On 14 March 2014, the motions of plaintiff Palmchip Corporation (1) to compel responses to form interrogatories, (2) to compel responses to special interrogatories, (3) to have requests for admission deemed admitted, and (4) to compel responses and production in response to plaintiff’s request for production of documents (set one), and for monetary sanctions, were argued and submitted. Defendant Ralink Technology Corporation filed a formal opposition to these motions.

The motions of defendant Ralink Technology Corporation (1) to compel responsive documents and (2) to enforce the parties’ stipulation regarding production of source code and expert reports, and for monetary sanctions, were also argued and submitted. Plaintiff Palmchip Corporation filed formal oppositions to these motions in which it also requests monetary sanctions.

Statement of Facts

This action arises from a licensing relationship among the parties by which plaintiff Palmchip Corporation (“Palmchip”) licensed certain intellectual property to defendants Ralink Technology Corporation, a Taiwan corporation (“Ralink Taiwan”), Ralink Technology Corporation, a California corporation (“Ralink USA”), Mediatek, Inc. (“Mediatek Taiwan”), and Mediatek USA, Inc. (“Mediatek USA”) (collectively, “Defendants”) pursuant to a 2005 written agreement and a 2007 implied license. Palmchip alleges that Defendants used its technology in excess of and wholly outside of these licenses. Palmchip further alleges that Defendants fraudulently misrepresented material facts during the negotiation of the 2007 implied license and afterwards.

Palmchip first filed this action on October 19, 2012, and filed the operative first amended complaint on August 6, 2013. The first amended complaint includes causes of action for: (1) breach of contract, (2) fraud, (3) negligent misrepresentation, (4) accounting, (5) conversion, (6) unjust enrichment, and (7) unfair competition.

On March 5, the trial setting conference in this action was continued to May 6, 2014.

Discovery Disputes

Palmchip’s Motions:

At issue in Palmchip’s motions are requests for production of documents (“RPD”s), special interrogatories (“SI”s), requests for admissions (“RFA”s), and form interrogatories (“FI”s) served on each of Defendants on or around June 21, 2013 (“Palmchip’s Discovery Requests”). After agreed extensions, Defendants served responses to Palmchip’s Discovery Requests on or around August 29, 2013. Defendants both interposed objections and provided substantive answers in their responses. Palmchip’s counsel states that these responses all lacked verifications, but Palmchip did not notice this at the time. On or about November 20, 2013, after the parties met and conferred concerning Defendants’ responses, Ralink Taiwan served supplemental responses to the RPDs directed to it and each of Defendants served supplemental responses to FI 17.1. Palmchip’s counsel declares that Palmchip again did not notice that these supplemental responses all lacked verifications. On or about January 16, 2014, following additional meet and confer, Ralink Taiwan served additional supplemental responses to the RPDs and RFAs directed to it. Again, Palmchip did not notice that these supplemental responses were all unverified. Palmchip continued to meet and confer with Defendants concerning their responses, and during this period became aware that none of Defendants’ discovery responses had been verified.

On February 5, in his final, 23-page meet and confer letter to Defendants’ counsel, Palmchip’s counsel requested for the first time that Defendants provide verifications to their responses to Palmchip’s Discovery Requests. Counsel also requested that Defendants provide additional supplemental responses to Palmchip’s Discovery Requests and supplement their document production. Although Palmchip’s counsel requested that verifications be provided by February 11, it does not appear that any verifications have yet been supplied.

On February 20, Palmchip filed the instant motions (1) to compel responses to the FIs, (2) to compel responses to the SIs, (3) to have the RFAs deemed admitted, and (4) to compel responses and production in response to the RPDs, and for monetary sanctions (collectively, “Palmchip’s Motions”). On March 3, Defendants filed a single opposition to Palmchip’s Motions. On March 7, Palmchip filed a single reply in support of its motions, along with evidentiary objections.

Ralink’s Motions:

On December 2, 2012, the parties stipulated to stay this action in order to engage in settlement discussions directly or through mediation. (Ex. A to Liang Decl. ISO Mtn. to Enforce Parties’ Stipulation, Joint Stipulated Request to Stay Action, ¶ 2.) Defendants agreed to provide Palmchip with sufficient documents and information to facilitate meaningful settlement discussions. (Id., ¶ 3.)

