Netflix, Inc. v. Blockbuster, Inc.

Filing 129

Attachment 1
Declaration of Eugene Paige in Support of 128 Reply Memorandum Netflix's Claim-Construction Reply Brief filed byNetflix, Inc.. (Attachments: # 1 Exhibit Exhibit A)(Related document(s)128) (Chanin, Jeffrey) (Filed on 1/10/2007)

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Netflix, Inc. v. Blockbuster, Inc. Doc. 129 Att. 1 Case 3:06-cv-02361-WHA Document 129-2 Filed 01/10/2007 Page 1 of 6 . EXHIBIT A Dockets.Justia.com Case 3:06-cv-02361-WHA Document 129-2 Filed 01/10/2007 Page 2 of 6 1 ~".r UNITED STATES DISTRICT COURT 2 NORTHERN DISTRICT OF CALIFORNIA 3 4 ------------------------------5 6 7 8 NETFLIX, INC. , a Delaware ) corporation, Certified Copy No. C 06 2361 WHA VOLUME I ) Plaintiff, vs. BLOCKBUSTER INC., a Delaware ) ) ) 9 10 11 corporation, DOES 1-50, Defendants. ) ) 12 ------------------------------13 AND RELATED COUNTER ACTION. i''' Ji 14 15 16 17 18 Deposi tion of ERIC P. MEYER, at 1620 26th Street, Santa Monica, California, commencing at 9: 05 A.M., 19 20 21 22 23 24 Friday, September 22, 2006, before Judith A. Mango, CSR No. 5584. 25 PAGES 1 - 268 Veritext Court Reporting Servces 213623-5005 Case 3:06-cv-02361-WHA Document 129-2 Filed 01/10/2007 Page 3 of 6 1 Q. Yes. It does not ring a bell. Have you 03 : 08 PM 2 3 A. Q. ever seen a patent application in 03 : 08 PM 4 your life? 5 6 7 8 A. Q. Patent application? Yes, sir. I don't think I have seen an application. A. Q. Have you ever seen a patent? I have seen patents. 9 A. Q. 10 11 How many times have you seen patents? 03 : 09 PM A. Q. A few times. Not many times. What's a few? 12 13 14 A. Q. Probably between 10 and 40. 14 or 40? 15 A. Q. 4 0 . 03 : 0 9 PM 40. When did you see your first patent? I don't remember. 16 17 A. Q. is 19 How long ago? I have no A. Q. idea . 03 : 09 PM 20 21 22 When did you see your last patent? Wi thin the last few years, I would say. A. Q. Have you seen a patent wi thin the last two 23 weeks? 24 A. Q. No. Do you know how to read a patent? 03 : 09 PM 188 25 Veri text Court Reporting Services 213623-5005 Case 3:06-cv-02361-WHA Document 129-2 Filed 01/10/2007 Page 4 of 6 1 A. Q. No. So what do you do when you see patents? 03 : 09 PM 2 3 Just kind of hold them up and look at them? 4 A. You look at the title and then you notice 03 : 09 PM 5 6 7 the verbiage is nonreadable for the common mortal. Q. So what have you looked at the patents for? A. You don't always look -- you look at a lot 8 of documents you don't search for and you can look at 9 documents because you are curious. 10 Q. Have you ever read any NetFlix patents? I have glanced at the NetFlix patent when it 03 : 10 PM .11 A. 12 came out. 13 14 Q. How many NetFlix patents are there? I don't know. A. Q. 15 16 17 How many have you looked at? At least one. 03 : 10 PM A. Q. Is it fair to say you looked to see if you 18 were named as an inventor? 19 20 A. Q. I knew I was not named as an inventor. How did you know you were not named as an 03 : i 0 PM 21 inventor? Let me rephrase. Let me rephrase the 22 question. 23 24 A. Q. I was still at NetFlix but I don't remember. Did somebody tell you that you were not 03 : 11 PM 189 25 being named as an inventor? Veritext Court Reporting Services 213 623-5005 Case 3:06-cv-02361-WHA Document 129-2 Filed 01/10/2007 Page 5 of 6 i 3 STATE OF CALIFORNIA ss: 2 COUNTY OF LOS ANGELES 4 I, JUDITH A. MANGO, CSR No. 5584, do hereby 5 certify: 6 7 That the foregoing deposition of ERIC P. MEYER 8 was taken before me at the time and place therein set 9 forth, at which time the witness was placed under 10 oath and was sworn by me to tell the truth, the whole 11 truth, and nothing but the truth; 12 13 That the testimony of the witness and all 14 objections made at the time of the examination were 15 recorded stenographically by me and were thereafter 16 transcribed under my direction and supervision, and 17 that the foregoing pages contain a full, true and 18 accurate record of all proceedings and testimony to 19 the best of my skill and ability. 20 21 I further certify that I am neither counsel for 22 any party to said action, nor am I related to any 23 party to said action, nor am I in any way interested 24 in the outcome thereof. 25 263 Veritext Court Reporting Services 213623-5005 Case 3:06-cv-02361-WHA Document 129-2 Filed 01/10/2007 Page 6 of 6 1 IN WITNESS WHEREOF, I have subscribed my name 2 this 4th day of October, 2006. 3 4 5 6 7 8 A. MAGO, CSR No. 5584 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 264 Veri text Court Reporting Services 213623-5005

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