Moonbug Entertainment Limited v. Babybus (Fujian) Network Technology Co., Ltd ( 2023 )

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 MOONBUG ENTERTAINMENT Case No. 21-cv-06536-EMC LIMITED, et al., 8 Plaintiffs, ORDER RE WITNESS DISCLOSURES 9 AND CROSS DISCLOSURES AND v. DEPOSITION DESIGNATIONS AND 10 COUNTERDESIGNATIONS FOR JULY BABYBUS (FUJIAN) NETWORK 7, 2023 11 TECHNOLOGY CO., LTD, et al., 12 Defendants. 13 14 15 The Court has reviewed Plaintiffs’ witness disclosures, Defendants’ witness cross 16 disclosures, Plaintiffs’ deposition designations, and Defendants’ deposition counter-designations, 17 as well as the parties’ objections. The Court makes the following rulings. 18 For future filings of deposition designations and counter-designations, the Court directs the 19 parties to include quotation of the actual language of the designations and cross-designations with 20 the citations. 21 For future filings of disclosures and cross-disclosures of exhibits, the Court directs the 22 parties to include a brief description of each exhibit with the exhibit number. The Court also 23 directs the parties to group common exhibits (e.g., Super JoJo videos, CoComelon works) when 24 making objections that apply to an entire group. 25 26 IT IS SO ORDERED. 27 1 2 ______________________________________ EDWARD M. CHEN 3 United States District Judge 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 DEFENDANTS’ OBJECTIONS TO PLAINTIFFS’ WITNESS DISCLOSURES 1 2 Defendants have made objections to approximately 400 exhibits to be used on July 7, 2023. Docket No. 487. The Court OVERRULES the objections, provided that foundation and 3 authentication are established at trial. The Court RESERVES JUDGMENT on translation issues and will follow the Court’s previously discussed protocol at trial. 4 5 PLAINTIFFS’ OBJECTIONS TO DEFENDANTS’ WITNESS CROSS 6 DISCLOSURES 7 The Court reviewed Plaintiffs’ objections and addresses them below. 8 Witnesses Trial Exhibit No. P’s Objections Court’s Rulings Naiyong Defendant’s Demonstrative 1 Not in The Court 9 Yan evidence or RESERVES Babybus explains “Demonstrative 1 was disclosed in JUDGMENT on 10 taken while playing BabyBus' "Colors" discovery. this objection, app, available for download on the Apple depending on 11 App store at https://apps.apple.com/us/app/ whether the colorsbabybus/id973832743.” Docket No. document was in 12 473. evidence or produces in 13 discovery. 14 Naiyong Defendant’s Demonstrative 2 Not in The Court Yan evidence or RESERVES 15 Demonstrative 2 is a montage taken from disclosed in JUDGMENT on the following publicly accessible YouTube discovery. this objection, 16 links with the specific timestamps of the depending on clips noted in parentheses below. BabyBus whether the 17 is also concurrently serving the full length YouTube videos YouTube video available for download at included within 18 the sendfile provided: have been entered https://www.youtube.com/watch?v=mY1h into evidence. 19 wb-Nxts (1:00-1:13) https://www.youtube.com/watch?v=3havA 20 ZG0cjk (0:52-1:05) https://www.youtube.com/watch?v=gtaMC 21 nC1pGIOops (1:37- 1:52) https://www.youtube.com/watch?v=IAPK7 22 T3iNRc (3:50-4:15) 23 24 DEFENDANTS’ OBJECTIONS TO PLAINTIFFS’ DEPOSITION DESIGNATIONS & 25 PLAINTIFFS’ OBJECTIONS TO DEFENDANTS’ DEPOSITION COUTNERDESIGNATIONS 26 The Court reviewed Defendants’ objections and counterdesignations and Plaintiffs’ 27 designations and objections to the counterdesignations. The Court addresses them below. Witness Deposition D’s Objections and P’s Objections Court’s Rulings 1 es Designation Counter- Designations 2 Shaojie 42:16-43:8 FRE 106; FRCP To the extent OVERRULED (P’s He 32(2)(6) Defendants objection). 