Weather Underground, Incorporated v. Navigation Catalyst Systems, Incorporated et al

Filing 216

REPLY to Response re 189 MOTION for Partial Summary Judgment filed by Weather Underground, Incorporated. (Attachments: # 1 Index of Exhibits, # 2 Exhibit OO, # 3 Exhibit PP, # 4 Exhibit QQ, # 5 Exhibit RR, # 6 Exhibit SS, # 7 Exhibit UU) (Schaefer, Enrico)

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Jacoby, Seth Confidential - Attorneys' Eyes Only 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 9/15/2010 UNITED STATED DISTRICT COURT EASTERN DISTRICT OF MICHIGAN 1 -------------------------------x THE WEATHER UNDERGROUND, INC., a Michigan corporation, Plaintiff, vs. Case No. 2:09-CV-10756 NAVIGATION CATALYST SYSTEMS, INC., a Delaware corporation; BASIC FUSION, INC., a Delaware Corporation; CONNEXUS CORP., a Delaware corporation; and FIRSTLOOK, INC., a Delaware corporation, Defendants. -------------------------------x C O N F I D E N T I A L A T T O R N E Y S' E Y E S O N L Y Butzel Long, P.C. 380 Madison Avenue New York, New York Wednesday, September 15, 2010 10:03 a.m. Videotape deposition of SETH JACOBY, held at the above-mentioned time and place, before Elizabeth M. Kondor, CCR, CLR and Notary Public. Westlaw Deposition Services 800.548.3668 Ext. 1 Jacoby, Seth Confidential - Attorneys' Eyes Only 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. 9/15/2010 I'm responsible for running the 30 Firstlook business, which includes domain acquisition, domain optimization, lander page optimization, toolbar development, toolbar search optimization. I run the technology group, I run the business group. employees. Q. There's approximately 19 I'm in charge of the business. And how are those employees broken down, generally, in terms of domain acquisition versus toolbar versus lander pages? A. Let's see. So, the toolbar business probably -- of course, there's going to be overlap between those businesses, because they're all somewhat related, but the toolbar business probably is -- if I had to break it down in percentages, would that work for you? Q. A. Sure. I would say probably 10 percent of the business works on the toolbar-related business. Maybe 50 percent of the business is related to page optimization, sort of page delivery, and that includes for toolbar pages and domain pages. And the rest of the business is -- maybe 20 percent -- I guess that's about right. And then the remaining part is surrounded around Westlaw Deposition Services 800.548.3668 Ext. 1

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