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SCO Asks for More Time and IBM Says Just Show Us the Code, Already
Tuesday, October 21 2003 @ 05:29 AM EDT

SCO is asking for more time to respond to IBM's Motion to Compel and is also asking for more time to get its discovery done in response to IBM's interrogatories and request for documents. IBM has opposed the first, saying that SCO is just stalling, and doesn't fight the second. Why is this significant? Normally, asking for a one-week delay wouldn't be something you'd be likely to oppose, unless you thought the other side was deliberately stalling or playing games and you wanted the judge to know and intervene.

In SCO's Motion asking for more time to respond to the Motion to Compel, they tell the judge that IBM didn't dot its I's and cross its T's properly in the Motion to Compel according to some local Utah court rule, DUCivR 37-1(b), they have dug up and that anyway, they are working as fast as they can, and so no such motion is needed. In the course of working things out between the lawyers, they say, they volunteered to provide IBM with supplemental responses to some of the interrogatories, but IBM filed its Motion to Compel instead of agreeing to SCO's offer. SCO then was served by a second set of interrogatories and request for documents by IBM, and answering the second set "intertwines" with the first set of answers, SCO says, and so they can't finish in time on the first. They don't like the intro to IBM's Motion to Compel and they are informing the judge, on the basis of the local Utah rule, that they believe it is moot, but they will answer the Motion to Compel but need more time.

IBM says the real problem is that SCO doesn't want to show the code and is stalling to avoid it. All they have to say is that they will provide everything IBM has asked for. How long does it take to say that? SCO, they say, is dancing around and won't commit to providing everything IBM asked for. They're showing their code to anyone else who rolls into Lindon and is willing to sign an NDA, IBM points out, but they haven't provided it to us, and they won't commit to doing so. The material is already ready to be provided without requiring more time to prepare it, because they are showing it to others. IBM says it offered to withdraw its motion to compel if SCO would just agree that it would provide all the materials and information requested in IBM's first set of interrogatories and request for documents, and SCO then would have had one more week. But SCO's refusal to agree to do that and instead file for more time indicates to IBM, they say, that the real problem is SCO doesn't want to comply fully and is just looking for a delay. The case has been going on for 7 months already and discovery for 15 weeks, with SCO showing its "evidence" right and left and making public statements about IBM having behaved improperly, so, now it's time to provide the materials requested, IBM argues.

On the Utah law SCO is trying to use, IBM says they can hardly give detailed explanations of exactly what is missing from SCO's answers when they haven't provided anything meaningful in the way of answers. The problem isn't refinement, in other words. It's getting them to respond meaningfully and completely. Anyway, they say, they did provide an addendum detailing what they want, and, IBM says, curled lip showing, this formatting issue hardly makes it impossible for SCO to know what they are supposed to cough up because of the list being in one place instead of another in the document. IBM is mocking their "inability" to know what is being requested. We've been in discussions for a long time now, IBM points out. They know already. Using a procedural issue like this is exactly what judges usually don't like, by the way, if it's obviously just a tactic, and that is the way IBM is viewing it.

They don't mind, they tell the judge, giving SCO a little more time on the interrogatories, but they do object to giving them more time to respond to the Motion to Compel. It doesn't take two weeks to respond by saying, Yes, we will provide everything IBM has asked for in one week. And that is all they have to say in response, if they plan on doing just that, IBM argues.

Once again, we owe Frank Sorenson a debt for getting all the court documents. He even made a text version for us of IBM's opposition document. The rest are pdfs. So here is SCO's Plaintiff's Motion for Enlargement of Time to Respond to Defendant IBM's Second Set of Interrogatories and Second Request for Production of Documents. Next, is SCO's Motion for Enlargement of Time to Respond to Defendant IBM's Motion to Compel Discovery here , and here is IBM's Memorandum in Opposition to Plaintiff's Motion for Enlargement of Time to Respond to IBM's Motion to Compel Discovery as a pdf. And saving the best for last, here it is as text. In short, things are not friendly:

[UPDATE: If you are interested in the rules relating to discovery, go here and read up on the Rule 26 of the Federal Rules of Procedure and here on sanctions.}

*********************************

Alan L. Sullivan (3152)
Todd M. Shaughnessy (6651)
SNELL & WILMER LLP
[Address]
[Phone]
[Fax]

Evan R. Chesler (admitted pro hac vice)
David R. Marriott (7572)
CRAVATH, SWAINE & MOORE LLP
[Address]
[Phone]
[Fax]

Attorneys for Defendant/Counterclaim-Plaintiff
International Business Machines Corporation

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF UTAH

THE SCO GROUP, INC.