3 Q. So Ms. assert their Fang in the *cross-designating designations as Rule 32 also provides 4 BabyBus 43:8-10 affirmative that when “a party offers legal designations, in evidence only part of a 5 department A. That is correct.· FRE 106, FRE deposition, an adverse told you she However, I am not 32(a)(4) party may require the 6 needed -- further (counterdesignati offeror to introduce other certain images communicating ons are permitted parts that in fairness 7 that she with her.· I just only under the should be considered needed to do went ahead and sent rule of with the part introduced.” 8 the the request of the completeness, Fed. R. Civ. P. 32(b)(6); registration documents to her. and Defendants see also Fed. R. Evid. 9 process, cannot avoid this 106 (“If a party correct? requirement by introduces all or part of a 10 A. That's purportedly writing or recorded correct. “redesignating” statement, an adverse 11 Q. And in their counter party may require the response to designations as introduction, at that time, 12 Ms. Fang's affirmative of any other part—or any request, you designations). other writing or recorded 13 looked for and statement—that in located To the extent fairness ought to be 14 images in Defendants considered at the same Flash on your assert their time.”); Charles A. 15 local designations as Wright & Arthur R. computer, affirmative Miller, Federal Practice 16 correct? designations, and Procedure § 2148 (3d A. Well, yes. FRE 32(a)(4) ed. 2010). “This principle 17 Q. And once and FRE 106 is known as “the rule of you located because this completeness” and it 18 those images witness is not exists to avert in Flash on “unavailable.” misunderstanding or 19 your local distortion caused by computer, you introduction of only part 20 outputted of a document or them to recording.” In re Pac. 21 picture files Fertility Ctr. Litig., No. on your 18-CV-01586-JSC, 2021 22 computer, WL 2075560, at *1 (N.D. correct? Cal. May 24, 2021) 23 A. Correct. (citing United States v. Q. And then Vallejos, 742 F.3d 902, 24 you 905 (9th Cir. 2014)). For communicate instance, testimony 25 d or cannot be designated as transmitted counter-designations 26 those under FRCP 36(a)(6) and outputted FRE 106 when they 27 picture files “fail[] to correspond to computer to designated. See 1 Ms. Fang in Chaudhry v. Angell, No. legal in 173-182, 2021 WL 2 response to 4461667, at *8 (E.D. Cal. her request, Sept. 29, 2021), aff'd sub 3 correct? nom. Chaudhry v. A. That is Aragon, 68 F.4th 1161 4 correct.· (9th Cir. 2023). However, I However, Rule 106 is 5 am not . . . essentially a matter of timing, particularly 6 where the material at issue is deposition 7 testimony. If the witnesses at issue had 8 appeared live and testified as to those 9 matters designated in the deposition transcript, 10 Defendants could properly have elicited the 11 clarifying testimony (along the lines of the 12 counter-designations) on cross. This especially so 13 with respect to Plaintiffs’ calling of adverse 14 witnesses. The Court has the power to order the 15 testimony of witnesses. FRE 611. 16 In this instance, this 17 counter-designation completes the last answer 18 in the designation that was cut off, so including 19 it averts misunderstanding or 20 distortion caused by introduction of only part 21 of the deposition. 22 Shaojie *cross-designating FRE 106, FRCP OVERRULED (P’s He 73:15-19, 73:23- 32(a)(6) (not objection). While there 23 74:5, 74:11-22, designated in is no original designation 75:10-11, 75:15-18, response to any here that the counter- 24 75:20-76:10, 76:16- of Plaintiffs' designations would 77:9, 86:20-21, designation). See complete, see above, the 25 86:25-87:10, 87:23- Chaudhry v. Court’s explanation on 88:1 without Angell, No. 173- Rule 611. 