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sheets, roadmap presentations, compliance and certification documents, developer manuals etc., for products provided by the Respondent to Shenzhen. The Letter of Request seeks to cast a wide net for production of a vast, all-encompassing range of documents with no explanation for their relevance or necessity.

21. The Petitioner is seeking to obtain information from a non-party to the proceedings as a pre-trail discovery. Indian Law does not provide for such pre-trial discovery from a non- party to the proceedings, and hence, under Article 9 of the Hague Convention, a Letter of Request cannot be executed. The Letter of Request also covers confidential and sensitive documents such as the Chip Schematics, Printed Circuit Board Layouts, VHSIC Hardware Description Language descriptions and source codes for software and hardware in the products supplied by the Respondent and it includes the Respondent's proprietary intellectual property, which is a product of several years of dedicated research and development. Respondent would be severely prejudiced if the Petitioner is permitted to access such documents, as the Petitioner is in a competing supply chain of the Respondent. This intellectual property does