Plaintiff/Counterclaim-Defendant,

against

INTERNATIONAL BUSINESS
MACHINES CORPORATION,

Defendant/Counterclaim-Plaintiff.

MEMORANDUM IN OPPOSITION
TO PLAINTIFF'S MOTION FOR
ENLARGEMENT OF TIME TO RESPOND
TO IBM'S MOTION TO COMPEL
DISCOVERY

Case No. 2:03CV-0294 DAK

Honorable Dale A. Kimball

Magistrate Judge Brooke Wells

Defendant/Counterclaim-Plaintiff International Business Machines Corporation ("IBM"), through counsel, respectfully submits this memorandum in opposition to the Motion

for Enlargement of Time to Respond to IBM's Motion to Compel Discovery submitted by Plaintiff/Counterclaim-Defendant The SCO Group, Inc. ("SCO").

In its Amended Complaint, SCO alleges that IBM has misappropriated or misused SCO's trade secrets in violation of SCO's rights. SCO has publicly touted its evidence of IBM's alleged misconduct and has disclosed its supposed evidence to countless third-parties. At the same time, in a case that has been pending for more than seven months, SCO has repeatedly refused to provide meaningful responses to IBM's discovery requests.

After giving SCO more than 15 weeks to comply voluntarily with IBM's discovery requests (which were served on June 13, 2003), IBM was required to move to compel responses to its first set of interrogatories. That is true despite the fact that SCO does not dispute -- indeed, could not dispute -- that IBM is entitled to the information that it has requested in the interrogatories.

In a further effort to resolve the parties' dispute, IBM advised SCO, upon submitting its motion, that, if SCO would promptly provide IBM with the information IBM has requested, then IBM would withdraw its motion. In the negotiations leading up to IBM's motion, SCO acknowledged that it was required to supplement its interrogatory responses, which are inadequate, but SCO consistently declined even to commit to provide IBM with all of the information it has requested (thus necessitating IBM's motion).

Two days before it was required to respond to IBM's motion, SCO proposed that IBM consent to a deferral of SCO's obligation to respond to the motion. SCO stated that, because SCO intends to supplement its interrogatory responses next week and because "IBM will be very happy with SCO's supplemental responses", the opposition should be deferred. If IBM

2

were not satisfied with SCO's supplemental responses, SCO further proposed, briefing on the motion could then resume.

To give SCO the benefit of the doubt, we suggested that, if SCO truly intends to provide IBM with all of the information that IBM has requested next week, then SCO should simply respond to IBM's motion by advising the Court that it will provide IBM next week with all of the information that IBM has requested and that, from SCO's perspective, IBM's motion is therefore moot. We further stated that if, in fact, SCO provides IBM with all of the information that IBM has requested, then (in its reply brief) IBM will so advise the Court and withdraw its motion. We proposed that approach because, in light of SCO's non-production to date, we are frankly not confident that SCO will, in fact, satisfactorily respond to IBM's outstanding requests. We, therefore, attempted to obtain SCO's formal commitment while not derailing the motion process.

Tellingly, SCO refused to proceed in this fashion. In so doing, SCO made clear that it does not, in fact, intend to provide IBM with all of the information that IBM has requested. If SCO did intend to do so, there is no reason why it would not follow IBM's suggestion. There is not, we submit, a more efficient way to proceed, assuming SCO intends to provide IBM with the information that it has requested, as opposed to merely seeking additional delay.

