AMERICAN SOCIETY FOR TESTING AND MATERIALS et al v. PUBLIC.RESOURCE.ORG, INC.

Filing 164

REPLY in support of motion re #163 SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by PUBLIC.RESOURCE.ORG, INC. (This document is SEALED and only available to authorized persons.), #120 SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by PUBLIC.RESOURCE.ORG, INC. (This document is SEALED and only available to authorized persons.) filed by PUBLIC.RESOURCE.ORG, INC.. (Attachments: #1 [Redacted] Declaration of Matthew Becker, #2 [Redacted] Consolidated List of Exhibits, #3 [Redacted] Response to Supplemental Statement of Facts, #4 [Redacted] Response to Statement of Disputed Facts, #5 Supplemental Objections to Evidence, #6 Response to Evidentiary Objections, #7 Supplemental Request for Judicial Notice, #8 Supplemental Declaration of Carl Malamud, #9 Exhibit 1, #10 Exhibit 2, #11 Exhibit 3, #12 Exhibit 4, #13 Exhibit 5, #14 Exhibit 6, #15 Exhibit [Redacted] 7, #16 Exhibit 8, #17 Exhibit 9, #18 Exhibit [Redacted] 10, #19 Exhibit [Redacted] 11, #20 Exhibit 12, #21 Exhibit 13, #22 Exhibit 14, #23 Exhibit 15, #24 Exhibit 16, #25 Exhibit 17)(Bridges, Andrew) Modified text on 2/5/2016 (ztd).

EXHIBIT 4

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UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
- - AMERICAN SOCIETY FOR
: Case No.
TESTING AND MATERIALS d/b/a: 1:13-cv-01215-PSC-DAR
ASTM INTERNATIONAL;
:
:
NATIONAL FIRE PROTECTION
:
ASSOCIATION, INC.; and
:
:
AMERICAN SOCIETY OF
:
HEATING, REFRIGERATING,
:
AND AIR-CONDITIONING
:
ENGINEERS, INC.
:
Plaintiffs,
:
:
vs.
:
:
PUBLIC.RESOURCE.ORG, INC., :
Defendant.
:
___________________________:
AND RELATED COUNTERCLAIMS. :
___________________________:
Videotaped 30(b)(6) deposition
of American Society for Testing & Materials,
through DANIEL SMITH, held in the offices of
Veritext Philadelphia, 1801 Market Street,
Ten Penn Center, Suite 1800, Philadelphia,
Pennsylvania 19103, commencing at 10:43 a.m.,
July 24, 2015, before Linda Rossi Rios, a
Federally Approved RPR, CCR and Notary
Public.

PAGES 1 - 292
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giving your best testimony today?
A. No.
Q. Mr. Smith, what do you do for a
living?
A. I work for ASTM International.
Q. And when you say you work for
ASTM International, what do you mean?
A. I'm the vice -MR. FEE: Objection. Vague.
You can answer.
THE WITNESS: I'm the vice
president of technical committee
operations.
BY MR. BECKER:
Q. And what is technical committee
operations?
A. It's a division within ASTM.
Q. What does technical committee
mean?
A. Technical committees develop
standards.
Q. When you say "standards," what
do you mean by that?
A. Consensus standards.
Q. By "consensus standards," what

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technical committee?
A. A group of experts that develop
standards.
Q. And who are those experts?
A. Volunteers.
Q. And are they only volunteers?
MR. FEE: Objection. Vague.
THE WITNESS: For the most part
from my knowledge, they're all
volunteers.
BY MR. BECKER:
Q. How does a technical committee
go about developing standards as you say?
A. They use our consensus process.
Q. What is the consensus process?
A. It's two levels of voting
starting with the subcommittee and then the
main committee.
Q. What's the difference between a
subcommittee and a main committee?
A. A subcommittee is typically
smaller with a more narrow interest. A main
committee has broader interest.
Q. So within a technical
committee, then, there is -- is there just

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do you mean by that?
A. Documents.
Q. Any documents?
A. Specifications, test methods,
practices, guides, classifications and
terminology.
Q. Does the term "standards" have
any specific meaning to you?
MR. FEE: Objection. Vague.
THE WITNESS: I'm not sure what
you mean by that.
BY MR. BECKER:
Q. Can you define what a standard
is?
A. Just what I said previously,
it's a test method, a specification, a
practice, a guide, classification or
terminology.
Q. And you say that the technical
committees develop standards. How do -actually, let me back up.
What is a technical committee?
A. I'm not sure how to answer
that. I'm not sure what you mean by that.
Q. How would you define a