Ralink Taiwan’s counsel declares that, pursuant to the stipulation, Ralink Taiwan agreed to produce source code subject to a protective order permitting Palmchip’s expert to review the code. Counsel declares that Ralink Taiwan made this agreement in exchange for Palmchip’s “repeated assurances that once the source code was produced, … [Palmchip] would produce to [Ralink Taiwan] its expert report detailing Ralink’s alleged misuse of licensed technology and alleged damages owed to Palmchip.” (Liang Decl., ¶ 7.) Palmchip’s expert reviewed the source code during or around the week of August 13, 2013, and Palmchip’s counsel sent Ralink Taiwan’s counsel an email stating that he expected to have an expert report to share before the end of the month. However, Ralink Taiwan never received the expert report.

On October 2, 2013, the parties executed another stipulation concerning settlement discussions. The stipulation provided that the parties had been engaged in settlement discussions and had retained a mediator, and indicated that Palmchip had agreed to share, “as part of the settlement discussions and the mediation,” its “preliminary expert report on liability and/or claim chart” and its “preliminary expert report on damages.” (Ex. C to Liang Decl., Stipulation Relating to Settlement Discussions, p. 1.) The parties agreed that these documents could not be used in any of the proceedings in this action or a related federal action between the parties. (Id.) Palmchip agreed to deliver the reports once it had received executed copies of the confidentiality agreement that would govern access to the documents. (Id. at p. 2.)

Ralink Taiwan’s counsel declares that on October 3, Palmchip responded to Ralink Taiwan’s service of certain third-party subpoenas by indicating that it no longer agreed to produce its expert’s reports. Palmchip’s counsel states that the mediation contemplated by the October 2nd stipulation never took place, and the parties consequently entered into negotiations for another stipulation. The terms under discussion as reflected in an October 2013 email chain among counsel included: (1) that the parties would agree to a mid-December mediation; (2) that the parties’ experts and/or their counsel would participate in three telephonic settlement conferences; (3) that Palmchip would provide Defendants with its expert analysis by the close of business on October 16, while Defendants would provide their rebuttal by November 17; and (4) that Ralink Taiwan would withdraw its third-party subpoenas without prejudice until after the mediation. A draft of the proposed stipulation was circulated in November, but was never executed by the parties.

Meanwhile, on September 6, 2013, Ralink Taiwan served discovery requests upon Palmchip, including its first set of requests for production (the “Requests”). Palmchip served responses to the Requests on or about November 6, following extensions of its time to respond. On or about November 21, Palmchip made an initial production of documents responsive to the Requests.

On December 17, Ralink Taiwan’s counsel sent Palmchip’s counsel a meet and confer letter in which he outlined asserted deficiencies in Palmchip’s responses to the Requests, including its responses to Request Nos. 27, 41, 45, and 47-52. Counsel met and conferred on these issues on January 6, 2014, and also discussed the scope of Palmchip’s search for and production of Maha Zaidi’s communications in response to other document requests. Ralink Taiwan’s counsel memorialized this conversation in a January 6th email, in which he stated that Palmchip had agreed to provide further information or responses as to certain issues, while the parties were at an impasse as to other issues.

The parties agreed to extend Ralink Taiwan’s deadline to move to compel further responses to the Requests until March 6. Ralink Taiwan’s counsel declares that the parties had also agreed to have their respective motions to compel heard on March 14, but that Palmchip approached Ralink Taiwan on February 14 about moving the hearing date to March 21 or 28. Ralink Taiwan agreed, but Palmchip then filed and served its own motions to be heard on March 14.

On February 21, Ralink Taiwan filed the present motions to compel further responses to the Requests (“Ralink’s Motion to Compel”) and to enforce the parties’ stipulation regarding production of source code and expert reports (“Ralink’s Motion to Enforce”) (collectively, “Ralink’s Motions”). Ralink’s Motion to Compel was noticed to be heard on March 14, and Ralink’s Motion to Enforce was noticed to be heard on April 4. On February 26, the Court granted Ralink Taiwan’s ex parte application to advance the hearing on Ralink’s Motion to Enforce to March 14. The Court ordered that opposition papers must be filed and served by March 7 and reply papers must be filed and served by March 12.

On March 7, Palmchip filed separate sets of papers in opposition to each of Ralink’s Motions.

Discussion

I. Palmchip’s Motions
II.
Palmchip seeks an order compelling Defendants to provide verified responses to the FIs, SIs, and RPDs that do not contain objections; deeming the RFAs admitted; and awarding monetary sanctions against Defendants and their counsel. Defendants oppose Palmchip’s Motions, defending their objections and the status of their document production and asking the Court to enter a protective order enabling them to make a further production. Defendants do not address their failure to provide verifications to their responses to Palmchip’s Discovery Requests in their opposition papers.

