N.D. Ga. Patent L.R. 3.1

(a) These Rules do not excuse any party from responding to any

proper discovery request made under the Federal Rules of Civil Procedure

within the time required by such rules, except as follows:

(1) Requests seeking to elicit a party=s claim construction

position;

(2) Requests seeking to elicit from the patent claimant a

comparison of the asserted claims and the accused technology;

(3) Requests seeking to elicit from an accused infringer a

comparison of the asserted claims and the prior art; and

(4) Requests seeking to elicit from an accused infringer the

identification of any opinions of counsel, and related documents, that

it intends to rely upon as a defense to an allegation of willful

infringement.

(b) Disclosure of such information shall instead be made pursuant

to these rules, absent stipulation of the parties or other order of the Court.