26 corresponding to 182, 2021 WL any original 4461667 (E.D. 27 designations Cal. Sept. 29, designations that 1 “fail to correspond to 2 any [designated] deposition 3 testimony”), aff'd sub nom. 4 Chaudhry v. Aragon, 68 F.4th 5 1161 (9th Cir. 2023). Counter- 6 designated testimony also 7 concerns a different exhibit 8 than one discussed in 9 designated testimony. To 10 the extent Defendants 11 assert their designations as 12 affirmative designations, 13 FRE 106, FRE32(a)(4) 14 (counterdesignati ons are permitted 15 only under the rule of 16 completeness, and Defendants 17 cannot avoid this requirement by 18 purportedly “redesignating” 19 their counter designations as 20 affirmative designations). 21 22 Jianing 8:17-18 35:24-36:4, 36:7- To the extent OVERRULED (P’s Gao 11, 36:17- 22 Defendants objection). See above, 23 THE assert their the Court’s explanation WITNESS:· I Q. When I say designations as on Rule 611. 24 was involved "Super JoJo affirmative in JoJo project," do you designations, 25 project. understand what I FRE 32(a)(4) mean? and FRE 106 26 A. Super JoJo because this project means witness is not 27 Season 1, Super “unavailable.” Q.· And what was 1 your role if any on the Super JoJo 2 project? Q.· Were you the 3 main builder of the 3D character 4 modelling of Super JoJo? 5 A.· Correct. Q.· Did you build 6 the Super JoJo 3D model from 7 scratch? A.· Correct. 8 Jianing 25:15 FRE 106; FRCP To the extent OVERRULED (P’s 9 Gao 32(a)(6) Defendants objection). See Court’s A. …was a assert their explanation above on 10 bug, that's *cross-designating designations as FRE 106 and FRCP why I sent 20:7-9; 20:11-14; affirmative 32(a)(6). The cross- 11 this message. 25:13-15; 22:4- designations, designated testimony 23:3; 23:5-14; FRE 106, FRE averts misunderstanding 12 23:17-20 32(a)(4) or distortion caused by (counterdesignati introduction of only part 13 Q. What did Coco ons are permitted of the deposition. do as you referred only under the 14 to it in Exhibit 290? rule of … completeness, 15 THE WITNESS:· I and Defendants just heard about the cannot avoid this 16 syllables Coco in requirement by my communication purportedly 17 with the person “redesignating” who gave me the their counter 18 feedback but I don't designations as know what does affirmative 19 this Coco mean. designations). … 20 THE WITNESS:· To the extent What happened Defendants 21 during that time, I assert their cannot remember designations as 22 clearly.· But affirmative because there was a designations, 23 bug, that's why I FRE 32(a)(4) sent this message. and FRE 106 24 … because this What did you mean witness is not 25 by "fake cut" in “unavailable.” Exhibit 290? 26 A.· It is a technical term used by 27 movement team. technical term used 1 by the movement team"? 2 A.· The camera usage methods in 3 the production of movements. 4 Q.· What do you mean, "camera 5 usage methods in the production of 6 movements"? A.· This question 7 can be directed to movement, because 8 as far as I know when there are bugs 9 in modelling, we can use this fake 10 cut to avoid bugs. Q.· How does using 11 a fake cut avoid bugs? 12 A.· When modelling or when 13 models are used in storyboard, there 14 are bugs like overlapping of 15 images or distortion of figures or they 16 simply do not look real.· So prior to 17 that happening, we can use a lens 18 cutting to avoid that. 19 Q.· What do you mean by "lens 20 cutting"? A.· You can direct 21 this question to movement team.· I 22 only know that there is such a 23 technique but I don't know how to 24 use it.· But I can tell them that this is 25 a possible technique to be 26 used. Q.· That's what you 27 said in Exhibit 290? THE WITNESS:· 1 What I said here was after a bug 2 emerged, we could use lens cutting to 3 solve that. BY MR. TYZ: Q.· 4 How did you know lens cutting could 5 solve that bug? A.· Because this is 6 a way to avoid modelling bug.· 7 This is a technical method to avoid 8 bugs. Q.