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LPR 1-9. DOCUMENT PRODUCTION ACCOMPANYING INVALIDITY CONTENTIONS With the "Disclosure of Non-Infringement, Invalidity, and Unenforceability Contentions," the party opposing a claim of patent infringement must produce to each opposing party or make available for inspection and copying:

(a) Source code, specifications, schematics, flow charts, artwork, formulas, or other documentation sufficient to show the operation of any aspects or elements of an Accused Instrumentality identified by the party opposing infringement in its disclosure;

(b) A copy of each item of prior art identified under LPR 1-8(b)(2) which does not appear in the file history of the patent(s) at issue. To the extent any such item is not in English, an English translation of the portion(s) relied upon must also be produced;

(c) All documents evidencing the prior art described in LPR 1-8(b)(2) that are reasonably available to the party opposing infringement; and

(d) All documents relating to the conception, development, or commercialization of any product that the party opposing infringement contends is prior art.