ORDER RE: JOINT DISCOVERY LETTER [DOCKET NO. 226]

DONNA M. RYU, Magistrate Judge.

Before the court is a discovery letter submitted by Plaintiff Synopsys Inc. and Defendant Mentor Graphics Corp, in which Mentor seeks to compel miscellaneous discovery responses from Synopsys.1 [Docket No. 226.] The court held a hearing on August 28, 2014, and made rulings from the bench. This order summarizes those rulings. For the reasons stated at the hearing, the court ordered the following:

Mentor's motion to compel Synopsys to produce Deirdre Hanford and Russell Segal for further deposition is granted. Synopsys shall produce (1) Hanford for a deposition of no longer than two hours, and (2) Segal for a deposition of no longer than one hour. Both depositions shall be limited to questions regarding documents produced after each deponent's previous deposition, including the relevant Swap Space newsletters. Mentor's motion to compel Synopsys to produce an "accounting" of Synopsys's production of the Swap Space newsletters is denied.

With respect to Mentor's motion to compel Synopsys to "give a complete answer" to Interrogatory No. 30, the parties did not provide the court with Synopsys's response. For this reason, the court was not able to assess its sufficiency. To the extent Synopsys responded to the interrogatory by referring to a declaration, Mentor's motion is granted. Synopsys must produce a complete written response to the interrogatory; incorporation by reference to declarations in lieu of a written interrogatory response is insufficient. See Fed. R. Civ. P. 33(b)(3) ("Each interrogatory must, to the extent it is not objected to, be answered separately and fully in writing under oath."); Scaife v. Boenne, 191 F.R.D. 590, 594 (N.D. Ind. 2000) (answer to interrogatory should be complete in itself and should not refer to the pleadings or other documents) (quotations omitted).

Mentor's motion to compel Synopsys to produce Kevin Kranen for a deposition is granted. The deposition is limited to two hours. Mentor's motion to compel the production of the remainder of Kranen's notebooks is denied.

Mentor's motion to compel Synopsys to produce an explanation for the production date of the Beta Test Agreement is denied. However, by September 2, 2014, Synopsys shall provide written confirmation that it has made best efforts to review its documents, including documents relating to prior relevant litigation, and that to the best of its knowledge, it has now produced all non-privileged responsive documents. The written confirmation shall be signed by lead counsel for Synopsys, whose signature shall have the effect set forth in Federal Rule of Civil Procedure 26(g).

Mentor's motion to compel Synopsys to produce metadata for approximately 4200 pages of documents produced by Synopsys between May and July 2014 is denied.

Mentor's motion to compel Synopsys to produce a Rule 30(b)(6) witness on Topics 44, 45, and 49 is denied. Mentor's motion to compel Synopsys to produce a Rule 30(b)(6) witness on Topic 51 is granted. Synopsys shall produce an adequately prepared witness on Topic 51.

IT IS SO ORDERED.