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one main committee?
A. A main committee is a technical
committee.
Q. And are there numerous
subcommittees?
A. Yes.
Q. And how many subcommittees on
average?
A. It varies.
Q. Could you give me a range by
which it might vary?
A. The best of my knowledge, maybe
from 3 to 40, 50.
Q. When you say there is a
consensus process that involves voting in the
subcommittee and then voting at the main
committee level, can you elaborate on that
process?
MR. FEE: Objection. Vague.
THE WITNESS: They vote on
standards so the folks on that
committee will vote on whether or not
they agree or not agree with the
content of the standard.
BY MR. BECKER:

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1
document.
2
Q. Well, this is the listing of
3
standards that ASTM is asserting are
4
infringed by Public.Resource.Org.
5
- - 6
(Exhibit 1291, Certificates of
7
Copyright Registration, Bates
8
ASTM000001 - ASTM000168, was marked
9
for identification.)
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- - 11
BY MR. BECKER:
12
Q. I'm handing you what has been
13
marked as Exhibit 1291. These are the
documents produced as Bates number ASTM000001 14
15
to ASTM000168. Do you recognize this
16
document?
17
MR. FEE: Objection.
18
Mischaracterizes what has been marked
19
as 1291 as one document.
20
THE WITNESS: I think I saw an
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example of one yesterday.
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BY MR. BECKER:
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Q. What is Exhibit 1291?
24
MR. FEE: Objection. Lack of
25
foundation.

A. It was just in the materials
along with other Bates numbered documents.
Q. Do you recall which Certificate
of Copyright Registration you viewed
yesterday?
A. No.
Q. Was it only one Certificate of
Copyright Registration that you looked at?
A. I believe so.
Q. Did you have any discussions
with anyone in preparation for your
deposition today concerning Certificates of
Copyright Registration by ASTM?
MR. FEE: You can answer it yes
or no.
THE WITNESS: Yes.
BY MR. BECKER:
Q. And who did you have these
discussions with?
A. I had a discussion with Kathe
Hooper.
Q. Anybody else?
A. Other than the legal team, I
don't think so.
Q. I don't believe that Kathe

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THE WITNESS: They look like
they're examples of Certificates of
Copyright Registration.
BY MR. BECKER:
Q. I will represent to you that
Exhibit 1291 is all of the Certificates of
Copyright Registration that ASTM has produced
to Public.Resource in this action.
You said you saw an example of
one of these Certificates of Copyright
Registration yesterday?
A. Yes.
Q. Was that in preparation for
your deposition?
A. Yes.
Q. And in what context did you see
an example of the Certificate of Copyright
Registration?
MR. FEE: Objection. Vague.
THE WITNESS: I'm not sure what
you mean by "context."
BY MR. BECKER:
Q. Were you shown an example of
the Certificate of Copyright Registration by
anybody?

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Hooper was one of the people that you listed
as an individual that you spoke with in
preparation for your deposition?
A. Yeah, we -- I didn't -- we did
not have a special meeting with her.
Q. What did you discuss when you
spoke with Kathe Hooper in preparation for
your deposition today?
A. We discussed why, when this
form was filled out, why we had checked off
the box yes to question 2a about "Was this
contribution to the work a work made for
hire."
Q. And why is that, that box 2a
was checked off on the copyright
registrations?
A. She said that the copyright
office had told her to fill out the form that
way.
Q. Did she say why the copyright
office told her to fill out the form that
way?
A. I don't believe so.
Q. Was she the one who prepared
the copyright registrations?

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A. I think she started back in
1984, I think she may have said.
Q. Do you know who was filling out
ASTM Certificate of Copyright Registration
forms prior to Kathe Hooper?
A. A name was mentioned yesterday,
but I don't recall the name.
Q. Was that individual Robert L.
Meltzer?
A. I recognize that name, but I
don't know if Robert Meltzer was the one that
was filling out this form.
Q. Do you know who Robert Meltzer
is?
A. He was a former vice president
of publications.
Q. Did Kathe Hooper say what
communications with the copyright office led
to her decision to check box 2a of the
copyright registrations?
A. What led her to fill out this
form that way?
Q. Did she say what communications
she had with the copyright office that led
her to fill out the forms to check box 2a?

