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| IBM Reply Memorandum in Support of Motion to Compel Discovery |
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Wednesday, November 05 2003 @ 03:24 AM EST
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There are developments in the SCO v. IBM case. IBM is pressing forward aggressively with its Motion to Compel Discovery, despite SCO giving it Supplemental Answers to IBM's discovery requests, which IBM characterizes as inadequate.
IBM filed in Utah, on November 3, a Reply Memorandum in Support of its Motion to Compel Discovery (available at http://www.groklaw.net/pdf/IBM-63.pdf )and an addendum to it. It isn't available yet on the free Pacer list, but it should be soon. Then on the 4th, IBM filed a certificate of service regarding its Responses and Objections to SCO's First Request for Admissions. That is not yet available online.
Here, as text, is its Reply Memorandum. The PDF is at http://sco.tuxrocks.com/Docs/IBM/Doc-86.pdf. Here are the operative paragraphs:
"Put bluntly, SCO's public relations efforts are at odds with its conduct in this litigation. SCO has made repeated, public accusations of IBM's supposed misconduct, while refusing to disclose its alleged evidence to IBM. Either SCO has evidence to support its accusations or it does not. If it does, IBM is entitled to see it now; if it does not, IBM will be entitled to dismissal of this case. In any event, it is time for SCO to respond properly (although belatedly) to IBM's discovery requests.
"In our opening brief, we explained that while SCO has publicly touted its alleged evidence of IBM's supposed misconduct, it has refused to disclose that evidence to IBM in any meaningful way. Nothing has changed. SCO purports to answer some of IBM's questions with its supplemental discovery responses, but they come nowhere close to providing us with the information IBM requested, and to which IBM is entitled under the Rules. SCO refuses altogether to answer some of IBM's requests. . . .
"To give the false impression that it has responded to Interrogatory No. 1, SCO lists 591 files from unidentified versions of the Linux 2.4 and/or Linux 2.5 kernels. According to SCO, these files include or may include "information (including methods) that IBM was required to maintain as confidential or proprietary". (Exh. A at 3-6, 7-19.) While this information is partially responsive to Interrogatory Nos. 3(d), 4(d) and 12 (which ask SCO to identify all of the places in which its trade secrets and confidential or proprietary information are found), it does not respond to Interrogatory No. 1. Interrogatory No. 1 asks for the identification of files and lines of code from Unix that SCO contends IBM has misappropriated. It is Unix software, after all, not Linux software, that IBM is alleged to have misappropriated. . . .
"Thus, in its supplemental responses, SCO says (in effect), that it has or might have rights in some of the approximately 335,000 lines of code that SCO has identified (or the methods embodied in that code), but SCO is not saying what or where that code is. That, according to SCO, is for IBM to figure out."
IBM also cites some cases that it says show that SCO can't hide behind a "we can't tell you because it is a trade secret" excuse. There are exhibits, but they were not scanned into the court's records, so we'll present them once we are able to obtain them. Following is the complete Reply Memorandum in Support of Motion to Compel Discovery. Enjoy.
*************
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF UTAH
__________________
THE SCO GROUP, INC.,
Plaintiff/Counterclaim-Defendant,
vs.
INTERNATIONAL BUSINESS MACHINES CORPORATION,
Defendant/Counterclaim-Plaintiff
__________________
DEFENDANT/COUNTERCLAIM PLAINTIFF INTERNATIONAL BUSINESS MACHINES CORPORATION'S
REPLY MEMORANDUM IN SUPPORT OF MOTION TO COMPEL DISCOVERY
ORAL ARGUMENT REQUESTED
Civil No. 2:03cv0294
Honorable Dale A. Kimball
Magistrate Judge Brooke Wells
____________________
Pursuant to Rule 37 of the Federal Rules of Civil Procedure, Defendant/Counterclaim-Plaintiff International Business Machines Corporation ("IBM"), through counsel, respectfully submits this Reply Memorandum in Support of its Motion to Compel Discovery from The SCO Group, Inc. ("SCO").
PRELIMINARY STATEMENT
IBM brought this motion because SCO refused to provide basic discovery necessary to IBM's defense. In its opposition brief, SCO represents that its supplemental responses to IBM's interrogatories meet SCO's obligations. That is not true, as we discuss below. IBM's motion to compel should be granted.
Put bluntly, SCO's public relations efforts are at odds with its conduct in this litigation. SCO has made repeated, public accusations of IBM's supposed misconduct, while refusing to disclose its alleged evidence to IBM. Either SCO has evidence to support its accusations or it does not. If it does, IBM is entitled to see it now; if it does not, IBM will be entitled to dismissal of this case. In any event, it is time for SCO to respond properly (although belatedly) to IBM's discovery requests.
In our opening brief, we explained that while SCO has publicly touted its alleged evidence of IBM's supposed misconduct, it has refused to disclose that evidence to IBM in any meaningful way. Nothing has changed. SCO purports to answer some of IBM's questions with its supplemental discovery responses, but they come nowhere close to providing us with the information IBM requested, and to which IBM is entitled under the Rules. SCO refuses altogether to answer some of IBM's requests.
SCO does not dispute that it is obliged to provide IBM with the information IBM has requested. In cases of this kind, courts have repeatedly found that a plaintiff must, as a matter of fundamental fairness and to permit the just and efficient resolution of litigation, provide meaningful answers to precisely the kinds of questions at issue on this motion. Moreover, SCO does not even attempt to justify its reliance on Rule 33(d) as a substitute for providing answers to IBM's interrogatories. The case law squarely condemns SCO's use of Rule 33(d).
In opposition to IBM's motion, SCO argues that the motion should be denied on the grounds that, in view of SCO's supplemental discovery responses, it is moot. In addition, SCO complains generally that we have distorted the facts and circumstances relating to this motion. SCO's opposition to this motion is baseless.
First, IBM's motion is not moot. SCO has not provided IBM with the information that it has requested and to which it is entitled, as illustrated in Section I below and described in more detail in the Addendum hereto.
Second, SCO's complaints that IBM has distorted the facts and circumstances relating to this motion are misplaced. Each of SCO's complaints is refuted in Section II below.
As is further discussed below, IBM's motion to compel should be granted. SCO should be required to provide IBM with the information it has requested, on the terms set out in the proposed order submitted herewith.