· And it's what Coco did 9 according to Exhibit 290? 10 … THE WITNESS:· 11 Coco was only a word I heard of 12 when we talked about the bugs.· 13 This was only a word I overheard.· I 14 didn't know what Coco was referring 15 to. 16 Jianing 26:8-17 FRE 106; FRCP To the extent OVERRULED (P’s Gao 32(a)(6) Defendants objection). See Court’s 17 Q. Exhibit assert their explanation above on 291 is a *cross-designating designations as FRE 106 and FRCP 18 message from 26:17-21 affirmative 32(a)(6). This counter- you to designations, designation completes 19 Xinfeng Lin, A. Yes. I wrote this FRE 106, FRE the last answer in the Jian Lin, message same as 32(a)(4) designation that was cut 20 Xiaohiu Chen, the previous (counterdesignati off, so including it averts with a time scenario. So I ons are permitted misunderstanding or 21 stamp April created the models only under the distortion caused by 2nd, 2021, for storyboard but rule of introduction of only part 22 and the text there were bugs. So completeness, of the deposition. says, "The after checking the and Defendants 23 storyboard models, I said using cannot avoid this drawn is the cutting can avoid requirement by 24 same as the bugs. purportedly Coco's cut. It “redesignating” 25 doesn't their counter matter." Do designations as 26 you see that? affirmative A. Yes, I see designations). 27 the message. you wrote in assert their 1 Exhibit 291? designations as A. Yes. I affirmative 2 wrote this designations, message same FRE 32(a)(4) 3 as the… and FRE 106 because this 4 witness is not “unavailable.” 5 Jianing 28:13-23 20:7-9; 20:11- 14; To the extent OVERRULED (P’s 6 Gao 22:4-23:3; Defendants objection). The counter- assert their designation provides 7 designations as context for the terms affirmative “fake cut” and “Coco,” 8 designations, so including it averts FRE 106, FRE misunderstanding or 9 32(a)(4) distortion caused by (counterdesignati introduction of only part 10 ons are permitted of the deposition. only under the 11 Jianing 29:2-14 29:22-24; 30:2 rule of OVERRULED (P’s Gao completeness, objection). See above, 12 and Defendants the Court’s explanation cannot avoid this on Rule 611. 13 requirement by purportedly 14 “redesignating” their counter 15 designations as affirmative 16 designations). 17 To the extent Defendants 18 assert their designations as 19 affirmative designations, 20 FRE 32(a)(4) and FRE 106 21 because this witness is not 22 “unavailable.” 23 Xianyin 6:20-22 See dkt. 473. OVERRULED (D’s 24 Lin objection). Defendants’ objection not clearly 25 XIANGYIN stated. LIN, ·having 26 been first duly sworn 27 testified as Xianyin 7:4-8 See dkt. 473. OVERRULED (D’s 1 Lin objection). Defendants’ objection not clearly 2 Q.· · Will you stated. please state 3 and spell your name? 4 A.· · My 5 name is Lin Xiangyin. 6 English name is Xiangyin 7 Lin, spelled as 8 ·X-i-a-n-g-y- i-n, last name 9 L-i-n. 10 Xianyin 8:6-7 See dkt. 473. OVERRULED (D’s 11 Lin objection). Defendants’ objection not clearly Q.· · And 12 where do you stated. 13 work? A.· · I work at 14 BabyBus. 15 Xianyin 19:7-11 See dkt. 473. To the extent OVERRULED (D’s 16 Lin 18:19-19:4 D ase sf ee rn t d tha en it rs o ob bj je ec ct ti io on n) n. o D t ce lf ee an rd lya nts’ Q. …videos, I designations as stated. 17 was just Q.· · And as part of affirmative asking about your role in leading designations, OVERRULED (P’s 18 CoComelon.· the development of FRE 32(a)(4) objection). See above, 19 Did you S wu ap tce hr J Co oJ Co, o d mid e ly oo nu a bn ed ca F uR seE t h1 i0 s6 t oh ne RC uo lu e r 6t’ 1s 1 e . xplanation watch videos? witness is not 20 CoComelon A.· · Yes.· I would “unavailable.” videos as part usually watch 21 of your job at videos together with children. 22 BabyBus as A.· · Yes.