Requests 2 and 32 show some chutzpah, to say the least. Rarely will you see a finer example of lawyer-ese than this:
"Apple's Request 2 is very narrow. It simply requests documents sufficient to show Valve's: (a) total yearly sales of apps and in-app products; (b) annual advertising revenues from Steam; (c) annual sales of external products attributable to Steam; (d) annual revenues from Steam; and (e) annual earnings (whether gross or net) from Steam. Apple has gone as far as requesting this information in any readily accessible format, but Valve refuses to produce it."
Now if you thought that demand from Apple was ballsy (and bear in mind Steam is a non-party to this main dispute) hold on to your hat, because Request 32 piles-on to demand documents showing:
"(a) the name of each App on Steam; (b) the date range when the App was available on Steam; and (c) the price of the App and any in-app product available on Steam."
That is, Apple wants Valve to provide the names, prices, configurations and dates of every product on Steam, as well as detailed accounts of exactly how much money Steam makes and how it is all divvied-up. Apple argues that this information is necessary for its case against Epic, is not available elsewhere, and "does not raise risk of any competitive harm."