ARGUMENT
I. IBM's MOTION IS NOT MOOT.
Careful review of IBM's requests and SCO's responses makes clear that IBM's motion is not moot. In truth, SCO's supplemental responses serve merely to give the superficial impression of compliance with SCO's obligations. The shortcomings of SCO's responses are detailed in the Addendum hereto and illustrated by the following example.
IBM's Interrogatory No. 1 asks SCO to "identify, with specificity (by product, file and line of code, where appropriate) all of the alleged trade secrets and any confidential or proprietary information that plaintiff alleges IBM misappropriated or misused. . . ." The case law makes clear that IBM is entitled to this information at the outset of the litigation. (See Defendant/Counterclaim-Plaintiff IBM's Memorandum of Support of Motion to Compel Discovery ("Opening Br.") at 9-10.) Nowhere in its opposition does SCO dispute these authorities. Nor, again, does SCO attempt to defend its initial misplaced reliance on Rule 33(d).
Although the gravamen of SCO's case is that IBM misappropriated SCO's rights to Unix software, SCO's supplemental response to Interrogatory No. 1 fails to identify a single allegedly-misappropriated Unix file or line of code -- not one. (See Plaintiff's Supplemental Response to Defendant's First Set of Interrogatories, appended hereto as Exhibit ("Exh.") A.) Instead, SCO reiterates its previous references to broad categories of "UNIX software design methods" and lists the "technical Unix categories" included in its original response to Interrogatory No. 1. (Exh. A at 3.) As stated in our opening brief, however, SCO's descriptions are so vague as to be essentially meaningless. In fact, SCO does not identify any of the methods it purports to own; it merely describes the categories in which these methods supposedly fail (e.g., multi-processor locking and unlocking methods). Merely disclosing the category in which a method falls says next to nothing about what the method is. There are, as SCO knows, entire publicly available books addressing certain categories of what SCO appears to mean by Unix "methods". See, e.g., Uresh vahalia, Unix Internals: the New Frontiers (1996). The only way for SCO properly to identify any of the methods at issue is for it to disclose the lines of code that implement the method that SCO contends IBM has misappropriated.
To give the false impression that it has responded to Interrogatory No. 1, SCO lists 591 files from unidentified versions of the Linux 2.4 and/or Linux 2.5 kernels. According to SCO, these files include or may include "information (including methods) that IBM was required to maintain as confidential or proprietary". (Exh. A at 3-6, 7-19.) While this information is partially responsive to Interrogatory Nos. 3(d), 4(d) and 12 (which ask SCO to identify all of the places in which its trade secrets and confidential or proprietary information are found), it does not respond to Interrogatory No. 1. Interrogatory No. 1 asks for the identification of files and lines of code from Unix that SCO contends IBM has misappropriated. It is Unix software, after all, not Linux software, that IBM is alleged to have misappropriated.
Even if Interrogatory No. 1 called for the identification of Linux files, however (which it does not), SCO's listing of 591 Linux files is inadequate. SCO fails to identify the precise releases of the Linux kernel in which these files are found. That is no small problem since there are 75 different releases of the Linux kernel 2.5 alone. Moreover, ignoring all but the version of each file in a single release of Linux (and thus underestimating significantly the number of lines of code at issue), there are approximately 335,000 lines of code in the files identified by SCO. SCO does not contend that it has rights to (or that IBM misappropriated) all 335,000 lines of this code. SCO states that it "does not contend that the entire source code in all files identified . . . contains proprietary and confidential information and/or trade secrets. Rather, information (including code and methods) that IBM agreed to maintain as confidential is interspersed through parts of each identified file." (Exh. A at 7; see also id, at 19.) Thus, in its supplemental responses, SCO says (in effect), that it has or might have rights in some of the approximately 335,000 lines of code that SCO has identified (or the methods embodied in that code), but SCO is not saying what or where that code is. That, according to SCO, is for IBM to figure out.
It is beyond reasonable debate that SCO has not provided IBM with the information requested in Interrogatory No. 1. the same is true with respect to each of the interrogatories at issue, as summarized in the Addendum. By way of further example, SCO has failed adequately to disclose the nature and source of SCO's rights to the methods that it alleges IBM has misappropriated, the persons to whom the methods have been disclosed, the places in which they are found and the particulars of each instance of alleged misappropriation -- to list just a few of the deficiencies in SCO's supplemental interrogatories. The specificity that IBM seeks here is no more exacting than the specificity compelled by other courts in similar cases. See, e.g., Lynchval, 1996 WL 735586 at * 6-8 (affirming sanctions against plaintiff where in response to defendant's interrogatory asking for each allegedly stolen trade secret, plaintiff responded that "'the structures and respective organizations of the . . . software constitute protectable trade secrets'" and holding that "(t)his vague description does not constitute notice of any trade secret."); Microwave Research Corp. v. Sanders Associates, Inc., 110 F.R.D. 669, 673-74 (D. Mass. 1986) (halting broad discovery of defendant where plaintiff listed products and methods that it claimed embodied trade secrets rather than the trade secrets themselves); Struthers Scientific and Int'l Corp. v. Gen. Foods Corp., 51 F.R.D. 149, 153 (D. Del. 1970)(granting defendant's motion to compel a m ore responsive answer where plaintiff indicated that trade secrets could be found in some "unique combination" of its listed trade secrets, and requiring plaintiff to "specifically describe what particular combination of components it has in mind, howe these components are combined, and how they operate in a unique combination").
II. SCO'S COMPLAINTS ARE MERITLESS AND IRRELEVANT.
Rather than address its shortcomings, SCO complains that IBM distorts the facts and circumstances relating to the present motion. SCO's complaints are misplaced.
First, SCO complains that IBM mischaracterizes SCO's lawsuit by characterizing it as a case about the alleged misappropriation of trade secrets. (See Plaintiff's Memorandum of law in Opposition to IBM's Motion to Compel Discovery ("Opposition Br.") at 2-3.) That is so, SCO says, because SCO asserts six causes of action, only one of which is for the alleged misappropriation of trade secrets. It is true that SCO asserts five additional causes of action. But three of the five allege that IBM breached its contractual obligations to SCO by disclosing trade secrets or confidential information, and the other two, in SCO's own words, "flow from" IBM's alleged breaches of contract based upon the disclosure of SCO's trade secrets or confidential information. To the extent it matters, there is no question that the gravamen of SCO's case concerns the alleged misuse of trade secrets or confidential information.
