GOOGLE

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received or obtained each ALLEGED TRADE SECRET, the identity of the GOOGLE

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employee(s) or contractors who received or obtained each ALLEGED TRADE SECRET, and

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any agents or employees of PLAINTIFF who have personal knowledge of each such event.

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DEFENDANT GOOGLE INC.’S FIRST SET OF
INTERROGATORIES TO PLAINTIFF
CASE NO.: CV-12-3373 LHK

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website accessed, and (d) all documents and information relating to your responses to items (a)

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through (c) above.

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INTERROGATORY NO. 16:

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Identify with specificity all evidence that GOOGLE agreed to the CamUp Terms of
Service.

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Dated: May 29, 2013

WILSON SONSINI GOODRICH & ROSATI
By: /s/ Colleen Bal
Colleen Bal

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Attorneys for Defendants
Google Inc. and Richard Robinson

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DEFENDANT GOOGLE INC.’S FIRST SET OF
INTERROGATORIES TO PLAINTIFF
CASE NO.: CV-12-3373 LHK

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