Free Objections - District Court of Delaware - Delaware

. » Case 1:04-cv-01488-JJF Document 89-11 Filed 08/20/2007 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
STEVEN G. MILLETT, MELODY J. MILLETT, )
On Behalf Of Themselves and All Others )
Similarly Situated, )
)
Plaintiifs, )
) Case No. 05-599-SLR
v. )
)
TRUELINK, INC., )
A Trans Union Company, )
)
Defendant. )
RESPONSE TO PLAIN'I`IFFS’ FIRST INTERROGATORIES
TO DEFENDANT TRUELINIQ, INC.
Defendant 'I`meLink, Inc., now known as Trans Union Interactive, Inc.
("TrueI..ink"), by its attorneys, hereby responds to Plaintiffs’ First interrogatories to
Defendant Truelsink, Inc.
GENERAL OBJECTIONS
1. 'I`rueLink objects to the definition of "Customers," as overly broad, unduly
burdensome, and seeks information that is neither relevant to the claims or defenses of
any party in this litigation, nor reasonably calculated to lead to the discovery of
admissible evidence insofar as the definition includes persons who purchased Credit
Monitoring from Trans Union, LLC.
2. 'I`rueLink objects to the definition of "identify" and "identification" as
overly broad and unduly burdensome.
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A . Case 1 :04-cv-01488-JJF Document 89-1 1 Filed 08/20/2007 Page 2 of 2
RESPONSES TO INTERROGATORIES
I. Please identify the divisicn(s) or group(s) responsible for marketing Credit
Monitoring and the person(s) who are in charge of those division(s) or grcup(s),
RESPONSE: Subject to and without waiving the foregoing General Objections,
TrueLink identities the following division and individuals: TrueLink’s Marketing
Group, including Lucy Duni, Director of Marketing (San Luis Obispo, CA).
2. Please identify the division(s) or group(s) that are responsible for the
design and/or development of Credit Monitoring and the person(s) who are in charge of
those division(s) or group(s).
RESPONSE: Subject to and without waiving the foregoing General Objections,
TrueLink identines the following division and individuals: 'I`rueLink’s Product
Management Group, including Lucy Duni and Justin DePow (San Luis Obispo,
CA).
3. Please identify, by date and method of distribution, all advertising or
Marketing Materials that have been used at any time to market or advertise Credit
Monitoring by any media including print, broadcast and internet/email.
RESPONSE: TrueLink objects to lnterrogatory No. 3 to the extent that it is
overly broad and unduly burdensome. Subject to and without waiving the
foregoing General Objections and specific objections, and pursuant to Federal
Rule of Civil Procedure 33(cl), 'I`rueLink will produce documents containing
responsive information. TrueLink further directs Plaintit`fs’ counsel to documents
previously produced by TrueLink in this action and numbered TLOOOOOI through
'l`L000l3l.
4. When was Credit Monitoring first offered for sale?
RESPONSE: Subject to and without waiving the foregoing General Objections,
T rueLink first offered Credit Monitoring for sale on or about July 29, 2001.
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