Second, SCO complains that IBM mischaracterizes SCO's presentation at the SCO Forum, which we understand (reasonably, we believe) to describe the kinds of misappropriation SCO alleges against IBM. (See Opposition Br. at 6-7.) According to SCO, not all of the misconduct described in the presentation is attributable to IBM. We are pleased with SCO's acknowledgment that its presentation does not accurately describe IBM's conduct. There is, however, no question that the presentation was designed to give a false impression as to the presentation to our opening brief as Exhibit F), IBM is the only company SCO has sued and the only company mentioned in the presentation; the presentation purports to quote from the agreements IBM is alleged to have breached (Opening Br. Exh. F at 6-7, 17); the presentation specifically identifies bodies of code (however indeterminate) that SCO's complaint attributes to IBM, e.g., JFS (id at 19); the presentation purports to quote an IBM copyright attribution identifying two IBM employees (id. at 21); and the presentation purports to include an IBM email allegedly making an improper "non-literal transfer" of "methods and concepts". (Id. at 22.)
Third, SCO complains that "IBM's claims that it will not respond to discovery until it receives supplemental answers is belated and improper." (ftnt 6 ) (Opposition Br. at 7.) IBM has not made any such claim, and SCO's characterization of IBM's position lacks citation. although the law is clear that IBM may limit discovery until SCO provides the information IBM has requested, IBM has endeavored to move forward with discovery based on the information it has, and we will continue to provide documents to SCO as they become ready for production. (ftnt 7 ) (See Opening Br. at 18.)
CONCLUSION
For the foregoing reasons, IBM respectfully requests that the Court issue an Order compelling SCO to respond to IBM's interrogatories with specificity and in detail.
DATED this 3rd day of November, 2003.
SNELL & WILMER L.L.P.
________________
Alan L. Sullivan
Todd M. Shaughnessy
Amy F. Sorenson
CRAVATH, SWAINE & MOORE LLP
Evan R. Chesler
David R. marriott
Attorneys for Defendant/Counterclaim-Plaintiff
International Business Machines Corporation
Of counsel:
INTERNATIONAL BUSINESS MACHINES CORPORATION
Donald J. Rosenberg
Alec S. Berman
1133 Westchester Avenue
White Plains, New York 10604
(914) XXXXXXX
Attorneys for Defendant/Counterclaim-Plaintiff
International Business Machines Corporation
________________
Footnotes:
1. SCO also argues that IBM's motion was filed prematurely. That is false. This case has been pending nearly seven months. IBM served its first set of discovery requests more than four months ago. IBM filed this motion only after giving SCO more than 3 months to meet is obligations.
2. We did not address SCO's responses to Interrogatory Nos. 12 and 13 in our opening brief. SCO had not then responded to those interrogatories. After seeking an extension of time to submit its responses, SCO has submitted responses to Interrogatory Nos. 12 and 13 that are deficient for the same reasons that its responses to Interrogatory Nos. 1-9 are deficient. Indeed, SCO's responses to Interrogatory Nos. 12 an 13 merely incorporate by reference its responses to Interrogatory Nos. 1-4. In the interests of efficiency, we believe that the Court should rule on the sufficiency of SCO's answers to Interrogatory Nos. 12 and 13 in ruling on this motion. nevertheless, so that it cannot be said that there is any procedural impediment to such a ruling, we intend promptly to move to compel responses to Interrogatory Nos. 12 and 13.
3. A plaintiff cannot satisfy its disclosure obligations by reference to information that "potentially" constitutes trade secrets; rather, it must identify those trade secrets with specificity. See Lynchval Sys. Inc. v. Chicago Consulting Actuaries, Inc., Civ. A. No. 95 C 1490, 1996 WI, 735586, at *6 (N.D. Ill. Dec. 19, 1996).
4. Contrary to SCO's contention, it does not require additional discovery from IBM before providing the information IBM seeks. The identity of SCO's trade secrets or proprietary or confidential information, for example, is peculiarly within SCO's own possession. As the cases cited in IBM's opening brief make clear, SCO is not entitled to further discovery from IBM until it defines exactly what it believes that IBM has misappropriated or misused. (See Opening Br. at 17-18.)
5. Notably, it is SCO (not IBM) that mischaracterizes the case, including in particular its alleged agreements with IBM and Sequent. Suffice it so say here that IBM does not agree with SCO's view of the agreements at issue or IBM's and Sequent's obligations under those agreements.
6. Contrary to SCO's suggestion, IBM timely raised with SCO the fact that its failure to provide IBM with the information that it seeks makes it difficult sensibly to proceed with discovery. IBM objected to a number of SCO's requests as overbroad and unduly burdensome (see IBM's Responses & Objections to SCO's First Request for the Production of Documents and First Set of Interrogatories at 12-13, attached hereto as Exhibit B) and has repeatedly told SCO during negotiations that it cannot reasonably construe the request until it receives more information from SCO about the nature of the alleged misconduct. Once SCO identifies with specificity the Unix code and/or methods that it claims IBM has misappropriated (in response to Interrogatory No. 1) and the locations in Linux where the allegedly wrongful contribution can be found (in response to Interrogatory Nos. 3 and 4), IBM can much better focus its search fro responsive documents from individuals (if any) who made contributions that bear any relationship to the alleged portions of Unix or Linux.
7. As of the date of this submission, IBM has provided over one hundred thousand pages of production documents to SCO. IBM intends to continue rolling its production to SCO, despite the inadequate supplemental responses we have received from SCO.
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| Authored by: Anonymous on Wednesday, November 05 2003 @ 03:57 AM EST |
Excellent to have text version already, PJ.
It's after 10 AM in Greece, buy 3 AM (4 AM?) where you are.
Thanks for your dedication, but get some sleep.[ Reply to This | # ]
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| Authored by: Steve Martin on Wednesday, November 05 2003 @ 04:23 AM EST |
Wow.
Real life intrudes, so I can't enjoy this as much as it deserves right now, but
it sure looks like IBM is calling SCO's busted flush. I can't wait to see what
kind of response comes from Boies et co.
BTW, what the heck is up with SCO stock?? Seems the Novell announcement might
have shot it to the root (at least the timing matches up).
[ Reply to This | # ]
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| Authored by: Anonymous on Wednesday, November 05 2003 @ 04:32 AM EST |
I had to laugh that IBM had given SCO 100,000 pages of documentation.
