J.T. Colby & Company, Inc. et al v. Apple, Inc.

Filing 126

DECLARATION of Partha P. Chattoraj in Opposition re: 104 MOTION for Summary Judgment.. Document filed by Ipicturebooks LLC, J.Boyston & Company, J.T. Colby & Company, Inc., Publishers LLC. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13, # 14 Exhibit 14, # 15 Exhibit 15, # 16 Exhibit 16, # 17 Exhibit 17, # 18 Exhibit 18, # 19 Exhibit 19, # 20 Exhibit 20, # 21 Exhibit 21, # 22 Exhibit 22, # 23 Exhibit 23, # 24 Exhibit 24, # 25 Exhibit 25, # 26 Exhibit 26, # 27 Exhibit 27, # 28 Exhibit 28, # 29 Exhibit 29, # 30 Exhibit 30, # 31 Exhibit 31, # 32 Exhibit 32, # 33 Exhibit 33, # 34 Exhibit 34, # 35 Exhibit 35, # 36 Exhibit 36, # 37 Exhibit 37, # 38 Exhibit 38, # 39 Exhibit 39, # 40 Exhibit 40, # 41 Exhibit 41, # 42 Exhibit 42, # 43 Exhibit 43, # 44 Exhibit 44, # 45 Exhibit 45, # 46 Exhibit 46, # 47 Exhibit 47, # 48 Exhibit 48, # 49 Exhibit 49, # 50 Exhibit 50, # 51 Exhibit 51, # 52 Exhibit 52, # 53 Exhibit 53, # 54 Exhibit 54, # 55 Exhibit 55, # 56 Exhibit 56, # 57 Exhibit 57, # 58 Exhibit 58, # 59 Exhibit 59, # 60 Exhibit 60, # 61 Exhibit 61, # 62 Exhibit 62, # 63 Exhibit 63, # 64 Exhibit 64, # 65 Exhibit 65, # 66 Exhibit 66, # 67 Exhibit 67, # 68 Exhibit 68, # 69 Exhibit 69, # 70 Exhibit 70, # 71 Exhibit 71, # 72 Exhibit 72, # 73 Exhibit 73, # 74 Exhibit 74, # 75 Exhibit 75, # 76 Exhibit 76, # 77 Exhibit 77, # 78 Exhibit 78, # 79 Exhibit 79, # 80 Exhibit 80, # 81 Exhibit 81, # 82 Exhibit 82, # 83 Exhibit 83, # 84 Exhibit 84, # 85 Exhibit 85, # 86 Exhibit 86, # 87 Exhibit 87, # 88 Exhibit 88, # 89 Exhibit 89, # 90 Exhibit 90, # 91 Exhibit 91, # 92 Exhibit 92, # 93 Exhibit 93, # 94 Exhibit 94, # 95 Exhibit 95, # 96 Exhibit 96, # 97 Exhibit 97, # 98 Exhibit 98, # 99 Exhibit 99, # 100 Exhibit 100, # 101 Exhibit 101, # 102 Exhibit 102, # 103 Exhibit 103, # 104 Exhibit 104 Part 1, # 105 Exhibit 104 Part 2, # 106 Exhibit 104 Part 3, # 107 Exhibit 104 Part 4, # 108 Exhibit 104 Part 5, # 109 Exhibit 104 Part 6, # 110 Exhibit 104 Part 7, # 111 Exhibit 105, # 112 Exhibit 106, # 113 Exhibit 107, # 114 Exhibit 108, # 115 Exhibit 109, # 116 Exhibit 110, # 117 Exhibit 111, # 118 Exhibit 112, # 119 Exhibit 113, # 120 Exhibit 114, # 121 Exhibit 115, # 122 Exhibit 116, # 123 Exhibit 117, # 124 Exhibit 118, # 125 Exhibit 119)(Chattoraj, Partha)

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EXHmiT90 Page 1 1 IN THE UNITED STATES DISTRICT COURT 2 SOUTHERN DISTRICT OF NEW YORK 3 4 5 J.T. COLBY, INC., et al., 6 Plaintiffs, 7 vs. 8 APPLE, INC. , CASE No. 9 11-CIV-4060 Defendants. __________________________ / 10 11 12 13 VIDEOTAPED DEPOSITION OF LINDA TAYLOR 14 REDWOOD SHORES, CALIFORNIA 15 TUESDAY, OCTOBER 9, 2012 16 17 18 19 20 21 BY: 22 CSR LICENSE NO. 9830 23 JOB NO. 54541 ANDREA M. IGNACIO HOWARD, CSR, RPR, CCRR, CLR 24 25 TSG Reporting- Worldwide 877-702-9580 Page 60 1 or around it, rather, why do you use it in your 2 advertising and marketing materials? 3 MS. CENDALI: 4 You can answer. 5 THE WITNESS: 6 Objection. MR. CHATTORAJ: ~ Q. 1 I ~ To the best of your 8 knowledge, when you released the iBook notebook 9 computer to the public, did you use the R with the 10 I I ~! We use it to indicate that it is a registered trademark. 7 ~ lj I little circle around it? 11 A Yes, 12 Q Do you have any knowledge yourself about the I believe we did. 13 registration process that occurred with respect to the 14 iBook trademark? 15 A No, 16 Q Have you ever heard of a company called 17 I do not. Family Systems Limited? 18 A No, 19 Q Are you aware of any agreements that existed I have not. 20 between Apple and Family Systems Limited at any point 21 before the present? 22 A No. 23 Q When the iBook was first released to the 24 public, what were the media in which it was initially 25 advertised? TSG Reporting- Worldwide 877-702-9580 ~ I I I I ~ I

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