A. Legal Standards
B.
The party to whom written discovery has been propounded is required to serve a response within 30 days, or on any later date to which the parties have agreed. (See Code Civ. Proc. (“CCP”), §§ 2030.260, 2030.270 [interrogatories]; 2031.260, 2031.270 [requests for production]; 2033.250, 2033.260 [requests for admission].) Where a verification to a response is required, service of an unverified response is tantamount to no response at all. (See Appleton v. Super. Ct. (1988) 206 Cal.App.3d 632, 635 -636 [unsworn responses are tantamount to no responses at all].) Substantive responses to interrogatories (CCP, § 2030.250, subd. (a)), requests for production (CCP, § 2031.250, subd. (a)), and requests for admission (CCP, § 2033.240, subd. (a)) must be verified. Objections need not be verified. (Food 4 Less Supermarkets, Inc. v. Super. Ct. (1995) 40 Cal.App.4th 651, 657-658 [there is no need to verify the portion of a discovery response containing objections].)

If the party to whom interrogatories or requests for production are directed fails to serve a timely response, that party waives any objections to the discovery. (CCP, §§ 2030.290, subd. (a) [interrogatories]; 2031.300, subd. (a) [requests for production].) Additionally, the propounding party may move for an order compelling a response. (CCP, §§ 2030.290, subd. (b) [interrogatories]; 2031.300, subd. (b) [requests for production].) There is no limitation period (see CCP, §§ 2030.290, 2031.300) or meet and confer requirement (see Sinaiko Healthcare Consulting, Inc. v. Pacific Healthcare Consultants (2007) 148 Cal.App.4th 390, 411-412; Leach v. Super. Ct. (1980) 111 Cal.App.3d 902, 905-906) for bringing a motion to compel an initial response. The moving party need only show that the discovery was properly propounded and a timely response was not served. (See id.)

If the party to whom requests for admissions are directed fails to serve a timely response, that party waives any objection to the requests. (CCP, § 2033.280, subd. (a).) Additionally, the propounding party may move for an order that the truth of any matters specified in those requests be deemed admitted. (CCP, § 2033.280, subd. (b).) The court shall make this order unless it finds that, prior to the hearing on the motion, the responding party served a proposed response that is substantially code-compliant. (CCP, § 2033.280, subd. (c); see also Tobin v. Oris (1992) 3 Cal.App.4th 814, 828, disapproved of on another point by Wilcox v. Birtwhistle (1999) 21 Cal.4th 973.) There is no limitation period (see Demyer v. Costa Mesa Mobile Home Estates (1995) 36 Cal.App.4th 393, 395, fn. 4, disapproved of on another point by Wilcox v. Birtwhistle, supra, 21 Cal.4th 973) or meet and confer requirement (see Brigante v. Huang (1993) 20 Cal.App.4th 1569, 1584, disapproved of on another point by Wilcox v. Birtwhistle, supra, 21 Cal.4th 973) for bringing a motion for deemed admissions. The moving party need only show that the discovery was properly propounded and a timely response was not served. (See id.)

C. The FIs, SIs, and RPDs
D.
Palmchip seeks to compel verified responses to the FIs, SIs, and RPDs that do not contain objections. While Palmchip is entitled to verifications given that Defendants do not rest upon objections only in any of their responses (see CCP, §§ 2030.250, subd. (a), 2031.250, subd. (a)), Palmchip does not contend that Defendants failed to serve their objections in a timely fashion. Consequently, Defendants’ objections are not waived, and it would be improper for the Court to order Defendants to provide responses to the FIs, SIs, and RPDs that do not contain objections on this basis. (See Food 4 Less Supermarkets, Inc. v. Super. Ct., supra, 40 Cal.App.4th at pp. 657-658 [“The omission of the verification in the portion of the response containing fact-specific responses merely renders that portion of the response untimely and therefore only creates a right to move for [an order compelling initial responses] and sanctions … as to those responses but does not result in a waiver of the objections made.”]; Korea Data Systems Co. v. Super. Ct. (1997) 51 Cal.App.4th 1513, 1516 [failure to timely serve a privilege log does not lead to waiver where objections were timely served, albeit in “boiler plate” form].)

