You want discovery of your opponent's entire source code? You’re probably not getting that.

Sometimes you want discovery of another company's source code. Maybe you think it infringes your patent. Maybe you think it misappropriates your trade secrets. 

Whatever.

But beware. You'll need to be specific on what you need and why you need it.

Uniloc USA v. Apple underscores this.

In that suit, Uniloc claims that Apple infringed a patent for a step counter. And Uniloc sought discovery of the source code for iOS and watchOS.

All of it.

Even the stuff unrelated to counting steps.

And that’s a hard no. Getting that would require Uniloc showing how the entire iOS and watchOS source code is relevant to the narrow dispute of counting steps.

Which it couldn't do.

The court also made a broader point. You can’t make all-encompasing discovery requests, with the aim of looking at everything to then determine what's relevant. You can’t force a party to “produce every email it has ever sent or received, on whatever topic, no matter how unrelated to the case” on the theory that’s it too difficult to craft "relevant and proportional” requests.