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 TransPerfect Legal Solutions 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? TransPerfect Legal Solutions 212-400-8845 - Depo@TransPerfect.com

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