A company uses proprietary software in conducting this screening.

Plaintiff recently attended one of these mixers and signed up for the service, which ultimately led to his marriage after a brief courtship. Six months into the marriage, plaintiff discovered that spouse was using an assumed name and had never gone to law school, let alone worked as an attorney. The doomed marriage ended when Plaintiff followed spouse and learned she was bartending every day in the next town over.

Plaintiff is suing said company for false advertising, breach of contract, and misrepresentation of its screening services.

Plaintiff has requested any and all information regarding said company screening protocols from the inception of the company to the present. Plaintiff also seeks data associated with spouse's application and any and all applicants who have filed any type of claim against the company. Said Company is demanding any and all information regarding Plaintiff's business records, personal social media usage, financial records, and medical history, including any psychological treatment.

1. Said Company counsel is arguing that it should not have to produce any data related to its proprietary software program. Identify the procedural rule that supports this argument and explain your rationale
2. Analyze and explain the relevancy of Plaintiff's request for other claims filed against Said company.