IBM: According to SCO, not all of the misconduct described in the presentation
is attributable to IBM.
According to SCO _none_ of the misconduct described at the show was attributed
to IBM. Here is the text:
SCO: The slides from the SCO Forum trade show relied upon by IBM (IBM Mem.,
Exhibit F), corroborate that SCO has not publicly made any such allegation
against IBM.
I was confused about Rule 33(d). What is that? The only reference I could find
was this:
"(d) Form of Interrogatories and Answers. A party propounding
interrogatories shall provide sufficient space for a response to each
interrogatory. The party responding to interrogatories may either (1) make his
answers on the spaces provided or (2) retype or otherwise reproduce each
interrogatory and state the his answer after each interrogatory, or (3)
disregard the space provided and prepare answers separately from the
interrogatories. If the responding party elects to answer on the space provided
and the space is inadequate, additional pages may be used with a reference in
the space to the additional pages."
http://www.alacourt.org/Publications/Rules/Civil/rule33.htm
I could almost imagine SCO trying to use that, but some how I don't think that
is the actual Rule 33(d)... :P
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| Authored by: Anonymous on Wednesday, November 05 2003 @ 04:37 AM EST |
7. As of the date of this submission, IBM has provided over one
hundred thousand pages of production documents to SCO. IBM intends to continue
rolling its production to SCO, despite the inadequate supplemental responses we
have received from SCO.
I'm sure it's a pretty standard
choking tactic in the legal world to drown the other party under a few
truckloads of paper, but SCO has only themselves to blame here: that's what you
get for keeping to broad concepts and allegations and not being specific in your
claims... [ Reply to This | # ]
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| Authored by: Hygrocybe on Wednesday, November 05 2003 @ 04:45 AM EST |
Yes please - I also echo Steve Martin's last statement - I would VERY much like
to know what is happening to SCO's stock price and especially over the next few
days. Perhaps at last we will see sanity prevail and the truth come out with
respect to SCO's shares and what I believe is their true value.
To me, the Novell purchase of SuSE almost resembles the situation in which a
soccer field has been given new lines and a brand new set of rules; but worst of
all, the whole of the field is now tagged with penalty areas which all have
SCO's name on them. I would dearly love to be a fly on the wall in a couple
of board rooms right now: one of course, is SCO, but there are such incredible
implications within this new situation that I suspect some very interesting
discussions are now taking place somewhere in Redmond.
---
LamingtonNP[ Reply to This | # ]
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| Authored by: DrStupid on Wednesday, November 05 2003 @ 04:48 AM EST |
"If it does, IBM is entitled to see it now; if it does not, IBM will be
entitled to dismissal of this case."
Am I right in thinking this is the first time IBM's filings have explicitly
raised dismissal as a possibility? Of course we knew that a dismissal motion is
the logical last step if a plaintiff refuses to state his/her case with enough
specificity, but there seems a deliberate planting of a seed in this filing.
[ Reply to This | # ]
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- Revving up for dismissal motion? - Authored by: Anonymous on Wednesday, November 05 2003 @ 05:04 AM EST
- Revving up for dismissal motion? - blacklight - Authored by: Anonymous on Wednesday, November 05 2003 @ 05:12 AM EST
- Revving up for dismissal motion? - Authored by: PJ on Wednesday, November 05 2003 @ 05:58 AM EST
- Revving up for dismissal motion? - Authored by: DFJA on Wednesday, November 05 2003 @ 08:05 AM EST
- Revving up for dismissal motion? - Authored by: Anonymous on Wednesday, November 05 2003 @ 09:51 AM EST
- Bahhhhh! - Authored by: Anonymous on Wednesday, November 05 2003 @ 04:11 PM EST
- Bahhhhh! - Authored by: Anonymous on Wednesday, November 05 2003 @ 07:15 PM EST
- Revving up for dismissal motion? - Authored by: skidrash on Wednesday, November 05 2003 @ 09:40 AM EST
- Dismissal, IBM, RH, Novell suits - Authored by: Thomas Frayne on Wednesday, November 05 2003 @ 10:24 AM EST
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| Authored by: Anonymous on Wednesday, November 05 2003 @ 05:18 AM EST |
I intend to read this, in its entirety, tomorrow, but right now I've been out
too late and I'm too drunk to review and comment adequately on the text.
So why am I bothering to respond now?
Well, many SCOX shills, not on this board but elsewhere, have hypothesized that
SCO has an "ace in the hole". I don't think they do. They've never
shown one at any rate. On the other hand, IBM has already revealed its
"ace in the hole". Ultimately, SCO has no standing to sue.
Everything else SCO desires to claim is penultimate to that fact.
While it would be desirable for IBM to slaughter SCO on other issues, what many
of us would consider the more important issues, such as enforcing the GPL,
ultimately, Section 4.16(b) of the APA between Novell and (old) SCO will be
controlling, and there is no way IBM can lose this case. All of IBM's actions
outside the scope of proving that point are, well:
Gravy.
And that's why, and what for, the Open Source community should be grateful.
There wasn't and isn't any need for IBM to litigate the other issues involving
the GPL, etc., exzcept to make a point. That point being to enforce the GPL and
crush the first betrayer of the GPL, i.e. SCO, to ensure that it will never be
betrayed again, or, if it is, that the betrayer will know, in advance, that the
betrayal will not go unchallenged.
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| Authored by: Anonymous on Wednesday, November 05 2003 @ 05:22 AM EST |
Gee, what happened to "over a million lines?"