Palmchip argues that, notwithstanding that its motions are to compel initial responses and Defendants’ objections have admittedly been preserved, the Court should address the merits of Defendants’ objections now. However, this issue is not properly before the Court at the present time given that Defendants’ responses are not yet complete. As noted by Palmchip, its deadline to move to compel further responses has not yet been triggered, and it would be more efficient for the Court to address the merits of Defendants’ objections in the context of motions to compel further responses supported by the required separate statements. (See Cal. Rules of Court, rule 3.1345(a) [“Any motion involving the content of a discovery request or the response to such a request must be accompanied by a separate statement.”]; Mills v. U.S. Bank (2008) 166 Cal.App.4th 871, 893 [failure to include separate statement required by Rules of Court provided justification of court’s denial of discovery motion].) Any such motions to compel further responses can be appropriately focused on the specific requests concerning which the parties continue to disagree following Defendants’ service of complete responses and the parties’ continued efforts to meet and confer. (See CCP, §§ 2016.040, 2030.300, subd. (b); 2031.310, subd. (b)(2) [a motion to compel further responses shall be accompanied by a meet and confer declaration “showing a reasonable and good faith attempt at an informal resolution of each issue presented by the motion”].)

Accordingly, Palmchip’s motions to compel responses to the FIs, SIs, and RPDs are GRANTED to the extent that Palmchip requests an order compelling Defendants to provide verified responses to these discovery requests, but the motions are DENIED to the extent that Palmchip seeks an order compelling Defendants to respond to these requests without objection.

E. The RFAs
F.
Defendants do not specifically address their responses to the RFAs or Palmchip’s request for deemed admissions in their opposition. Given that there is no indication that Defendants have served a proposed response that is in substantial compliance with the CCP, the Court must grant Palmchip’s motion to deem the RFAs admitted. (See CCP, § 2033.280, subd. (c) [court “shall” enter an order deeming requests for admission admitted if the party to whom the requests are directed fails to serve a timely response unless it finds substantially compliant proposed responses have been served]; St. Mary v. Super. Ct. (2014) 167 Cal.Rptr.3d 517, 531-532 [an unverified response to RFAs is not substantially code-compliant].)

Accordingly, Palmchip’s request for an order deeming the RFAs admitted is GRANTED.

G. Defendants’ Request for a Protective Order
H.
A party may move the court for a protective order pursuant to various statutory authorities. (See, e.g., CCP, §§ 2017.020 2019.030, 2031.060.) Here, however, Defendants’ request for a protective order is not properly before the Court because it was made in their opposition rather than in the form of a noticed motion.

Accordingly, Defendants’ request for a protective order is DENIED without prejudice.

I. Objections to Evidence
J.
Palmchip objects to Defendants’ introduction of a statement in their counsel’s declaration concerning which of their products are at issue in this litigation. There is no authority, however, for the proposition that the Court must rule on an evidentiary objection made in connection with a motion other than a motion for summary judgment or an anti-SLAPP motion. Furthermore, this statement is not necessary to the Court’s resolution of Palmchip’s Motions. The Court, therefore, declines to rule on Palmchip’s evidentiary objections.

K. Requests for Monetary Sanctions
L.
Palmchip makes a code-compliant request for monetary sanctions against Defendants and their counsel in connection with each of Palmchip’s Motions.

With respect to Palmchip’s motions to compel responses to the FIs, SIs, and RPDs, the court shall impose a monetary sanction against a party who unsuccessfully opposes such a motion unless it finds the party “acted with substantial justification” or “other circumstances make the imposition of the sanction unjust.” (CCP, §§ 2030.290, subd. (c), 2031.300, subd. (c).) Defendants’ oppositions to these motions were largely unsuccessful and no other circumstances make the imposition of sanctions unjust. Thus, the Court will award monetary sanctions against Defendants and their counsel in connection with these motions.

Palmchip requests a total of $15,000 in monetary sanctions in connection with these motions: $4,470 in connection with the motion to compel responses to the FIs, $5,490 with regards to the motion to compel responses to the SIs, and $5,040 associated with the motion to compel responses to the RPDs. Palmchip’s counsel Ms. Brosas declares that she spent 2.8 hours per motion on tasks attributable to all of Palmchip’s Motions, along with 1.5 additional hours on the motion to compel responses to the FIs, 2.6 additional hours on the motion to compel responses to the SIs, and 3.1 additional hours on the motion to compel responses to the RPDs. Palmchip’s counsel Mr. Hodas declares that he spent 8.6 hours per motion on tasks attributable to all of Palmchip’s Motions, along with 2 additional hours on the motion to compel responses to the FIs, 4.3 additional hours on the motion to compel responses to the SIs, and 2.3 additional hours on the motion to compel responses to the RPDs. Both Ms. Brosas and Mr. Hodas bill at an hourly rate of $300 per hour.

