N.D. Cal. Patent L.R. 3-4

With the “Invalidity Contentions,” the party opposing a claim of patent infringement shall

produce or make available for inspection and copying:

(a) Source code, specifications, schematics, flow charts, artwork, formulas, or other

documentation sufficient to show the operation of any aspects or elements of an Accused

Instrumentality identified by the patent claimant in its Patent L.R. 3-1(c) chart;

(b) A copy or sample of the prior art identified pursuant to Patent L.R. 3-3(a) which does not

appear in the file history of the patent(s) at issue. To the extent any such item is not in

English, an English translation of the portion(s) relied upon shall be produced;

(c) All agreements that may be related to the accused instrumentality or may be comparable

to a license that would result from a hypothetical reasonable royalty negotiation;

(d) Documents sufficient to show the sales, revenue, cost, and profits for accused

instrumentalities identified pursuant to Patent L.R. 3-1(b) for any period of alleged

infringement; and

(e) All agreements that may be used to support the party denying infringement’s damages

case.

The producing party shall separately identify by production number which documents

correspond to each category.