From SCO Forum:
SMP 829,393 lines (1,185 files)
RCU 109,688 lines (46 files)
NUMA 56,587 lines (101 files)
JFS 32,224 lines (173 files)
Assuming that they included RCU, NUMA and JFS there, they must have scaled down
the SMP claim to ~136,500 lines (271 files).[ Reply to This | # ]
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| Authored by: Khym Chanur on Wednesday, November 05 2003 @ 05:42 AM EST |
| Okay, as far as I can tell, SCO's view of the world is that they have a contract
with IBM saying "You can develop your own stuff, which you don't have to show to
us, but you have to keep it secret from everyone else." How the hell can you
enforce a contract like that? If IBM didn't have to keep the licensor up to
date on what they were doing, then how could the licensor know if the license
was ever broken? The only way to do it would be to do what SCO is doing, saying
"Tell us everything that you've been doing, so we'll actually know what stuff
you developed, so we can see if you broke the contract." But that means that
the contract depends on "fishing" in a lawsuit discovery in order to be
enforced. Can such a license/contract possibly be valid? [ Reply to This | # ]
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- SCO doesn't know it's own trade secrets - Authored by: Anonymous on Wednesday, November 05 2003 @ 05:52 AM EST
- SCO doesn't know it's own trade secrets - Authored by: Khym Chanur on Wednesday, November 05 2003 @ 06:20 AM EST
- SCO doesn't know it's own trade secrets - Authored by: Anonymous on Wednesday, November 05 2003 @ 07:21 AM EST
- SCO doesn't know it's own trade secrets - Authored by: arch_dude on Wednesday, November 05 2003 @ 07:40 AM EST
- SCO doesn't know it's own trade secrets - Authored by: krow on Wednesday, November 05 2003 @ 08:26 AM EST
- SCO doesn't know it's own trade secrets - Authored by: Tsu Dho Nimh on Wednesday, November 05 2003 @ 08:57 AM EST
- SCO doesn't know it's own trade secrets - Authored by: Kevin on Wednesday, November 05 2003 @ 10:29 AM EST
- SCO doesn't know it's own trade secrets - Authored by: rgmoore on Wednesday, November 05 2003 @ 12:24 PM EST
- SCO doesn't know it's own trade secrets - Authored by: J.F. on Wednesday, November 05 2003 @ 01:17 PM EST
- Mitigating damages requirement - Authored by: mflaster on Wednesday, November 05 2003 @ 01:27 PM EST
- SCO doesn't know it's own trade secrets - Authored by: Anonymous on Wednesday, November 05 2003 @ 01:29 PM EST
- Grim Reaper - Authored by: dmomara on Wednesday, November 05 2003 @ 06:51 PM EST
- Grim Reaper - Authored by: dmomara on Wednesday, November 05 2003 @ 07:05 PM EST
- Grim Reaper - Authored by: arch_dude on Wednesday, November 05 2003 @ 09:24 PM EST
- Grim Reaper - Authored by: Anonymous on Wednesday, November 05 2003 @ 11:29 PM EST
- Grim Reaper - Authored by: Anonymous on Thursday, November 06 2003 @ 08:13 AM EST
- SCO doesn't know it's own trade secrets - Authored by: Anonymous on Wednesday, November 05 2003 @ 11:20 PM EST
- SCO doesn't know it's own trade secrets - Authored by: Anonymous on Wednesday, November 05 2003 @ 01:08 PM EST
- Different law - Authored by: overshoot on Wednesday, November 05 2003 @ 09:20 AM EST
- Different law - Authored by: Anonymous on Wednesday, November 05 2003 @ 09:37 AM EST
- Different law - Authored by: Anonymous on Wednesday, November 05 2003 @ 11:34 AM EST
- Different law - Authored by: Anonymous on Wednesday, November 05 2003 @ 11:53 AM EST
- Different law - Authored by: Anonymous on Wednesday, November 05 2003 @ 12:19 PM EST
- Different law - Authored by: Anonymous on Wednesday, November 05 2003 @ 12:13 PM EST
- Different law - Authored by: eric76 on Wednesday, November 05 2003 @ 01:54 PM EST
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| Authored by: eloj on Wednesday, November 05 2003 @ 05:44 AM EST |
that read like.
100K pages. I sure hope this doesn't bog down the
SCOX lawyers too much, going through it all just to make sure there's nothing
for them to use in there.
It'd just be a tragedy if they'd have
to work through all that and get nothing. A tragedy I tell
you. [ Reply to This | # ]
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- a wasteful tragedy - Authored by: Anonymous on Wednesday, November 05 2003 @ 10:29 AM EST
- A piece of art - Authored by: Anonymous on Wednesday, November 05 2003 @ 01:30 PM EST
- A piece of art - Authored by: Anonymous on Wednesday, November 05 2003 @ 04:45 PM EST
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| Authored by: maxhrk on Wednesday, November 05 2003 @ 05:54 AM EST |
my apology for a little offtopic, but i see that novell and linux made a
headline very recently on Foxnews(which i assume talking about partnership or
something else.)
Unforunately I am deaf and T.V. in living room unlike my own room that dont have
closed caption talking about it. POOR ME! *weep* i wish i could tape it right
away but it too late anyway.
---
SCO: Linux... I am your.. father.[ Reply to This | # ]
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| Authored by: Wesley_Parish on Wednesday, November 05 2003 @ 06:17 AM EST |
| I love it when IBM talks straight. "Put bluntly,..." that's one
thing that's
been missing from Societe Commercial de
On-dit! I expect SCO will now claim
it lacks time to process
the information IBM has been giving it, and somehow
try to tie that
in with its inability to provide IBM with discovery. At which
point
I hope the presiding judge will throw SCO's case out, and IBM's
case
will take over. It would be nice if at that point, Novell,
with Su.S.E.
nicely digested, were to initiate a case of breach of
contract and violation of
copyright, etc, based on what SCO
formerly known as Caldera, has done to its
counterparts in the
UnitedLinux consortium, and the copying that is alleged SCO
did
from UnitedLinux1.0/Su.S.E. 8.x to UnixWare 7.1.3 to make
UnixWare at
least partially up-to-date. ---
finagement: The Vampire's veins and
Pacific torturers stretching back through his own season. Well, cutting like a
child on one of these states of view, I duck [ Reply to This | # ]
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| Authored by: Sri Lumpa on Wednesday, November 05 2003 @ 07:16 AM EST |
Notably, it is SCO (not IBM) that mischaracterizes the case,
including in particular its alleged agreements with IBM and Sequent. Suffice it
so say here that IBM does not agree with SCO's view of the agreements at issue
or IBM's and Sequent's obligations under those agreements.
I find
the use of vocabulary (alleged agreements) strange as at first read it seems
that they contest their existence. On second read however I suppose that they
are contesting the particular version of the agreements put forward by SCO
and/or their interpretation. Maybe somebody with more legal experience will care
to explain what this strange use of words means?
Also, I wonder if SCO
will now claim that among the 335,000 lines of code they have referenced there
are more than a million lines that have been misappropriated from Unix :). Such
a claim would be even funnier than all the drivel they have put so
far.
