J.T. Colby & Company, Inc. et al v. Apple, Inc.
Filing
135
DECLARATION of Claudia T. Bogdanos in Opposition re: 120 MOTION in Limine to Exclude any Testimony, Argument or Evidence Regarding the Expert Reports and Opinions of Susan Schwartz McDonald.. Document filed by Ipicturebooks LLC, J.Boyston & Company, J.T. Colby & Company, Inc., Publishers LLC. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I Part 1, # 10 Exhibit I Part 2, # 11 Exhibit J, # 12 Exhibit K, # 13 Exhibit L, # 14 Exhibit M, # 15 Exhibit N, # 16 Exhibit O, # 17 Exhibit P, # 18 Exhibit Q, # 19 Exhibit R)(Chattoraj, Partha)
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EXHIBIT O
CONFIDENTIAL - ATTORNEYS' EYES ONLY
Page 193
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
-----------------------------x
J.T. COLBY & COMPANY, INC.
d/b/a BRICK TOWER PRESS, J.
BOYLSTON & COMPANY, PUBLISHERS
LLC and IPICTUREBOOKS, LLC,
Plaintiff,
vs.
No. 11-cv-4060
APPLE, INC.,
Defendant.
-----------------------------x
CONFIDENTIAL
ATTORNEYS' EYES ONLY
VIDEOTAPED DEPOSITION OF
30(b)(6) JOHN T. COLBY, JR.
New York, New York
Wednesday, July 18, 2012
Reported by:
Jennifer Ocampo-Guzman, CRR, CLR
Ref: 7845
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212-400-8845 - Depo@TransPerfect.com
CONFIDENTIAL - ATTORNEYS' EYES ONLY
Page 194
1
Confidential-Attorneys' Eyes Only-Colby
2
3
MS. CENDALI:
So can I have my last
question read back, please.
4
(A portion of the record was read.)
5
A.
Is there some reason?
6
Q.
Yes.
7
A.
We had assembled the data in such a
What is it?
8
way and organized the backlist, like allocate
9
titles to e-platform versus print platform.
10
Q.
So I'm sorry, why would that make a
11
difference as to your decision to provide
12
more e-mail titles?
13
A.
We needed to exploit our title
14
list, and in 2010 opportunities arose for us
15
to do that.
16
Q.
17
18
19
And what do you mean by
opportunities arose for you to do that?
A.
Sales channels that developed in
2010 that didn't exist prior.
20
Q.
And what were those sales channels?
21
A.
Kindle.
22
Q.
Anything else?
23
A.
Apple 2 and Nook.
24
Q.
Do you sell any of your books using
25
Apple's iBooks app?
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212-400-8845 - Depo@TransPerfect.com
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