To establish contributory infringement under the statute, plaintiff needs to establish a likelihood of specific future infringement; specific allegations of the theory of infringement are necessary. While the software removes the metadata that aids in the detection of infringement, plaintiffs do not demonstrate how removal of this information alone will prompt a future infringement.
Discovery denials appropriate, as there was no specific statement of how the additional time and productions would show such future specific infringement.
Costs for testimony of employees of deft corporation can be taxed to opposing party.
http://cdn.ca9.uscourts.gov/datastore/opinions/2018/06/20/16-56089.pdf