We would ordinarily consent to a request for a brief extension of time. In fact, IBM has, upon request, offered SCO several extensions of time in this litigation. IBM opposes SCO's present request for an extension, however, because we believe that SCO has deliberately delayed providing meaningful answers to IBM's interrogatories. Moreover, inasmuch as SCO plainly does not intend to provide IBM with all of the information it has

3

requested, we believe that SCO's request for an extension is simply another attempt at further unnecessary delay.

Although it had two weeks to prepare a response to IBM's motion, SCO submitted its request for an extension minutes before the expiration of its deadline. In support of its motion for an enlargement of time, SCO makes two primary arguments -- both without merit.

First, SCO states that IBM's motion to compel runs afoul of DUCivR 37-1(b) because, SCO says, the motion does not provide "a succinct statement, separately for each objection, summarizing why the response received [for each objection] was inadequate." That is not so. IBM moved to compel because SCO offered essentially no response to IBM's interrogatories, as we explained to SCO repeatedly over the course of many weeks and as IBM's motion papers make clear. Moreover, in support of its motion, IBM submitted an addendum that explains in great detail why SCO's response (or, more accurately, lack thereof) to each of IBM's interrogatories is deficient. Even a cursory examination of IBM's motion makes clear that SCO's claim that its ability to respond to IBM's motion has been complicated by the "format of IBM's Motion to Compel Discovery" is untenable.

Second, SCO contends that IBM's motion is premature. As stated, this case has been pending for more than seven months. IBM served its interrogatories over four months ago. As detailed more fully in IBM's motion to compel, it is undisputed that IBM is entitled to complete, meaningful answers to those interrogatories, but also it has refused to commit to provide IBM with all of the information that it has requested. At the same time, as stated, SCO has repeatedly disclosed its supposed evidence to any third-party that would sign

4

a non-disclosure agreement, as well as many who have not. As SCO's CEO puts it, "[E]very day, more people roll into here in Lindon, and we show them the code".

While, again, we do not object to SCO's having a few extra days to supplement its responses to IBM's interrogatires, we do not believe that there is any reason to defer SCO's obligation to respond to IBM's motion. If, as it has represented, SCO intends to supplement its interrogatory answers to provide IBM with the information that it seeks, then SCO should not need more than the two weeks it has already had to respond to IBM's motion. It need only say that it intends to provide IBM with the information it has requested.

Contrary to SCO's suggestion, it will not be unduly prejudiced by not being granted a further extension of time that it did not seek until minutes before the expiration of the two-week period it had to respond to IBM's motion. There is nothing for SCO to say in response to IBM's motion except that it will provide all of the information IBM has requested. As stated in IBM's motion, SCO does not claim the right to withhold responsive information based on any of its boilerplate objections to these interrogatories. By contrast, further delay will compound the prejudice imposed upon IBM by SCO's delay of more than three months. This case has been pending more than seven months, and SCO has still failed to disclose what its claims are about.

We respectfully request that SCO's motion be denied. We wish to emphasize that we would not normally object to a one week extension or trouble the Court with a memorandum on the subject. We have done so here only because of our genuine concern that SCO has not conducted itself appropriately.

5

Dated this 17th day of October, 2003.

SNELL & WILMER LLP

___[signature]___
Alan L. Sullivan
Todd M. Shaughnessy

CRAVATH, SWAINE & MOORE LLP
Evan R. Chesler
Thomas G. Rafferty
David R. Marriott

6

CERTIFICATE OF SERVICE

I hereby certify that on the 17th day of October, 2003, a true and correct copy of the MEMORANDUM IN OPPOSITION TO SCO's REQUEST FOR ENLARGEMENT OF TIME was served on the following by U.S. Mail, postage prepaid and facsimile transmission on:

David Boies
BOIES, SCHILLER & FLEXNER LLP
[address]

Stephen N. Zack
Mark J. Heise
BOIES, SCHILLER & FLEXNER LLP
[address]

Leonard K. Samuels
Fred O. Goldberg
BERGER SINGERMAN
[address]

and service by hand delivery was made upon:

Brent O. Hatch
Mark F. James
HATCH, JAMES & DODGE, P.C.
[address]

___[signature]___

7


  


SCO Asks for More Time and IBM Says Just Show Us the Code, Already | 146 comments | Create New Account
Comments belong to whoever posts them. Please notify us of inappropriate comments.
SCO Asks for More Time and IBM Says Just Show Us the Code, Already
Authored by: Anonymous on Tuesday, October 21 2003 @ 07:16 AM EDT
Keep up the good work PJ!
Just wondered if the "meny" in "as well as meny who have
not" was in the orginal IBM memo or if it's just a typo?