A court may only award sanctions for attorney’s fees that were reasonably incurred. (CCP, § 2023.030, subd. (a).) While counsel’s hourly rates are reasonable, the 50 combined hours they spent on motions to compel responses to these discovery requests are not. The Court finds that 9 hours (or 3 hours per motion) would have been a more reasonable amount of time to spend on these motions. Accordingly, the Court will award $2,700 (9 hours x $300/hour = $2,700) in monetary sanctions against Defendants and their counsel in connection with these motions.

With respect to Palmchip’s motion to deem the RFAs admitted, “[i]t is mandatory that the court impose a monetary sanction” given that Palmchip’s motion was granted. (CCP, § 2033.280, subd. (c).) Palmchip requests $4,410 in monetary sanctions in connection with this motion. Ms. Brosas declares that she spent 4.5 hours on this motion, while Mr. Hodas states that he spent 10.2 hours on the motion. The Court finds that 3 hours would have been a more reasonable amount of time to have spent on this motion, and will consequently award $900 in sanctions (3 hours x $300/hour = $900) in connection with this motion.

Accordingly, the Court will award a total of $3,600 in monetary sanctions against Defendants and their counsel in connection with Palmchip’s Motions.

III. Ralink’s Motion to Compel
IV.
Ralink Taiwan moves to compel the production of additional documents responsive to Request Nos. 2, 3, 7, 10, and 45 and the provision of further responses to Request Nos. 27, 41, and 47-52. A number of these Requests mirror document demands propounded by Ralink Taiwan in certain third-party subpoenas, which are the subject of Palmchip’s motion for a protective order currently under submission with the Court. In light of these circumstances, Ralink’s Motion to Compel is CONTINUED pending resolution of Palmchip’s motion for a protective order.

V. Ralink’s Motion to Enforce
VI.
Ralink Taiwan moves for an order compelling Palmchip to produce its expert reports on liability and damages. Palmchip opposes Ralink’s Motion to Enforce, arguing that Ralink Taiwan failed to meet and confer prior to filing it; the parties’ stipulation did not provide for the discovery of preliminary expert reports, only for their limited use during settlement efforts; the parties’ duties under the stipulation were never triggered because the mediation contemplated by the stipulation never took place; the preliminary reports are protected work product; and expert reports are not yet due to be exchanged in this action.

A. Legal Standard
B.
“A stipulation is an agreement between counsel respecting business before the court” (Palmer v. City of Long Beach (1948) 33 Cal.2d 134, 142), and, in proper form, “is binding upon the parties if it is within the authority of the attorneys” (Mileikowsky v. Tenet Healthsystem (2005) 128 Cal.App.4th 262, 279). A stipulation may, but need not, constitute a contract, and a stipulation accepted by the parties is binding upon the court so long as it is not illegal or contrary to public policy. (Leonard v. City of Los Angeles (1973) 31 Cal.App.3d 473, 477.) Unless the court orders otherwise, the parties may stipulate in writing to modify the procedures provided by the Discovery Act for any permitted method of discovery. (CCP, § 2016.030.)

Stipulations must be given a reasonable construction with a view to giving effect to the intent of the parties, and the language used will not be construed as an admission of a fact obviously intended to be controverted, or the waiver of a right not plainly intended to be relinquished. (Palmer v. City of Long Beach, supra, 33 Cal.2d at p. 142.)

C. Analysis
D.
Ralink Taiwan moves the Court to enforce the parties’ October 2nd stipulation by compelling Palmchip to produce the expert reports discussed in that stipulation. As an initial matter, Ralink Taiwan’s motion is one to enforce a stipulation and not to compel the production of the reports at issue in response to any discovery requests. Palmchip cites no authority for the proposition that there is a meet and confer requirement associated with such a motion, and its argument on this point consequently fails.