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Q. Do you know what had been the
discussion with the copyright office by Kathe
Hooper's predecessor concerning checking box
2a?
A. Do I know?
MR. FEE: Objection.
BY MR. BECKER:
Q. Yeah.
MR. FEE: Vague.
THE WITNESS: I only know what
Kathe Hooper told me.
BY MR. BECKER:
Q. And what precisely did Kathe
Hooper tell you about that?
MR. FEE: Objection. Asked and
answered.
THE WITNESS: That the copyright
office had informed Kathe Hooper's
predecessor to check box yes to the
answer -- to the question on 2a.
BY MR. BECKER:
Q. Did Kathe Hooper tell you any
information about what her predecessor had
said to the copyright office that led to the
copyright office telling her to check box 2a?

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A. She had said that her
predecessor had a conversation with the
copyright office, and they had informed her
that it should be filled out that way.
Q. Do you know if Kathe Hooper had
any interactions with the copyright office in
which the copyright office told her to fill
out the registrations by checking box 2a?
A. I don't believe she did.
Q. What is Kathe Hooper's role at
ASTM?
A. She assists the vice president
of publications.
Q. How long has Kathe Hooper held
that role for at ASTM?
A. I can't say for certain, but I
think she said yesterday, since about 1984
she was in that role.
Q. And currently the vice
president of publications is John Pace.
Correct?
A. Correct.
Q. Do you know how long John Pace
has held that role for?
A. It's been about 11 years.

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A. No. My understanding is it was
just a question on how to fill out the form.
Q. Did ASTM ever have a lawyer
review the applications for copyright
registration?
A. I don't know.
Q. Do you have any knowledge about
what information the copyright office had
obtained from ASTM when it said to check box
2a?
A. No.
Q. If ASTM had provided different
facts concerning the material that was being
copyrighted, that might call for a different
answer to whether box 2a should be checked on
the copyright registration form. Correct?
MR. FEE: Objection. Calls for
speculation. Calls for a legal
conclusion. Calls for expert
testimony. You can answer if you
know.
THE WITNESS: I don't know.
BY MR. BECKER:
Q. Why is ASTM listed as the
author under section 2a?

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A. I think the copyright office
told us to fill out the form in that manner.
Q. Did Kathe Hooper tell you that
the copyright office said to fill out the
copyright registration form by putting
American Society for Testing and Materials
under name of author, section 2a?
A. Yes.
Q. Did Kathe Hooper tell you
anything else about listing ASTM under the
name of author field in section 2a?
A. No.
Q. Are there any documents that
reflect ASTM's communication with the
copyright office concerning how to fill out
section 2a of the forms for copyright
registration?
MR. FEE: Objection. Calls for
speculation. This is beyond the
scope. You can answer.
THE WITNESS: Not that I'm aware
of.
BY MR. BECKER:
Q. Are there any letters that
reflect ASTM's communication with the

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concerning how to fill out section 2a of the
forms for copyright registration?
MR. FEE: Objection. Calls for
speculation. Beyond the scope of his
designation. You can answer.
THE WITNESS: I don't know.
Maybe the people that worked in our
publications department at the time
that that question was -- at the time
that the copyright office had informed
us.
BY MR. BECKER:
Q. Do you know who was the
president of publications as of the time that
ASTM communicated with the copyright office
regarding how to fill out section 2a of the
copyright registration forms?
A. I believe it was Bob Meltzer,
Robert Meltzer.
Q. Do you know if Robert Meltzer
is still alive?
A. I don't know for sure.
MR. FEE: Matt, is now a good
time to take a break?
MR. BECKER: We can in just a

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copyright office concerning how to fill out
section 2a of the forms for copyright
registration?
MR. FEE: Objection. Same
objections as before, plus you just
answered that question. You can
answer it again.
THE WITNESS: Not that I'm aware
of.
BY MR. BECKER:
Q. Are there any internal memos
that reflect ASTM's communication with the
copyright office concerning how to fill out
section 2a of the forms for copyright
registration?
MR. FEE: Objection. Calls for
speculation. It's beyond the scope of
his designation. You can answer if
you know.
THE WITNESS: Not that I'm aware
of.
BY MR. BECKER:
Q. Who would know whether any
documents exist that reflect ASTM's
communications with the copyright office