It's also funny to see IBM say about the SCOForum presentation
that SCO made it all about them (cited their contracts, cited some IBM email...)
except for the examples of infringement which are not about them. So, the only
things not about IBM in the presentation are the example of infringement? Not
the way to prove a case.
[ Reply to This | # ]
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| Authored by: John Douglas on Wednesday, November 05 2003 @ 07:27 AM EST |
....Either SCO has evidence to support its accusations or it does not. If it
does, IBM is entitled to see it now; if it does not, IBM will be entitled to
dismissal of this case...
(I love the subtle way IBM is not saying 'with prejudice')
This surely strengthens/proves Red Hats case if SCO fails to produce the
evidence.
[ Reply to This | # ]
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| Authored by: Anonymous on Wednesday, November 05 2003 @ 07:38 AM EST |
Wow! Whoever drafted IBMs reply is getting a bit POed.
I don't see how
SCO can delay being specific any longer.
IBM can justifiably object to a general
fishing expedition.
IBM can justifiably object to attempting to defend against
non-specific allegations.
The judge has to understand what has to be
decided.
One single real example of code found in a specific Linux release
that can be traced back to information SCO provided to IBM.
Can that be so
difficult?
BTW, if you want to see the latest SCOX share movements, type
SCOX into Google and hit enter. The first result gives the current and
historical values. [ Reply to This | # ]
|
- Stock News - Authored by: Anonymous on Wednesday, November 05 2003 @ 08:47 AM EST
- More SCO News - Authored by: sjohnson on Wednesday, November 05 2003 @ 05:28 PM EST
| |
| Authored by: Anonymous on Wednesday, November 05 2003 @ 08:49 AM EST |
It's been a while since we've seen anything on the Redhat front. What's the
timeline like for that?[ Reply to This | # ]
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| Authored by: gumout on Wednesday, November 05 2003 @ 09:37 AM EST |
This is what IBM is alluding to:
Rule 37. Failure to Make or Cooperate in Discovery; Sanctions
.........(b) Failure to comply with order.
...........(2) Sanctions by Court in Which Action Is Pending.
.............(C) An order striking out pleadings or parts thereof, or staying
further proceedings until the order is obeyed, or dismissing the action or
proceeding or any part thereof, or rendering a judgment by default against the
disobedient party;
---
"If people are violating the law by doing drugs, they ought to
be accused and they ought to be convicted and they ought to
be sent up." --- Rush Limbaugh[ Reply to This | # ]
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| Authored by: gumout on Wednesday, November 05 2003 @ 09:47 AM EST |
Darl is gonna enlighten us sinners !!!
May the light of proprietary greed shine down upon you.
http://biz.yahoo.com/prnews/031105/law042a_1.html
---
"If people are violating the law by doing drugs, they ought to
be accused and they ought to be convicted and they ought to
be sent up." --- Rush Limbaugh[ Reply to This | # ]
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| Authored by: StarTux on Wednesday, November 05 2003 @ 11:48 AM EST |
got to give it to IBM, many wondered what they would do, but they seem
to have sat back and let SCO hang themselves quite a bit imho...At least
that is what it seems to me.
I have doubted from almost the beginning that this would ever reach
court...But if SCO's case gets dismissed one would think that SCO would
lose stock (and a lot of it) and maybe IBM will then take the final punch;
Ask for a SEC/FTC investigation into SCO?
I am not in any way legal, para or otherwise :).
Thanks,
Matt [ Reply to This | # ]
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| Authored by: Anonymous on Wednesday, November 05 2003 @ 12:12 PM EST |
Just when I was feeling really down, (Red Hat stops support for the small
folks, my favorite distro gets bought by another comapny (SuSE and NOVELL deal),
SCOX stock goes up and my memory card arrived broken) I read a nice response
from IBM and feel much better again.
Finally some plain spoken words which I have missed before from IBM.
Now I can bear the next SCO attack in court.[ Reply to This | # ]
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| Authored by: Anonymous on Wednesday, November 05 2003 @ 12:13 PM EST |
In paragraph 3 of section 1:
"... in which these methods supposedly fail"
We all know that SCO's methods will fail eventually :-)
But I guess 'fall' would be more in context.
[ Reply to This | # ]
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| Authored by: Anonymous on Wednesday, November 05 2003 @ 12:20 PM EST |
Man, I hope IBM's laywer's have as much fun writting these as I have reading
them!
[ Reply to This | # ]
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| Authored by: Anonymous on Wednesday, November 05 2003 @ 01:00 PM EST |
| Oh boy, SCO is in deep shit. [ Reply to This | # ]
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| Authored by: gadget on Wednesday, November 05 2003 @ 01:06 PM EST |
Wouldn't it be funny if the judge came back and said that he should dismiss
SCO's case against IBM with prejudice, but that he wasn't because he felt SCO
should be complelled to argue their claims so they are out in the open exposed
for the world to see how baseless they are.
Hey, did you hear the one
about McBride and Boies were on this boat and ...
Yes, I know. I've heard
it already. The boat sank, it was the Titanic. [ Reply to This | # ]
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| Authored by: Anonymous on Wednesday, November 05 2003 @ 01:14 PM EST |
does this mean IBM wants faster action han the date already setup before the
magistrate judge?
br3n
[ Reply to This | # ]
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| Authored by: Anonymous on Wednesday, November 05 2003 @ 01:29 PM EST |
does anyone know, "what comes next" and "by when"?
The groklaw "IBM Timeline" was last updated on Monday.
Does anyone know:
1) When Sco will likely answer this (or when it has to answer this by?
2) When the judge is likely reply to this?
The press hasn't seemed to pick this awesome IBM response up very many places
yet. Maybe because they don't know where to find the courtroom proceedings?
[ Reply to This | # ]
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| Authored by: Grim Reaper on Wednesday, November 05 2003 @ 01:36 PM EST |
I'm posting this under it's own heading so it gets noticed.
A while ago, minkwe, posted the comment:
"Don't forget that SCO did not license Unix. They licensed source
code."
to which I responded:
"Since Novell broke up the Unix "IP" and sold the Unix
trademark and
definitions to the Open Group, it could be argued that methods no longer rest
with SCO.
Therefore, their arguments related to Unix methods and know-how are irrefuteably
moot!
NEXT!"
----------------------------------------------------------
This is very important because, even if there is contention over methods or, as
SCO puts it, "ways of doing things", only the Open Group should be
able to claim this. See here:
http://www.opengroup.org/comm/press/who-owns-unix.htm
Therefore that part of SCO's case is moot.
