Document gbyQdmjQGObDp48pMvwrraD59

INTERROGATORY NO. 130: Was this Defendant ever allowed to use the trademark or logo { of any other company, including but not limited to, its predecessor or related company, on any products Defendant sold, distributed or installed, and if so please state: (a) The trademark or iogo used by you; (b) The company allowing such use of its trademark or logo; (c) The time period such use was allowed: (d) Whether such use was by written, verbal or implied agreement: (e) Each and every product such trademark or logo was placed upon; (f) Identify all documents which refer to, relate to or reflect the use of such trademark or logo. ANSWER TO INTERROGATORY NO. 130: Abex objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, compound, vague and ambiguous and calls for speculation. Abex also objects to this interrogatory on the grounds that the terms "any other company" and "related company" are vague and ambiguous and call for speculation. \ Abex further objects to this interrogatory on the ground that it purports to shift the burden of establishing product identification from plaintiffs to Abex. Abex objects to this interrogatory to the extent it purports to seek information or materials regarding time periods and products that are not at issue in these cases, on the grounds that such information or materials lack relevance and are not reasonably calculated to lead to the discovery of admissible evidence. ; Abex also objects to this interrogatory to the extent to which it purports to seek information or materials that have been gathered, received or prepared in the course of litigation. f -291-