· I would the leader of usually watch 23 the Super JoJo videos together development with children. the 24 team? Super JoJo development team? 25 A. Yes, I did. A.· · I not only watched 26 CoComelon's video, I also 27 watched all of the videos on 1 YouTube. 2 Xianyin 29:1-5 See dkt. 473. OVERRULED (D’s 3 Lin o ob bj je ec ct ti io on n) n. o D t ce lf ee an rd lyan ts’ Q. ·You stated. 4 received Exhibit 18 5 that 6 referenced 18 different 7 CoComelon videos with 8 links to them 9 on YouTube in 2018 before 10 any Super JoJo video 11 ·was 12 developed at BabyBus; 13 correct? A.· · Yes. 14 15 Xianyin 30:7-31:3 See dkt. 473. OVERRULED (D’s Lin objection). Defendants’ 16 objection not clearly stated. 17 Xianyin 33:11-17 See dkt. 473. To the extent OVERRULED (D’s 18 Lin Defendants objection). Defendants’ 33:18-34:4 assert their objection not clearly 19 designations as stated. affirmative 20 designations, OVERRULED (P’s FRE 32(a)(4) objection). See above, 21 and FRE 106 the Court’s explanation because this on Rule 611. 22 witness is not “unavailable.” 23 Xianyin 40:5-8 See dkt. 473. To the extent OVERRULED (D’s 24 Lin Defendants objection). Defendants’ 39:19-21; 39:23-25; assert their objection not clearly 25 40:9- 12; 40:20- designations as stated. 41:3 affirmative 26 designations, OVERRULED (P’s FRE 32(a)(4) objection). See above, 27 and FRE 106 the Court’s explanation because this on Rule 611. witness is not 1 “unavailable.” 2 Xianyin 42:13-18 See dkt. 473. To the extent OVERRULED (D’s Lin Defendants objection). Defendants’ 3 43:7-9; 43:12- 23; assert their objection not clearly 44:12-17; 44:21- designations as stated. 4 45:7 affirmative designations, OVERRULED (P’s 5 FRE 32(a)(4) objection). See above, and FRE 106 the Court’s explanation 6 because this on Rule 611. witness is not 7 “unavailable.” 8 Xianyin 47:24-50:20 See dkt. 473. OVERRULED (D’s Lin objection). Defendants’ 9 objection not clearly stated. 10 Xianyin 53:22-55:9 See dkt. 473. To the extent OVERRULED (D’s 11 Lin Defendants objection). Defendants’ 53:11-17 assert their objection not clearly 12 designations as stated. affirmative 13 designations, OVERRULED (P’s FRE 32(a)(4) objection). See above, 14 and FRE 106 the Court’s explanation because this on Rule 611. 15 witness is not “unavailable.” 16 Xianyin 58:24-59:1 See dkt. 473. To the extent OVERRULED (D’s 17 Lin Defendants objection). Defendants’ 59:2-5; 59:12- 23 assert their objection not clearly 18 designations as stated. affirmative 19 designations, OVERRULED (P’s FRE 32(a)(4) objection). See above, 20 and FRE 106 the Court’s explanation because this on Rule 611. 21 witness is not “unavailable.” 22 23 X Lii na nyin 66:13-67:16 See dkt. 473. O obV jeE cR tiR onU ).L DED ef e( nD d’ as n ts’ objection not clearly 24 stated. 25 Xianyin 69:10-15 See dkt. 473. OVERRULED (D’s Lin objection). Defendants’ 26 objection not clearly stated. 27 objection not clearly 1 stated. 2 Xianyin 81:19-25 See dkt. 473. OVERRULED (D’s Lin objection). Defendants’ 3 objection not clearly stated. 4 Xianyin 110:1-6 See dkt. 473. OVERRULED (D’s 5 Lin objection). Defendants’ objection not clearly 6 stated. 7 Xianyin 113:7-10 See dkt. 473. OVERRULED (D’s Lin objection). Defendants’ 8 objection not clearly stated. 9 Xianyin 116:1-8 See dkt. 473. OVERRULED (D’s 10 Lin objection). Defendants’ objection not clearly 11 stated. 12 Xianyin 119:4-18 See dkt. 473. OVERRULED (D’s Lin objection). See Docket 13 No. 473. 14 Xianyin 119:23-120:6 See dkt. 473. To the extent OVERRULED (D’s Lin Defendants objection). See Docket 15 120:23- assert their No. 473. 121:3;121:5- designations as 16 11;121:13-17 affirmative OVERRULED (P’s designations, objection). See above, 17 FRE 32(a)(4) the Court’s explanation and FRE 106 on Rule 611. 18 because this witness is not 19 “unavailable.” 