Glory glory Hallelujah! ;-)
---
For the love of money is a root of all kinds of evil (1 Timothy 6:10); R.I.P. -
SCO Group, 2005/08/29[ Reply to This | # ]
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| Authored by: Anonymous on Wednesday, November 05 2003 @ 01:39 PM EST |
| Sorry that this is compleetly OT, but i noticed some verry funny thing in their
press release.
On 3/11 in http://biz.yahoo.com/prn
ews/031103/lam090_1.html
"the world grow their businesses everyday.
Headquartered in Lindon, Utah, SCO has a network of more than 11,000 resellers
and 8,000 developers. "
And on 5/11 in
http://biz.yahoo.com/pr
news/031105/law042a_1.html
Headquartered in Lindon, Utah, SCO has a
worldwide network of more than 11,000 resellers and 4,000 developers.
So they lost 4000 devlopers in one day
:)
Cioa
j.
[ Reply to This | # ]
|
- OT:Press release - Authored by: Anonymous on Wednesday, November 05 2003 @ 01:58 PM EST
- OT:Press release - Authored by: Anonymous on Wednesday, November 05 2003 @ 02:29 PM EST
- OT:Press release - Authored by: Anonymous on Wednesday, November 05 2003 @ 04:25 PM EST
- OT:Press release - Authored by: Anonymous on Wednesday, November 05 2003 @ 05:20 PM EST
- OT:Press release - Authored by: Anonymous on Wednesday, November 05 2003 @ 05:25 PM EST
- OT:Press release - Authored by: Anonymous on Wednesday, November 05 2003 @ 05:42 PM EST
- OT:Press release - Authored by: belzecue on Wednesday, November 05 2003 @ 06:01 PM EST
- OT:Press release - Authored by: Anonymous on Wednesday, November 05 2003 @ 08:11 PM EST
- OT:Press release - Authored by: Anonymous on Wednesday, November 05 2003 @ 07:36 PM EST
- OT:Press release - Authored by: PJ on Thursday, November 06 2003 @ 01:34 AM EST
- OT:Press release - Authored by: Anonymous on Thursday, November 06 2003 @ 02:10 AM EST
- OT:Press release - Authored by: Anonymous on Thursday, November 06 2003 @ 03:04 AM EST
- OT:Press release - Authored by: Anonymous on Thursday, November 06 2003 @ 05:30 AM EST
- OT:Press release - Authored by: Anonymous on Thursday, November 06 2003 @ 10:07 AM EST
- OT:Press release - Authored by: Anonymous on Friday, November 07 2003 @ 05:57 AM EST
- OT:Press release - Authored by: Anonymous on Wednesday, November 05 2003 @ 06:32 PM EST
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| Authored by: Anonymous on Wednesday, November 05 2003 @ 02:15 PM EST |
http://www.pcpro.co.uk/?http://www.pcpro.co.uk/news/news_story.php?id=49712
br3n[ Reply to This | # ]
|
- Indeed - Authored by: Ed L. on Wednesday, November 05 2003 @ 11:45 PM EST
- [OT]: NICE ARTICLE - Authored by: Anonymous on Friday, November 07 2003 @ 08:21 AM EST
| |
| Authored by: Newsome on Wednesday, November 05 2003 @ 03:23 PM EST |
Concerning Darl's coming keynote address
"There's no Free Lunch - Or Free Linux", does anyone else think it would be
great to order (and pay for) a pizza to be delivered to Darl? See, Darl, there
_is_ free lunch _and_ free Linux.
It would be best if it showed up on the
court docket:
Certificate of Service: Free Pizza served on
Plaintiff/Counterclaim Defendant ---
Frank Sorenson [ Reply to This | # ]
|
- No Free Lunch - Authored by: Anonymous on Wednesday, November 05 2003 @ 04:27 PM EST
- No Free Lunch - Authored by: Anonymous on Wednesday, November 05 2003 @ 04:30 PM EST
- No Free Lunch - Authored by: Anonymous on Wednesday, November 05 2003 @ 05:35 PM EST
- No Free Lunch - Authored by: Anonymous on Friday, November 07 2003 @ 08:37 AM EST
- OT - No Free Lunch - Authored by: Flower on Wednesday, November 05 2003 @ 06:48 PM EST
- Go one step further - Authored by: Dark on Wednesday, November 05 2003 @ 06:49 PM EST
- No Free Lunch - Authored by: Anonymous on Friday, November 07 2003 @ 12:07 PM EST
| |
| Authored by: Anonymous on Wednesday, November 05 2003 @ 03:53 PM EST |
here's quite an interesting read also. I wonder if they should get a bigger
shovel, or maybe an excavator to dig this hole.
http://biz.yahoo.com/prnews/031105/law081_1.html[ Reply to This | # ]
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| Authored by: Anonymous on Wednesday, November 05 2003 @ 07:06 PM EST |
Some woolly thoughts/speculation:
* IBM backs Novell's purchase of SuSE, strengthening its Linux position.
* DB gives RHAT a stay/sit/beg/whatever state - nothing in that considering
Redhat's refocusing.
* DB, somehow linked with SCO (it's midnight, I'm tired, so won't check the
archives for any links) sees the IBM/Novell move as SCO-threatening stock-wise,
so gives it a buy rating.
Today SCO started at $17.98, then very quickly peaked at $19.15 (presumably off
the back of the DB recommendation), and then dropped to $17.87 (12c below) at
close.
Questions: what would have happened had DB not made that buy recommendation at
that specific time? who would have suffered had they not done so? who has
benefited from what now that they have? does DB gain/lose anything either way?
Nothing more than idle curiosity right now...
[ Reply to This | # ]
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| Authored by: gadget on Wednesday, November 05 2003 @ 07:11 PM EST |
Is it just me or is IBM putting on a lawyer clinic here? Every time I see
filings from IBM's lawyers, I am just amazed at their excellent work.
Comprehensive in covering all the bases, yet not giving away too much.
SCO's
lawyers on the other hand, IMHO & IANAL, seem like they must be from law
firm of Lawyers-R-Us. I mean, you pretty much can accept the speak/double-speak
PR babble from SCO's execs, but even their lawyers can't seem to keep their
arguments straight.
----------------
Most common word heard
from SCO after an IBM filing: DOH!
