I know this is the part of the kitchen sink defense... the goal is to keep us running around with all these the dfendants,,,, but if you dont infringe why ask exclude products.....
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1. Category 1
Respondents seek the exclusion of CX-0168 and CX-0169 because they were produced
after the discovery cutoff. In order to conserve the time and resources of the ALJ and parties,
Complainants hereby withdraw CX-0168 and CX-0169, but reserve the option of using these
documents for impeachment purposes.
2. Category 2
Respondents seek the exclusion of entire deposition transcripts as exhibits. Pursuant to
Respondents’ requests, Complainants provided Respondents with designations to replace entire
transcripts. Complainants request that their deposition designations be entered as replacement
exhibits, as explained more fully below in subsection 3.
2
To the extent Complainants’ deposition designations are not entered pursuant to
stipulation and Ground Rule 8.6.9, the deposition transcripts in Respondents’ Category 2"
