Specifically, Samsung’s fundamental objection to PDS’s

requests, which it has clearly and repeatedly asserted, is the following: PDS’s definition of

“Accused Products” is overbroad and unduly burdensome because it purports to sweep in nearly

800 Samsung products for which PDS failed to provide infringement contentions in compliance

with Patent Local Rule 3-1.1

Overbroad? Overbroad? They used it in every device! How nis that overbroad??? Grewal will see right through this eventually! Basic questions still remains, why did they use it if it didn't work?