20 Xianyin 122:7-10 See dkt. 473. OVERRULED (D’s Lin objection). Defendants’ 21 objection not clearly stated. 22 23 Xianyin 122:16-23 See dkt. 473. OVERRULED (D’s Lin objection). Defendants’ objection not clearly 24 stated. 25 Xianyin 123:6-124:16 See dkt. 473. OVERRULED (D’s 26 Lin objection). See Docket No. 473. 27 Xianyin 125:13-23 See dkt. 473. To the extent OVERRULED (D’s 1 Lin Defendants objection). See Docket 124:18- assert their No. 473. 2 125:1;125:3-10 designations as affirmative OVERRULED (P’s 3 designations, objection). See above, FRE 32(a)(4) the Court’s explanation 4 and FRE 106 on Rule 611. because this 5 witness is not “unavailable.” 6 7 Jiachun 6:14-17 See dkt. 473. OVERRULED (D’s Xue objection). 8 Jiachun 7:5-7 See dkt. 473. OVERRULED (D’s 9 Xue objection). 10 Jiachun 8:2-3 See dkt. 473. ALREADY Xue OVERRULED (D’s 11 objection). See Docket No. 473. 12 13 J Xia uc eh un 8:6-19 See dkt. 473. O obV jeE cR tiR onU ).L ED (D’s 14 Jiachun 40:17-20 See dkt. 473. OVERRULED (D’s Xue objection). 15 16 Jiachun 40:25-41:15 See dkt. 473. OVERRULED (D’s Xue objection). 17 Jiachun 50:13-51:15 See dkt. 473. To the extent OVERRULED (D’s Xue Defendants objection). 18 9:10-18; 11:14- 16; assert their 11:24-12:5 designations as OVERRULED (P’s 19 affirmative objection). See above, designations, the Court’s explanation 20 FRE 32(a)(4) on Rule 611. and FRE 106 21 because this witness is not 22 “unavailable.” 23 Jiachun 51:19-20 See dkt. 473. OVERRULED (D’s Xue objection). 24 25 Jiachun 51:24 See dkt. 473. OVERRULED (D’s Xue objection). 26 Jiachun 52:1-53:17 See dkt. 473. To the extent OVERRULED (D’s 27 Xue Defendants objection). 9:10-18; 11:14- 16; assert their affirmative OVERRULED (P’s 1 designations, objection). See above, FRE 32(a)(4) the Court’s explanation 2 and FRE 106 on Rule 611. because this 3 witness is not “unavailable.” 4 Jiachun 57:1-10 See dkt. 473. To the extent OVERRULED (D’s 5 Xue Defendants objection). 9:10-18; 11:14- 16; assert their 6 11:24-12:5 designations as OVERRULED (P’s affirmative objection). See above, 7 designations, the Court’s explanation FRE 32(a)(4) on Rule 611. 8 and FRE 106 because this 9 witness is not “unavailable.” 10 11 Lei Sun 8:11-17 See dkt. 473. OVERRULED (D’s objection). 12 Lei Sun 9:4-9 See dkt. 473. ALREADY 13 OVERRULED (D’s objection). See Docket 14 No. 473. 15 Lei Sun 9:13-14 See dkt. 473. OVERRULED (D’s objection). 16 17 Lei Sun 9:22-10:7 See dkt. 473. OVERRULED (D’s objection). 18 Lei Sun 10:13 See dkt. 473. OVERRULED (D’s objection). 19 20 Lei Sun 21:5-7 See dkt. 473. OVERRULED (D’s objection). 21 Lei Sun 21:17-22 See dkt. 473. ALREADY 22 OVERRULED (D’s objection). See Docket 23 No. 473. 24 Lei Sun 26:14-23 See dkt. 473. To the extent OVERRULED (D’s Defendants objection). 25 24:23-25:21 assert their designations as OVERRULED (P’s 26 affirmative objection). See above, designations, the Court’s explanation 27 FRE 32(a)(4) on Rule 611. and FRE 106 witness is not 1 “unavailable.” 2 Lei Sun 39:8-13 See dkt. 473. To the extent OVERRULED (D’s Defendants objection). 3 28:21-24; 29:10-15; assert their 29:21-30:12; 31:12- designations as OVERRULED (P’s 4 23; 34:22- 35:09; affirmative objection). See above, 36:2-6; 37:7-10; designations, the Court’s explanation 5 37:22- 38:10; FRE 32(a)(4) on Rule 611. 38:12-14 and FRE 106 6 because this witness is not 7 “unavailable.” 8 Lei Sun 43:17-21 See dkt. 473. OVERRULED (D’s objection). 9 Lei Sun 94:13-16 See dkt. 473. ALREADY 10 OVERRULED (D’s objection). See Docket 11 No. 473. 12 Lei Sun 95:20-23 See dkt. 473. ALREADY OVERRULED (D’s 13 objection). See Docket No. 473. 14 15 Lei Sun 97:10-15 See dkt. 473. ALREADY OVERRULED (D’s objection). See Docket 16 No. 473. 17 Lei Sun 97:21-99:10 See dkt. 473. ALREADY OVERRULED (D’s 18 objection). See Docket No. 473. 19 20 21 22 23 24 25 26 27