Ralink Taiwan argues that the October 2nd stipulation requires Palmchip to produce its preliminary expert reports. However, as urged by Palmchip, Ralink Taiwan ignores the context in which the parties’ stipulation was executed. The stipulation expressly provides that Palmchip agreed to share these reports “as part of the [parties’] settlement discussions and the mediation” only, and the documents would not be used in any of the proceedings in this action or the related federal action between the parties. The parties further agreed that these documents would “be treated as confidential and subject to all state and federal settlement and mediation privileges.” Consequently, it is clear that the parties intended for these documents to be used in settlement discussions and during mediation only, and that Palmchip did not intend to relinquish any of its rights in discovery. This conclusion is reinforced by the parties’ omission of a specific deadline for the production of the reports from the October 2nd stipulation and their failure to execute a later draft stipulation that did provide for such a deadline.

While Ralink Taiwan bases its motion on the October 2nd stipulation, it also argues that it produced source code based on Palmchip’s “repeated assurances” that Palmchip would then produce the expert reports. However, there is no indication that any such agreement was reduced to writing as required. (See CCP, § 2016.030.) Consequently, the fact that Ralink Taiwan allowed Palmchip to review its source code does not compel the conclusion that Palmchip must now produce its preliminary expert reports.

Accordingly, the Court will not interpret the October 2nd stipulation to provide for the production of these documents outside of the settlement context contemplated by that stipulation. (See Palmer v. City of Long Beach, supra, 33 Cal.2d at p. 142.) Given that the parties are apparently no longer engaging in settlement discussions or planning to participate in mediation, the Court will not order Palmchip to produce these documents at this time.

Ralink’s Motion to Enforce is thus DENIED.

E. Requests for Monetary Sanctions
F.
Both Ralink Taiwan and and Palmchip request monetary sanctions in connection with Ralink’s Motion to Enforce.

Ralink Taiwan seeks $5,000 in monetary sanctions against Palmchip and/or its counsel pursuant to CCP section 128.5 for Palmchip’s asserted refusal to honor the parties’ stipulation. CCP section 128.5 only authorizes an award of sanctions in actions initiated on or before December 31, 1994 (CCP, § 128.5, subds. (a) and (b)(1); see also Olmstead v. Arthur J. Gallagher & Co. (2004) 32 Cal.4th 804, 809), and Palmchip acted reasonably in declining to turn over documents intended for use in settlement efforts once those efforts were discontinued. For these reasons, Ralink Taiwan’s request for sanctions is DENIED.

Palmchip requests monetary sanctions pursuant to CCP sections 128.5, 2023.010, 2023.030, and 2031.300. As discussed above, CCP section 128.5 does not apply to this action given that it was initiated after December 31, 1994. Further, section 2023.010 merely defines actions that constitute “misuses of the discovery process,” and section 2023.030 provides that sanctions may be imposed for misuses of the discovery process “[t]o the extent authorized by the chapter governing any particular discovery method or any other provision of this title.” Section 2031.300 provides for the award of sanctions on a motion to compel initial responses to requests for production, but, as discussed, Ralink’s Motion to Enforce is not this type of motion. Thus, sections 2023.010 and 2023.030 do not provide an independent basis for the award of sanctions, and Defendants fail to identify a complimentary provision of the Discovery Act that provides for sanctions under the circumstances. Accordingly, Palmchip’s request for sanctions is DENIED.

Conclusion and Order

Palmchip’s motions to compel responses to the FIs, SIs, and RPDs are GRANTED IN PART and DENIED IN PART. The motions are GRANTED to the extent that Palmchip requests an order compelling Defendants to provide verified responses to these discovery requests, but the motions are DENIED to the extent that Palmchip seeks an order compelling Defendants to respond to the requests without objection. Any objections to these requests that were timely made by Defendants are preserved. Accordingly, Defendants shall serve verified, code-compliant responses to the FIs, SIs, and RPDs within 20 calendar days of the filing of this Order.

Palmchip’s motion to deem the RFAs admitted is GRANTED.

Defendants’ request for a protective order is DENIED without prejudice.

Palmchip’s requests for monetary sanctions against Defendants and their counsel in connection with Palmchip’s Motions are GRANTED in the total amount of $3,600. Accordingly, Defendants and their counsel shall pay $3,600 to counsel for Palmchip within 20 calendar days of the filing of this Order.

Ralink’s Motion to Compel is CONTINUED to April 25, 2014 pending resolution of Palmchip’s motion for a protective order.

Ralink’s Motion to Enforce is DENIED. The parties’ requests for sanctions in connection with that motion are both DENIED.