[ Reply to This | # ]

SCO Asks for More Time and IBM Says Just Show Us the Code, Already
Authored by: Anonymous on Tuesday, October 21 2003 @ 07:18 AM EDT
Please excuse a foreigner's ignorance, but I would have thought that as this
case is being heard in a Federal court, the rules and applicable laws would be
those pertaining to Federal courts. Even though the court is physically located
in Utah does not mean that Utah procedures would apply, or do they?

I would have thought that an application based on a rule that is not applicable
would irritate the Judge.

Am I seeing this correctly or am I in error?

[ Reply to This | # ]

SCO Asks for More Time and IBM Says Just Show Us the Code, Already
Authored by: fjaffe on Tuesday, October 21 2003 @ 07:20 AM EDT
This is more great work. Thanks PJ and Frank Sorenson, from another Groklaw
addict.

Since I'm getting an incredible legal education here, maybe someone can tell
me:

1. How long it will be until the Judge rules on these motions?

2. What are the implications if SCOX loses this (besides teh obvious one that
they have to comply)? Is there a specific time limit that then applies to them
providing good details?

Is there an implication that anything that SCOX fails to provide in discovery is
then barred from use later in the case?

[ Reply to This | # ]

SCO Spin Doctors
Authored by: Nathan Hand on Tuesday, October 21 2003 @ 07:45 AM EDT

SCO seems determined to misinterpret everything in their favour.

In a memo for IBM sales representatives obtained by Reuters, the New York-based computer company said "SCO is asking customers to pay money based on pure unsubstantiated threats, without offering any facts." ...

SCO Spokesman Blake Stowell said the memo was a sign that IBM saw SCO's claims as a viable threat.

Even an outright dismissal is somehow validation of SCO's claims, in the eyes of the SCO faithful.

[ Reply to This | # ]

GPL and Derivative code (OT)
Authored by: Anonymous on Tuesday, October 21 2003 @ 08:08 AM EDT
Slightly off topic, but I have been wondering about the definition of a derived work.

My understanding of the GPL is that if I take a GPL'd work, add new functionality, and then compile the resulting program so that the new part is linked either statically or in a shared library with the GPL'd part then my part is a derived work and must come under the GPL. The GPL FAQ has this to say:

If the modules are included in the same executable file, they are definitely combined in one program. If modules are designed to run linked together in a shared address space, that almost surely means combining them into one program.
My concern here is that this is exactly what IBM have done with RCU etc. There is a contradiction here which might play to SCOs favour - if the GPL definition of a derived work is deemed to be the valid one then SCO have a case against IBM (i.e. that RCU is a derived work of SYS V), but if the GPL defintion is found to be invalid this might have consequences for free software.

Any thoughts on this theory (IANAL!)

Sean

[ Reply to This | # ]

On the RBC investment - which 'client'
Authored by: tcranbrook on Tuesday, October 21 2003 @ 08:32 AM EDT
The following article in the ITBusiness.ca has an interesting quote:

http://www.itbusiness.ca/index.asp?theaction=61&lid=1&sid=53813

"RBC spokesman Chris Pepper refused to explain the investment, or how it
would respond to any potential complaints from customers who make their living
selling open source products.

"We have a policy of not commenting on anything we do for clients,"
he said."

I wonder just which 'client' they are talking about? It could be SCO, but
perhaps it is the source of the funds in the first place. I can understand day
trader speculators and insiders trading the stock. But I can't for the life of
me understand how a regulated bank can put money into such a deal. If it is
depositers money they are investing here, I would assume that Canadian bank
regulations would require some degree of due diligence that SCO could not
possible survive. If it's not depositor fund, then whos money are they
investing? Perhaps that is the 'client' thy are refereing to.