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moment.
BY MR. BECKER:
Q. Please turn to page ASTM000107
of Exhibit 1291. I will represent to you
that this is the earliest copyright
registration that ASTM has provided to
Public.Resource in this action. Under
section 2-1, in the section that says, "NAME
OF AUTHOR," do you see that it lists
"American Society for Testing and Materials,"
and then says, "Was this author's
contribution to the work a 'work made for
hire,'" and then checks the box yes?
A. Yes.
Q. And then on the next page, do
you see that under the "CERTIFICATION" near
the bottom of the page, it lists "Robert L.
Meltzer," and then has his -- what appears to
be his signature -A. Yes.
Q. -- with a date of January 31,
1980?
A. Yes.
Q. Is it your belief that as of at
least January 31, 1980, Kathe Hooper's

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predecessor had had a conversation with the
copyright office in which they instructed her
to check the box saying that the -- scratch
that.
Is it your understanding that
as of at least January 31, 1980, someone at
ASTM had had a conversation with someone from
the copyright office in which that person
from ASTM was instructed to check the box
saying that the work was a "work made for
hire," and listing the name "American Society
for Testing and Materials" under the "NAME OF
AUTHOR" field?
MR. FEE: Objection to form.
THE WITNESS: I'm not sure I
understand the question. If you could
rephrase it, I'm a little lost.
BY MR. BECKER:
Q. Sure. Is it your -- after
looking at this document, page ASTM000107 to
108, is it your understanding that as of at
least January 31, 1980, someone at ASTM had a
conversation with someone from the copyright
office in which that person from ASTM was
instructed to check the box saying that the

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Q. Mr. Smith, do you know which
standards at issue in this litigation each
copyright registration that ASTM has provided
corresponds to?
A. I'm not sure I get the
question.
Q. If you look at, we were just
discussing ASTM000107 in Exhibit 1291, that's
a standard, the title of the work is "1980
ANNUAL BOOK OF ASTM STANDARDS, Part
1:Steel-Piping, Tubing, Fittings." Is that
correct?
A. Correct.
Q. Do you know how many standards
are in the 1980 Annual Book of ASTM
Standards, Part 1:Steel-Piping, Tubing,
Fittings?
A. No.
MR. FEE: Objection. Beyond the
scope of his designation.
THE WITNESS: No, I don't.
MR. BECKER: I would disagree, I
don't think this is beyond the scope
of his designation. This has to do
with the -- with copyright ownership

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work was a "work made for hire," and listing
the names "American Society for Testing and
Materials" under the "NAME OF AUTHOR" field?
MR. FEE: Objection. Form. Go
ahead.
THE WITNESS: Yeah, I believe
that's right, I just don't know
when that con -- I don't know when
that conversation exactly was made.
BY MR. BECKER:
Q. But you believe it was as of at
least January 31, 1980?
A. I don't know. It could have
been before that. I really don't know.
MR. BECKER: All right. We can
go off the record.
VIDEOGRAPHER: The time is now
3:08. We're going off the video
record.
- - (A recess was taken.)
- - VIDEOGRAPHER: The time is now
3:20. We're back on the video record.
BY MR. BECKER:

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and the chain of title. This is -MR. FEE: You just asked him how
many chapters essentially there were
in a book.
MR. BECKER: Well, that's one of
the questions I have, is related to
this particular registration. It's a
registration for a work.
MR. FEE: We disagree for the
record.
BY MR. BECKER:
Q. Are there multiple standards
listed in the 1980 Annual Book of ASTM
Standards, Part 1:Steel-Piping, Tubing,
Fittings?
MR. FEE: Same objection.
THE WITNESS: Yes.
BY MR. BECKER:
Q. How do you know that?
A. Because it's our volume of
standards and volumes contain more than one
standard.
Q. Is there a way to confirm -excuse me, scratch that.
Do you know how to determine

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Annual Book of ASTM Standards, Part
1:Steel-Piping, Tubing, Fittings?
A. I don't know specifically if
there would be -- you know, if it was called
the same thing, a Part 1 or -- because
sometimes we have to reshuffle our volumes
depending -- as they get bigger, we have to
manage the size of each volume. So I don't
know if it was -- would have been called Part
1 or something else, but I also don't know if
the same exact standards that were in there
in 1979 are not necessarily in there in 1980.
Q. Would ASTM A370 1977e2 have
been published in an Annual Book of ASTM
Standards prior to 1980?
A. Most -- yeah, most likely, yep.
Q. Do you know why ASTM has not
provided Public.Resource with the copyright
registrations for any such volumes prior to
1980?
MR. FEE: Objection. Calls for
speculation. Beyond the scope of his
designation.
THE WITNESS: I don't know.
BY MR. BECKER:

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A. Yes. Nothing is technically
significant.
Q. Returning to ASTM000108, just
below where it lists the information under
"PREVIOUS REGISTRATION," it has a section
that says, "COMPILATION OR DERIVATIVE WORK"
which says, "PREEXISTING MATERIAL." And then
below that it says, "1979 Annual Book of ASTM
Standards, Part 1." And then below that,
"MATERIAL ADDED TO THIS WORK," it says,
"Compilation of previously published text
plus additional text."
Do you know what that
additional text is that was added to the 1979
Annual Book of ASTM Standards, Part 1 to
create the 1980 Annual Book of ASTM
Standards, Part 1?
A. I don't know exactly what that
text was, but it's -- my guess is that it
means revisions to the standards that were
included in the 1979 book that are also
included in the 1980 book, but there are also
revisions, and any new standards that were
approved that were not in the 1979 book but
made it to the 1980 book.

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Q. Why are some standards
re-approved?
MR. FEE: Objection. Beyond the
scope of his designations.
THE WITNESS: The technical
committees make the decision as to
whether or not they want to re-approve
the standard through the consensus
process.
BY MR. BECKER:
Q. And in what situations are
standards re-approved?
MR. FEE: Same objection.
THE WITNESS: If the committees
want -- it's up to the committees. So
if there's -- if the committees are
happy with the current state of the
standard and they don't feel like
there's any revisions that are
necessary, then they can initiate a
ballot for a re-approval.
BY MR. BECKER:
Q. And does that re-approval mean
there are no changes from the previous
version?

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Q. Is the basis of your previous
statement that typically the next years'
Annual Book of Standards includes standards
that had been recently approved or changed in
that past year?
MR. FEE: Objection.
Mischaracterizes his testimony. Vague
and confusing.
THE WITNESS: Can you restate
that?
BY MR. BECKER:
Q. Yeah. Maybe I'll just ask you,
what's the basis for your guess that the
revisions to the standards that were included
in the 1979 book are -- excuse me.
What is the basis for your
statement that your guess is that any
revisions to the 1979 book of standards that
resulted in the 1980 book of standards is
attributable to new standards or revised
standards within that past year?
MR. FEE: Objection. Vague.
Confusing.
THE WITNESS: I'm not sure I
completely understand what your

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1 IP Policy or assignments?
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MR. BECKER: Object as to form.
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THE WITNESS: There is
4
additional language. This document
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identifies membership renewal Web
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screenshots for different types of
7
members. So I identified page 2, and
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then there's also additional language
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on page ASTM001796 as well as
10
ASTM001798. And I believe that's it.
11
MR. FEE: I have no other
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questions.
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Do you have any other questions
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or is he done?
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MR. BECKER: No, no redirect.
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MR. FEE: Great. Thank you.
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THE WITNESS: Thanks.
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VIDEOGRAPHER: The time is now
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7:57. This concludes the videotape
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deposition of Dan Smith.
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- - 22
(Witness excused.)
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- - 24
(Deposition concluded at 7:57
25
p.m.)

1
I declare under penalty of perjury
2 under the laws that the foregoing is
3 true and correct.
4
5
Executed on _________________ , 20___,
6 at _____________, ___________________________.
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_____________________________
12
DANIEL SMITH
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Page 292

CERTIFICATE

I do hereby certify that I am a Notary
4 Public in good standing, that the aforesaid
testimony was taken before me, pursuant to
5 notice, at the time and place indicated; that
said deponent was by me duly sworn to tell
6 the truth, the whole truth, and nothing but
the truth; that the testimony of said
7 deponent was correctly recorded in machine
shorthand by me and thereafter transcribed
8 under my supervision with computer-aided
transcription; that the deposition is a true
9 and correct record of the testimony given by
the witness; and that I am neither of counsel
10 nor kin to any party in said action, nor
interested in the outcome thereof.
11
WITNESS my hand and official seal this
12 7th day of August, 2015.
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____________________________
Notary Public
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