If it looks like SCO, smells like
SCO and tastes like SCO, then it must be SCO. Yuck [ Reply to This | # ]
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| Authored by: Anonymous on Wednesday, November 05 2003 @ 07:26 PM EST |
I suggest a very long sub sandwich, perhaps filled with lots of
baloney, and a banner saying "Sublicense This--Up Yours!"
Use Caldera CD's as section dividers and serving plates.
Toothpicks with flags saying "Linux-Free like Speech!"
And we'll need lots of bags of Cheetos (cheat OS pun?) which
everyone can pile next to McBride for an amusing photo op!
[ Reply to This | # ]
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| Authored by: Anonymous on Wednesday, November 05 2003 @ 10:53 PM EST |
This is OT, related to the Redhat front, regarding SCO's threat to sue Linux
users:
I do remember SCO denying they ever threatened to sue Linux users in
their motion to dismiss redhat's suit.
I wonder if anyone else noticed
their "SCOs(cam)ource" FAQ posted in their own website, here:
FAQ
I don't think
there are more than one way to read this (unless you work for SCO, that
is).
My favorite quotes:
11. Why is SCO willing to use litigation
with customers?
... SCO has made it clear that Linux infringes on
SCO’s intellectual property, so the company is left with no other choice but to
provide a license to Linux customers in order to be properly compensated, or to
use litigation. It is SCO’s hope that customers are willing to purchase a proper
license for SCO’s intellectual property.
13. Will SCO sue me as an
end user customer if I don’t buy a license?
... If a customer refuses
to compensate SCO for its UNIX intellectual property found in Linux by
purchasing a license, and the customer is unable to obtain indemnification from
the distributor who provided them with their copy of Linux, then SCO may
consider litigation
And how 'bout this:
14. How can SCO expect me
to purchase a license when its case with IBM hasn’t been resolved yet? What if
SCO loses its case against IBM? Will it reimburse Linux customers who purchased
a SCO IP License for Linux?
Some Linux users have the
misunderstanding that the SCO IP License for Linux hinges on the outcome of the
SCO vs. IBM case. If that case were completely removed, Linux end users would
still need to purchase a license from SCO to use the SCO IP found in Linux.
The IBM case surrounds mis-use of derivative works of SCO UNIX. It does not
change the fact that line-by-line SCO IP code is found in Linux.
I
wonder if Redhat lawyers ever used this document for their lawsuit. They are
virtualy disputing every claim in their own motion for dismissal here!
[ Reply to This | # ]
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| Authored by: webster on Wednesday, November 05 2003 @ 11:04 PM EST |
How could SCO have started down this litigous path without some firm evidence of
their accusations? How can their lawyers have signed the pleadings without a
good faith belief in the truth of their averments? Is there a mole at IBM or a
former employee who will admit to the acts complained of or knowledge thereof?
Would SCO be so smug without such evidence? Did they begin in ignorance of
their contracts and their Code only to learn that none of thier accusations hold
water? Will they give up sufficient discovery to avoid sanctions and continue
their case?[ Reply to This | # ]
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| Authored by: Anonymous on Thursday, November 06 2003 @ 02:23 AM EST |
I just noted this at /.:
http://www.ussg.iu.edu/hypermail/linux/kernel/0311.0/0621.html
Below is the latest message in the thread. Possibly a scriptkiddie?
Dan M
-----------------
Re: BK2CVS problem
From: Scott Robert Ladd (coyote@coyotegulch.com)
Date: Wed Nov 05 2003 - 23:13:33 EST
* Next message: steve: "Re: no DRQ after issuing WRITE"
* Previous message: Fabio Coatti: "Re: test9 and bluetooth"
* In reply to: Larry McVoy: "Re: BK2CVS problem"
* Messages sorted by: [ date ] [ thread ] [ subject ] [ author ]
Larry McVoy wrote:
On Wed, Nov 05, 2003 at 04:48:09PM -0600, Chad Kitching wrote:
From: Zwane Mwaikambo
+ if ((options == (__WCLONE|__WALL)) && (current->uid = 0))
+ retval = -EINVAL;
That looks odd
Setting current->uid to zero when options __WCLONE and __WALL are set? The
retval is dead code because of the next line, but it looks like an attempt
to backdoor the kernel, does it not?
It sure does. Note "current->uid = 0", not "current->uid
== 0". Good eyes, I missed that. This function is sys_wait4() so by
passing in
I just noted this at /.:
__WCLONE|__WALL you are root. How nice.
In other words, the theoretical exploit was inserted by someone clever. Do we
have any idea who?
BTW, good job catching the problem Larry.
--
Scott Robert Ladd
Coyote Gulch Productions (http://www.coyotegulch.com)
Software Invention for High-Performance Computing[ Reply to This | # ]
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| Authored by: Anonymous on Thursday, November 06 2003 @ 05:22 AM EST |
| There's some irony in Fedora naming their latest core release Yarrow (Downloads here) Remember MS called their
latest security folly RMS.
Ken [ Reply to This | # ]
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| Authored by: arch_dude on Thursday, November 06 2003 @ 08:22 AM EST |
We are discussing a particular theory in a thread titled
"SCO doesn't know its own trade secrets."
Here is the theory:
"The gravamen of the SCO complaint is not that IBM disclosed a trade
secret belonging to SCO, but that IBM disclosed a trade secret belonging to IBM,
in violation of a contractual obligation to SCO to maintain the secret."
This theory can described in considerable detail in a very few sentences, but it
is very hard to extract the theory from all of the garbage in SCO's ammended
complaint.
My question is this: I thought that the rules of procedure for court cases were
intended to make things go as smoothly and efficiently as possible, consistent
with fairness and law. If this is in fact SCO's true argument, then shouldn't
SCO be required to make it clear and explicit in the complaint? Is there a rule
somewhere that says in effect "You must clearly state your real complaint.
It's no fair to hide it."?
[ Reply to This | # ]
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| Authored by: SeismoGuy on Thursday, November 06 2003 @ 01:05 PM EST |
New stuff on http://www.utd.uscourts.gov/documents/ibm_hist.html
Another stall tactic?[ Reply to This | # ]
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| Authored by: Anonymous on Thursday, November 06 2003 @ 03:56 PM EST |
Are the various document requests and interrogatories available online?
I'm curious to see if the SCO requests are intended to be a fishing trip.[ Reply to This | # ]
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