[ Reply to This | # ]

SCO Asks for More Time and IBM Says Just Show Us the Code, Already
Authored by: burySCO on Tuesday, October 21 2003 @ 09:14 AM EDT
Have I got this right? SCO instigates this lawsuit accusing IBM of (among other
things) missapropriating SCO's code & donating it to the Linux kernel; this
code is now publicly availiable to anyone in the world who wishes to download it
or pick it up at a BestBuy outlet.

More than 6 months have passed. IBM says "Ok, please point out to us which
code is infringing". SCO says to the judge "We need more time to
decide whether or not we can ever possibly do that".

Unless I misunderstand things, surely the judge would see this as an obstruction
of justice and demand that SCO now commit to identifying this code to IBM (by
some mutually agreeable date), since SCO is suing IBM over the use of this code
(if indeed it exists). If not, then what am I missing?

---
My jabber handle is burySCO@jabber.org

[ Reply to This | # ]

2+2=5, Black is White etc..
Authored by: jobsagoodun on Tuesday, October 21 2003 @ 09:26 AM EDT
In a memo for IBM sales representatives obtained by Reuters, the New York-based computer company said "SCO is asking customers to pay money based on pure unsubstantiated threats, without offering any facts.''

The memo told IBM sales representatives: "Remember, we are counting on you to make sure that customers with questions or concerns get the correct facts.''

SCO Spokesman Blake Stowell said the memo was a sign that IBM saw SCO's claims as a viable threat.

"I think they are taking the threat seriously otherwise they wouldn't be informing their salespeople about that,'' he said. "We've had a lot of customers suggest they'd be interested in taking out a licence.''

Nrargh! Have we already introduced the word Stowelism into the english language? I can just see it after they get cremated in court...

"The Judge clearly supported SCO by ruling infavour of IBMs counterclaims and awarding them damages of $5,000,000,000. If SCO's claims had been unfounded, the damages would have been much less."

http://news.zdnet.co.uk/software/0,39020381,2138193,00.htm

[ Reply to This | # ]

New PR attack - critisizing SCO = terrorism
Authored by: Anonymous on Tuesday, October 21 2003 @ 10:11 AM EDT
I rather expected this sooner or later. Looks like its sooner. It from our
favorate, Rob Enderle.

http://www.technewsworld.com/perl/story/31899.html

"I've watched these people fabricate stories about my own job history and
events that I've written about -- as they were happening. These Zealots have
been the primary reason that I've come to believe SCO will likely win its
lawsuit -- because if the Zealots are lying about facts I know to be true, they
must be lying about facts I don't know about."

Not only are you bad people attacking SCO, but him personally! Just wait until
the Department of Homeland Security hears about this!




[ Reply to This | # ]

OUCH! That's a lethally worded motion!
Authored by: Anonymous on Tuesday, October 21 2003 @ 10:11 AM EDT
They dipped into the extra-special vintage reserve vitriol to fill the pen that
wrote that thing. Vocabulary like "touted" and "if SCO truly
intends" is rarely seen in motions.

And A friend commented via jabbre: "Reading between the lines, IBM is
obviously suggesting that the Court do the "Bailiff, whack him on the
pee-pee" thing. Seven months after the case was filed, and SCO still
needs an extension to provide the grounds for the suit? Counsel for Plaintiff
are supposed to have all that lined up before filing. This really is leading up
to the Court making a Rule 11 inquiry.
"

[ Reply to This | # ]

Career Limiting?
Authored by: overshoot on Tuesday, October 21 2003 @ 10:20 AM EDT
Do I read correctly that IBM is well along towards having this case dismissed as frivolous?

It sure looks like TSG is refusing to state a cause of action after seven months, and the Plaintiff's Counsel is putting off the day of reckoning as long as possible by wasting the Court's time. This latest Motion practically begs the Court to start its own Rule 11 inquiry.

Last I heard, this would be a distinctly career-limiting move for Plaintiff's Counsel.

