James J. Pisanelle
Nevada Bar No. 4027
Nicki L Wilmer
Nevada Bar No. 6562
SCHRECK BRIGNONE
[[ address ]]

Michael P Kenny, Esq.
James A Harvey, Esq.
David J Stewart, Esq.
Christopher A Riley, Esq.
Douglas L. Bridges, Esq/
ALSTON & BIRD LLP
[[ ADDRESS ]]

Attorneys for Defendant AutoZone, Inc.

United States District Court District of Nevada
The SCO Group, Inc.
a Delaware Corporation

  Plaintiff,
v.

AUTOZONE, INC.
A Nevada Corporation

  Defendant.

Civil Action File No.

CV-S-04-0237-RCG-LRL

DEFENDANT AUTOZONE, INC.'S FIRST INTERROGATORIES TO
PLAINTIFF THE SCO GROUP, INC.

_PAGE 1 _L24 Pursuant to Rule 33 of the Federal Rules of Civil Procedure (hereinafter _ "FRCP"), Defendant Autozone, Inc. ("Autozone" or "Defendant") requests that _ Plaintiff The SCO Group, Inc. ("SCO" or "Plaintiff") respond to the following _ Interrogatories, In accordance with FRCP 33, each interrogatory is to be answered _ fully and in writing under oath within thirty (30) days after service hereof. _PAGE _L1

Each interrogatory is addressed to the knowledge of SCO, as well as to _ knowledge, information or documents in the possession, custody or control of SCO _ and SCO's Attorneys, Accountants, Agents, employees or officers. _

_ AutoZone incorporates herein by reference each of the Instructions and _ Definitions contained in Defendant AutoZone, Inc's first Requests for Production _ of Documents and Things to Plaintiff The SCO Group, Inc., served concurrently _ Herewith. Each of the Definitions Apply with respect to each of the Following _ Interrogatories, and each of the terms defined therein, when used in any Interrogatory _ below, shall have the meaning given therein _ _L12
_L14 _P1

1. Identify with specificity each copyrighted work that you allege _ AutoZone has infringed, Including, but not limited to, each of the works identified in _ Paragraph 2 of SCO's Injunctive Relief Statement. For source code, identify the _ specific lines of code that you allege AutoZone has infringed. For non-source code, _ identify the specific lines or sections of materials that you allege AutoZone has _ infringed _L21! _P

2. For each line of code identified in response to Interrogatory No. 1, (a) _ identify all products in which, in whole or in part, the code is included or on which, _ in whole or in part, the code is based and (b) identify whether SCO has ever _ distributed the source code under the GPL, LGPL or any other open source license, _ and if so, the circumstances and license under which it was distributed or otherwise _ made available _PAGE 3 _L1 _P3

3. Identify the author(s) of each work identified in response to _ Interrogatory No. 1 above. _P _

4. Describe in detail when and how SCO obtained ownership of the _ Copyright of each work identified in response to Interrogatory No. 1 above. _P _

5. Identify by registration Number the United States copyright _ Registration for each copyrighted work identified in response to Interrogatory No. 1 _ above _P _L9

6. Describe with specificity how AutoZone has infringed the copyright _ in each work identified in response to Interrogatory No. 1 above. _P _

7. Identify the date when SCO first learned that AutoZone was _ migrating, or had migrated, from OpenServer to Linux. _P _L14

8. Identify the date when SCO first learned that Autozone had allegedly _ infringed each of the copyrighted works identified in response to Interrogatory No. 1 _ above. _P9 _L17

9. Describe in detail all harm that you are suffering as a result of each alleged act of infringement identified in response to Interrogatory No. 6 above. _P10 _l19

10. Identify all persons who have knowledge or information regarding the _ creation of the works identified in response to Request No. 1 above, and describe in _ detail the substance of each person's knowledge. _P11 _L23

11. Identify all persons who have knowledge or information regarding _ your ownership of the copyrights identified in response to Request No. 1 above, and _ describe in detail the substance of each person's knowledge. _P12 _l26

12. Identify all persons who have knowledge or information regarding your claims that AutoZone has infringed the copyright identified in response to _PAGE 4 _l1 interrogatory No. 1 above, including, without limitation, each of the SCO employees _ referenced in lines 7 & 8 of Paragraph 2 of SCO's Injunctive Relief Statement, and _ describe in detail the substance of each person's knowledge. _P13 _L4

13. Identify all facts documents and other information in your _ possession, custody or control that support your stated belief that "it is reasonably _ likely that AutoZone copied SCO's copyright materials during the migration process _ in violation of its contracts with SCO and in violation of Federal Copyright laws," as _ stated in Paragraph 2 of SCO's Injunctive Relief Statement, and identify all _ individuals with knowledge of the same. _ _P14 _L11

Identify each expert witness that you will call to provide testimony on _ your behalf in support of your anticipated motion for preliminary injunction, and, for _ each expert, state the subject matter and a summary of each such expert's _ testimony. _L16

This 1st day of September, 2004 _

_L18 [[ signature }}
James J. Pisanelli, Esq.
_ Nicki L. Wilmer, Esq. _ SCHRECK BRIGNONE _ [[ ADDRESS ]] _l23

Attorneys for defendant
AutoZone, Inc. _PAGE _L1

CERTIFICATE OF SERVICE
_ I hereby certify that I have this day served a copy of the within and foregoing _ DEFENDANT AUTOZONE, INC.'S FIRST INTERROGATORIES TO _ PLAINTIFF THE SCO GROUP, INC. upon all council of record addressed as _ follows:

_L20! This 1st day of September, 2004.

[[signature]]
An employee of Schreck Brignone

_L28! atl-1/1173000v: