J.T. Colby & Company, Inc. et al v. Apple, Inc.
Filing
127
DECLARATION of Dale M. Cendali in Opposition re: 87 MOTION for Partial Summary Judgment.. Document filed by Apple Inc.. (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 Tab - Borden Dep., # 10 Tab - Colby 30(b)(6) Dep., # 11 Tab - Gedikian Dep., # 12 Tab - Goldhor Dep., # 13 Tab - Gundersen Dep., # 14 Tab - Kvamme Dep., # 15 Tab - La Perle Dep. (REDACTED), # 16 Tab - Widup Dep.)(Cendali, Dale)
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
2
3
4
5
J.T. COLBY & COMPANY, INC.,
d/b/a BRICK TOWER PRESS,
J. BOYLSTON & COMPANY,
PUBLISHERS, LLC and
IPICTUREBOOKS, LLC,
6
Plaintiff,
7
vs.
Case No. 11-CIV4060 (DLC)
8
APPLE, INC.,
9
10
Defendant.
-----------------------------/
11
12
13
14
15
16
17
HIGHLY CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER
Attorneys' Eyes Only Confidential Pages 300 - 302
VIDEOTAPED DEPOSITION OF THOMAS LA PERLE
30(b)(6) Capacity
Redwood Shores, California
Wednesday, September 19, 2012
18
19
20
21
22
23
Reported by:
LORRIE L. MARCHANT, CSR No. 10523
RPR, CRR, CCRR, CLR
24
25
JOB NO. 53418
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question pending.
2
please read the question back.
Madam Court Reporter, can you
3
(Discussion off the record.)
4
(Record read as follows:
5
"Q
6
to use the '
7
"A
Yes.
8
"Q
Who made that decision?
9
MS. CENDALI:
10
THE WITNESS:
that decision.
13
14
' name?
Just a name.")
And without waiving any
privilege, he can answer as to a factual matter.
11
12
Was a decision at some point made not
I believe Steve Jobs made
Subject to our trademark clearance.
BY MR. CHATTORAJ:
Q.
You -- I just want to make sure I
15
understand your testimony.
16
made that decision subject to your trademark
17
clearance?
18
A.
So he decided that he did not want to go
19
with "
" and wanted us to look at "iBooks."
20
And we were doing trademark clearance for that.
21
22
23
Q.
You said that Steve Jobs
So in what way was Mr. Jobs' decision
subject to your trademark clearance?
A.
Well, your question was did someone -- who
24
made the decision to look into -- this is how I
25
interpreted your question:
Who made the decision to
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look into "iBooks"?
2
asked us to look into that -- that name.
3
Q.
And that person was Steve Jobs
That was helpful testimony, but that was
4
not my question.
5
promise.
6
7
My question was just who made the decision
not to use "
8
9
10
We'll get there, though, I
"?
MS. CENDALI:
Well, objection.
question speaks for itself.
Your
But is there a new
question?
11
MR. CHATTORAJ:
I think we really need to
12
stick to the -- the order the Court made about
13
objections.
14
BY MR. CHATTORAJ:
15
16
I am asking the following question.
Q.
"
Who made the decision not to use the name
"?
17
A.
I don't know.
18
Q.
Were any names other than "
19
20
" and
"iBooks" considered for the eReader application?
A.
I don't believe so.
But as I sit here
21
today, I don't recall if there were other names.
22
Those are the two that I do recall.
23
24
25
Q.
Is it fair to say that Steve Jobs had the
idea of calling the eReader application "iBooks"?
A.
I -- I was told that Steve Jobs wanted us
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1
with using the name "iBooks" for its eReader and
2
bookstore application?
3
4
5
A.
We proceeded with the -- some further work
that we had to do for the trademark clearance.
Q.
What was that further work?
Without
6
revealing attorney-client privilege, beyond
7
trademark clearance?
8
9
A.
Well, we had to -- as you know, we had to
acquire the Family Systems rights.
10
Q.
When was that decision made?
11
A.
I don't recall the exact date.
12
Q.
Were you instructed to carry that out, or
13
14
15
16
17
did you make that decision on your own?
A.
The decision to -- what decision are you
referring to?
Q.
The decision to acquire the Family Systems
mark.
18
A.
Oh, that was my recommendation.
19
Q.
When you made that recommendation, was that
20
in reliance on the opinion prepared by the Dechert
21
firm or based on your own analysis?
22
MS. CENDALI:
Okay.
Again, I'm concerned
23
that we're getting into matters of privilege here.
24
I think we should take a break to discuss it.
25
MR. CHATTORAJ:
That's fine.
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If it's okay
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with you, Mr. La Perle.
2
THE WITNESS:
3
MR. CHATTORAJ:
4
THE VIDEOGRAPHER:
5
No. 1, Volume I.
6
Yes.
We'll go off the record.
This is the end of Disk
12:04 p.m.
We are off the record at
7
(Recess taken, from 12:04 to 12:17.)
8
THE VIDEOGRAPHER:
9
10
11
Disk No. 2, Volume I.
12:17 p.m.
This is the beginning of
We are back on the record at
You may proceed.
MR. CHATTORAJ:
We went off the record so
12
that Mr. La Perle could consult with his counsel
13
regarding a question of privilege.
14
that, there was a question pending.
15
that the reporter kindly read back that question.
When we did
I would ask
16
(Record read as follows:
17
"Q
18
that in reliance on the opinion prepared by
19
the Dechert firm or based on your own
20
analysis?")
21
MS. CENDALI:
22
23
When you made that recommendation, was
I instruct you not to answer
on the grounds of attorney-client privilege.
However, you could inquire as to a factual
24
matter as to who made the decision to pursue an
25
agreement with Family Systems.
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2
3
BY MR. CHATTORAJ:
Q.
Who made the decision to pursue an
agreement with Family Systems?
4
A.
Steve Jobs.
5
Q.
Did anyone else participate in that
6
7
decision besides Mr. Jobs?
A.
Bruce Sewell, who I reported -- reported
8
to, had reported to Steve.
9
don't know to what extent, but I know he was the one
10
11
So he was involved.
I
that was portraying our -- our search reports.
Q.
Did Steve Jobs make the decision to use the
12
"iBooks" mark before or after he made the decision
13
to acquire the mark from Family Systems?
14
A.
I don't know the answer to that.
I know we
15
were instructed to pursue the trademark clearance
16
project.
17
18
19
Q.
So it's fair to say that Steve Jobs made
the decision to use the "iBooks" mark; right?
A.
No.
I'm saying that Steve Jobs made the
20
decision to instruct us to pursue the acquisition of
21
the Family Systems mark.
22
Q.
At some point in time, did Steve Jobs make
23
the decision to use the "iBooks" mark for the
24
eReader software application we've been discussing?
25
A.
I assume that Steve Jobs was the person
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that made the decision from -- based on the
2
correspondence I had seen that was between -- again,
3
as I testified, I was corresponding with
4
Bruce Sewell, who was having discussions with
5
Steve Jobs.
6
7
Q.
When was the decision made to seek -- to
acquire the trademark from Family Systems?
8
A.
I don't know the exact date.
9
Q.
Do you know what year?
10
A.
Again, I'm not sure.
11
January of 2010.
12
I believe it was in
certain.
13
Q.
But I -- I am not 100 percent
Do you know when Apple first publicly
14
announced the name "iBooks" for the eReader
15
application that would be made available on the
16
iPad?
17
A.
Yes.
18
Q.
What date was that?
19
A.
I believe it was January 21st, 2010.
20
21
MS. CENDALI:
I believe, Counsel, it was,
for the sake of the record, January 24th.
22
THE WITNESS:
24th.
23
MS. CENDALI:
26th?
24
MR. CHATTORAJ:
25
I'm sorry.
24th.
You know what, Counsel,
we'll take the witness's testimony.
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Q.
Does -- would anyone at Apple know that?
2
A.
People in our corporate communications
3
4
5
6
7
department would know that.
Q.
testify about that issue; right?
A.
I don't have knowledge of the specific
press release related to the iPad product.
8
9
But right now you're not prepared to
MS. CENDALI:
Is lunch here?
It's after
12:30.
10
MR. CHATTORAJ:
Lunch is here.
I'm just
11
going to ask one or two more questions, and then
12
we'll break.
Is that okay?
13
MS. CENDALI:
14
MR. CHATTORAJ:
Okay.
And for the record, lunch
15
has actually been put in your breakout room, so what
16
we'll do is we'll take our food and go elsewhere so
17
you have privacy.
18
MS. CENDALI:
19
BY MR. CHATTORAJ:
20
21
22
23
24
25
Q.
Okay.
When was the first time you heard of Family
Systems?
A.
I don't recall the exact date, but it was
shortly after I got to -- to Apple in 1999.
Q.
When you got to Apple in 1999, had Apple
already had communications with Family Systems, or
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did that begin at a point in time after you joined
2
the company?
3
4
5
A.
It had began before I joined the
company.
Q.
6
7
No.
At the time -- well, withdrawn.
What -- what is your understanding of what
Family Systems' business is today?
8
A.
Today?
9
Q.
Today.
10
A.
I don't know what their business is today.
11
Q.
Did you ever have an understanding of what
12
their business was?
13
A.
Yes.
14
Q.
Did you have that understanding in 1999?
15
A.
I can't say it was 19- -- I joined Apple on
16
September -- September 15th, 1999.
17
was the end of '99 or sometime in 2000, I can't say
18
exactly.
19
around late '99 and 2000.
20
21
22
23
24
25
Q.
So whether it
But I became aware of them, you know,
And at that time what was your
understanding of what Family Systems' business was?
A.
Family Systems was in the E-book reader
software business.
Q.
So it was your understanding that they made
E-book readers?
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A.
Software.
2
Q.
Sorry.
3
It was your understanding that they
made software to read E-books; right?
4
A.
Correct.
5
Q.
Who told you that?
6
A.
Well, I was aware of their U.S. trademark
7
application, and I did view their Web site as well.
8
And I was also aware of the consent agreement that
9
Apple had -- had done with Family Systems.
10
Q.
So between reviewing the consent agreement,
11
visiting the Family Systems Web site as it then
12
existed and reviewing the Family Systems trademark
13
application, you came to the conclusion that Family
14
Systems' business was to produce and distribute
15
E-book software?
16
A.
Software, you know, as it's portrayed in
17
their trademark applications.
18
and supporting user-modifiable electronic books.
Software for creating
19
Q.
So --
20
A.
Which is E-book reader software.
21
Q.
So, again, just so I'm clear, your
22
understanding at that time was that Family Systems
23
was in the business of E-book reader software; is
24
that right?
25
A.
Yeah.
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2
3
Q.
Okay.
Did that understanding ever change
at any point in time?
A.
I mean they had some other -- other
4
services, I think, that were related to that, but
5
that was primarily their business.
6
software developers.
7
8
9
Q.
They were
Did you gain knowledge about the other
areas of business they were involved in?
A.
I believe they did some Web hosting
10
business, but I didn't -- I'm not an expert on
11
Family Systems.
12
Q.
At that time of the transaction that Apple
13
entered into with Family Systems in 2010, what was
14
the business of Family Systems?
15
A.
Well, their -- their Web site was still up
16
and the software was still available for download.
17
I think they were in essentially the same business
18
as they were before.
19
20
Q.
So it's your testimony that they were in
the E-book reader software business?
21
A.
Correct.
22
Q.
And that they made E-book reader software
23
24
25
available for download on their Web site?
A.
Software, you know, as reflected in the --
in the U.S. registration.
Software that supports
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and creates user-modifiable electronic books, which
2
I would categorize as E-book reader software.
3
Q.
So what is an E-book?
4
A.
It's a -- it's a book in electronic form.
5
6
It's an electronic book.
Q.
Is there any distinction in your mind
7
between, like, the E-book version of a publicly
8
available printed book like, for example, a Stephen
9
King novel or "King Lear," on one hand, and the
10
electronic books that were made available to be read
11
through the software offered by Family Systems?
12
13
14
15
A.
I don't believe Family Systems was
providing books like Stephen King books.
Q.
Was Family Systems in the business of
providing "King Lear"?
16
A.
I don't know.
17
Q.
Was Family Systems in the business of
18
providing E-books that were available for sale in
19
hard copy in bookstores?
20
A.
Not that I'm aware of.
21
Q.
Is the answer, no?
22
A.
Not that I'm aware of.
23
Q.
Did you ever undertake an investigation of
24
Family Systems' business beyond the trademark
25
filings, their Web site and the consent agreement?
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time that was a question pending, and at this time I
2
would ask that the reporter to read back that
3
question.
4
(Record read as follows:
5
"Q
6
of Family Systems' business beyond the
7
trademark filings, their Web site and the
8
consent agreement?")
9
MS. CENDALI:
Did you ever undertake an investigation
And I instruct you not to
10
answer with regard to your communications with your
11
outside counsel; however, you can answer factually
12
with regard to what was done.
13
THE WITNESS:
So during the trademark
14
clearance process and the acquisition of the Family
15
Systems' mark, we did additional investigations of
16
the company.
17
18
19
BY MR. CHATTORAJ:
Q.
And when you say "investigations," you mean
investigations of their business?
20
A.
Yes.
21
Q.
What they do?
22
A.
Yes.
23
Q.
And what they did?
24
A.
Yes.
25
Q.
You indicated that a decision had been made
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adopted the iBooks software, it did not allow you to
2
do that.
3
4
Q.
When was the iBooks Author product made
available to consumers?
5
A.
I don't know the exact date.
6
Q.
Was it in 2010?
7
A.
I -- I don't know the date, actually.
8
Offhand I'd have to check.
9
supplement the record on that.
10
11
MR. CHATTORAJ:
We'll leave a blank
(Information requested:
________________
__________________________________________________.)
14
15
Okay.
if you'd like to supplement that.
12
13
I could -- I could
BY MR. CHATTORAJ:
Q.
If I represented to you that iBooks Author
16
was made available to consumers in 2012, would that
17
seem crazy and off the wall and wrong to you?
18
A.
No.
19
Q.
It's possible that it was in 2012?
20
A.
Yeah.
So when I'm talking about Apple
21
adopting the mark that's substantially similar, I'm
22
not talking about every single functionality of
23
Family Systems' ibooks.
24
was was E-book reading and creation software, and
25
that's exactly what Apple's iBook is.
What Family Systems' ibooks
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1
have the Web hosting functionality that Family
2
Systems used.
3
Q.
Let me make sure I understand.
If you turn
4
to page 2 of this document, there appears a question
5
in the middle of the page:
6
Can I have my own ibook?
And then there appears to be the answer:
7
Yes.
8
server working on your Web sites.
9
enrolled, you will be able to read about how to set
10
Subject to some rules, you can have an ibook
Once you are
up an ibook server.
11
Do you see that there?
12
A.
Yes.
13
Q.
Did Apple ever offer for consumers a
14
software package that was called iBook Server?
15
A.
No.
16
Q.
Did -- did Apple at any time after
17
January 2010 make available to consumers software
18
that allowed people to set up an iBook server, you
19
know, using the name "iBook Server"?
20
A.
No.
21
Q.
The bottom of the first page is written:
22
Can I contribute to ibooks?
23
And then the answer appears on the second
24
page:
25
the ibook you want to contribute to.
We hope you will.
First, you need to find
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Systems, Limited, products, do you have an
2
understanding of whether -- before 2010, a user
3
modification of a Family Systems ibook would change
4
other users experience of that ibook?
5
A.
I do not have direct knowledge of that, no.
6
Q.
Do you have any knowledge, direct or
7
8
9
10
indirect?
A.
that.
Q.
Right now my recollection is I don't recall
I believe -- well, I don't recall right now.
All right.
It was a -- the way that Family
11
Systems used ibooks, they were essentially personal
12
Web sites; right?
13
MS. CENDALI:
14
BY MR. CHATTORAJ:
Objection.
15
Q.
You may answer.
16
A.
It was software for creating E-books.
17
Whether the E-books were on Web sites or elsewhere,
18
I believe they were hosted on the Web sites.
19
Q.
Were there -- I'm sorry.
20
A.
But it's -- it was E-book reading software.
21
22
23
E-book reading and creation software.
Q.
So the E-books that you're referring to
were available on Web sites; right?
24
A.
That's my understanding.
25
Q.
In other words, they could only be read on
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Web sites; right?
2
A.
That's my understanding.
3
Q.
They could not be read anywhere except on
4
5
the Web; right?
A.
That's my understanding.
But, again, I'm
6
not an expert on every aspect of Family Systems'
7
software.
8
9
Q.
When a person modified the ibook, as Family
Systems used it, before January 2010, anyone
10
visiting that Web site and accessing that ibook
11
would see those modifications; right?
12
A.
I -- I don't have knowledge of that.
13
Q.
A person visiting such an ibook owned by
14
Family Systems or made available by Family Systems
15
could make changes to such ibooks; correct?
16
A.
Yes.
17
Q.
And it -- and it's that way in which Family
18
Systems referred to the ibook system as interactive;
19
right?
20
MS. CENDALI:
Objection.
21
THE WITNESS:
I don't know what Family
22
Systems meant by "interactive."
23
24
25
BY MR. CHATTORAJ:
Q.
When you reviewed their Web site and when
you reviewed their trademark filings, did you have
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any understanding of what they meant by
2
"interactive"?
3
A.
Part of the inter -- user modifiability was
4
part of the interactiveness.
5
people could make changes to the books.
6
haven't -- I never created a Family Systems ibook
7
and modified it or followed one to see the changes,
8
so I don't have personal knowledge of that.
I do recall that
Again, I
9
Q.
Do you know anyone who did do that?
10
A.
Not that I'm aware of, no.
11
Q.
So the person who was the content creator,
12
the person who downloaded the software that's made
13
available by Family Systems before January 2010,
14
could make changes to that content; right?
15
A.
I'm sorry.
16
Q.
That person who generated the content using
Could you repeat the question?
17
the ibook software that was then available on the
18
Web site, that person could then change the content
19
subsequently; right?
20
A.
Correct.
21
Q.
But other users could also change that
22
23
content when they visited; right?
A.
Again, I think -- I think that's true.
I
24
did not follow the Family Systems Web site or the
25
books on -- that were being hosted there to confirm
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A.
Not that I'm aware of.
2
Q.
After --
3
A.
I'm sorry.
It may be that there were -- in
4
some of the research that we did, we had that
5
information.
6
right now.
7
Q.
8
I just don't have that in my knowledge
Did you have it in your knowledge at that
time?
9
A.
I just don't recall.
10
Q.
Did Apple make any effort to identify any
11
customers of Family Systems after Apple acquired --
12
withdrawn.
13
After the execution of the acquisition
14
agreement, did Apple make any effort to identify
15
Family Systems' customers?
16
A.
Not that I'm aware of.
17
Q.
After the agreement was executed, did Apple
18
make any effort to identify Family Systems' users?
19
A.
Not that I'm aware of.
20
Q.
After the execution of the agreement, did
21
Apple have any intention of marketing to Family
22
Systems' customers?
23
A.
Apple's marketing was focused on the
24
general consumer, so I'm sure some of those
25
consumers would be Family Systems' customers.
TSG Reporting - Worldwide
877-702-9580
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Page 262
1
2
Q.
before.
On the next paragraph after what I read
This is the --
3
A.
We are in heavy use --
4
Q.
That's exactly right.
5
I'm referring to the
second sentence in that paragraph.
6
A.
Okay.
7
Q.
Is it your understanding today that Family
8
Systems has retained their existing "ibook" domain
9
name on their internal network?
10
11
12
A.
No.
That's -- my understanding is they've
transferred all their "iBook" domain names to Apple.
Q.
Is it your understanding that they did so
13
within the transition period called for by the
14
acquisition agreement?
15
16
A.
I believe so, but I -- I haven't checked
myself, but I believe that's true.
17
Q.
18
right?
19
A.
Yes.
20
Q.
Somebody employed by or acting on behalf of
21
But it's fair to say that somebody checked;
Apple; right?
22
A.
Yes.
23
Q.
Did you ever receive any reports that
24
Family Systems is violating the terms of the
25
agreement?
TSG Reporting - Worldwide
877-702-9580
CONTAINS HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY PORTIONS BOUND SEPARATELY
Page 263
1
A.
Not that I'm aware of.
2
Q.
The following paragraph reads, It was not
3
clear from talking to Brewster which of Family
4
Systems' ibooks -- sorry -- which of Family Systems'
5
ibook assets Apple are interested in.
6
multiple domain names and trademark registration, as
7
well as software technology and patents which
8
reference ibook systems.
9
There are
Do you see that?
10
A.
Yes.
11
Q.
To the best of your knowledge, was Apple
12
interested in acquiring Family Systems' software
13
technology?
14
A.
No.
15
Q.
Was Apple interested in acquiring Family
16
Systems' patents?
17
A.
No.
18
Q.
Was Apple interested in acquiring Family
19
20
21
22
23
Systems' patents which reference ibook systems?
A.
they reference -- I'm not -Q.
I -- I have -- my question is oriented
exclusively toward the words on this page.
24
25
What do you mean by -- in the patent claims
MS. CENDALI:
Then objection as to form.
Vague.
TSG Reporting - Worldwide
877-702-9580
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