![]() ![]() § 1030), and California Penal Code § 502 et seq. § 1201), the Computer Fraud and Abuse Act (18 U.S.C. ¶¶ 72-114.) RMG also uses, or makes available for use, automated devices to circumvent Ticketmaster's "access control" and "copy protection" systems in violation of the Digital Millennium Copyright Act (17 U.S.C. ¶ 4.) These activities constitute a civil RICO violation, intentional interference with contractual relations, and (Complaint ¶ 3.) In its complaint, Ticketmaster has alleged that RMG marketed and sold an applications that enable RMG's customers to use automated devices to enter and navigate Ticketmaster's website and unfairly procure large quantities of tickets in violation of Ticketmaster's terms of use, and to conceal from Ticketmaster their use of such automated devices on Ticketmaster's website. Ticketmaster distributes tickets for live entertainment events to the public through its "website. Specifically, Ticketmaster seeks an order requiring RMG to: (a) produce allegedly "confidential" materials pursuant to a reasonable protective order (b) provide amended responses to the requests and (c) produce additional unprivileged, non-confidential documents and electronically stored information covered by the requests set forth herein. TICKETMASTER'S INTRODUCTORY STATEMENT Ticketmaster seeks an order requiring RMG to provide amended responses to Ticketmaster's requests for production and to permit immediate inspection by Ticketmaster of unprivileged documents, including electronically stored information, reasonably calculated to lead to the discovery of admissible evidence and necessary for the prosecution of Ticketmaster's claims. ![]() In accordance with Local Rule 37-1, the parties have met and conferred in good faith to resolve this dispute but were unable to do so. ("Defendant" or "RMG") to permit inspection by Ticketmaster of documents and electronically stored information. This Joint Stipulation is submitted by the undersigned parties pursuant to Local Rule 37-2 in connection with Plaintiff Ticketmaster L.L.C.'s ("Plaintiff" or "Ticketmaster") motion to compel Defendant RMG Technologies, Inc. JOINT STIPULATION RE TICKETMASTER'S MOTION TO COMPEL Pre-Trial Conf.: SeptemTrial Date: OctoDiscovery Cut-Off: May 23, 2008 Location: Courtroom C, 8th Fl, Spring St. Johnson DISCOVERY MOTION JOINT STIPULATION REGARDING PLAINTIFF'S MOTION TO COMPEL PRODUCTION OF DOCUMENTS DECLARATIONS OF ADAM LIEB, RAAQIM KNIGHT, CIPRIANO GARIBAY, AND DAVID TARLOW Hearing Date: ApHearing Time: 2:00 p.m. RMG TECHNOLOGIES, INC., a Delaware corporation, and DOES 1 through 10, inclusive, Defendants. UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA TICKETMASTER L.L.C., a Virginia limited liability company, Plaintiff, vs. ![]()
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