[ Reply to This | # ]

Same style of argument
Authored by: Anonymous on Tuesday, October 21 2003 @ 11:38 AM EDT
There's another example here of that particular style argument where they
simply reverse whatever they are accused of.

IBM says in their motion to compel discovery, that SCO is not providing the
specific information that IBM requested and is entitled to.

SCO responds that it's IBM motion to compel discovery that is not specific in
its demands

[ Reply to This | # ]

OT but wow
Authored by: ijramirez on Tuesday, October 21 2003 @ 12:09 PM EDT
Any one want to fall fglat on your behind laughing must read this artcle from
Steve Ballmer. The article is full of quotable gems about how MS is so much
better because they pay thgeir developers to produce insecured code as opposed
to Linux bunch of coders from China (hehehe, the communits innuendo again).
http://searchwin2000.techtarget.com/originalContent/0,289142,sid1_gci932906,00.h
tml

[ Reply to This | # ]

Friends reunited?
Authored by: Anonymous on Tuesday, October 21 2003 @ 12:26 PM EDT
Altiris Prices Follow-on Public Offering:

Altiris, Inc. (Nasdaq: ATRS) today announced that it has priced the sale of 3,000,000 newly issued shares of its common stock by the Company and 2,000,000 shares of its common stock by a selling stockholder at $18.75 per share. The Company will not receive any of the proceeds from the sale of shares by the selling stockholder. The Company has also granted the underwriters a 30-day option to purchase up to an additional 750,000 shares of common stock to cover over-allotments, if any.

Credit Suisse First Boston is acting as lead manager in the offering, and the co-managers are Deutsche Bank, RBC Capital Markets, First Albany Corporation and D.A. Davidson & Co.

AMENDMENT NO. 1 TO FORM S-3 REGISTRATION STATEMENT

Go to page 57, and you'll see Canopy is selling 2,000,000 of its 3,989,092 shares.

As an aside for legal beavers, page 53's section on legal proceedings is kind of interesting.

[ Reply to This | # ]

What about the IBM countercharges?
Authored by: piskozub on Tuesday, October 21 2003 @ 01:10 PM EDT
If the judge declares the SCO lawsuit frivolous, what happens to the IBM
counter-suit?

[ Reply to This | # ]

Vanishing documents and discovery
Authored by: tcranbrook on Tuesday, October 21 2003 @ 04:40 PM EDT
After the embaresments of thier email in the MS monopoly trial, MS promised the
world vanishing email. THey are delivering that in the new Office/Server
combination.

http://www.newscientist.com/news/news.jsp?id=ns99994295


How is this kind of thing going to be handled with discovery proceedings? What
are the rules about records retention?

[ Reply to This | # ]

SCO Asks for More Time and IBM Says Just Show Us the Code, Already
Authored by: Anonymous on Tuesday, October 21 2003 @ 05:33 PM EDT
Is SCO stalling because they want to put the trial off as long as possible, or
because their is something in the code that would blow their case as soon as it
was revealed, so the suit would be dismissed and never come to trial?

As to the latter, I have this idea that maybe SCO never did the code comparisons
that they are talking about, or they did but found only a few similarities,
instead of the thousands of ones they keep saying they found. I know that sounds
like a crazy idea, but think of all the crazy things we have seen out of SCO so
far.

[ Reply to This | # ]

SCO Asks for More Time and IBM Says Just Show Us the Code, Already
Authored by: Anonymous on Tuesday, October 21 2003 @ 09:37 PM EDT
<blockquote>Dated this 17th day of October, 2003</blockquote>

Should not of something have happened with this already?

[ Reply to This | # ]

OT: groklaw link
Authored by: Anonymous on Wednesday, October 22 2003 @ 06:38 AM EDT
On this Inquirer page I don't want to point out the artical but the Groklaw icon in the right column.

Hans

[ Reply to This | # ]

  • OT: groklaw link - Authored by: Anonymous on Tuesday, December 30 2003 @ 03:42 AM EST
Groklaw © Copyright 2003-2013 Pamela Jones.
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Comments are owned by the individual posters.

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