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

Filing 145

REPLY AFFIRMATION of Partha P. Chattoraj in Support re: 87 MOTION for Partial Summary Judgment.. 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)(Chattoraj, Partha)

EXHIBIT G

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UNITED STATES DISTRICT COURT

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SOUTHERN DISTRICT OF NEW YORK

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J.T. COLBY & COMPANY, INC.

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d/b/a/ BRICK TOWER PRESS,

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J. BOYLSTON & COMPANY,

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PUBLISHERS, LLC and

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IPICTUREBOOKS, LLC,

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Plaintiffs

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V.

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Case No.:

APPLE, INC.,

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11-CIV4060

Defendant
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Deposition of Richard S. Goldhor, Ph.D.

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Tuesday, January 31, 2012

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9:58 a.m.

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Goodwin Procter, LLP

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53 State Street

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Boston, Massachusetts

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Reported by: Deborah Roth, RPR/CSR

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Job # 45894
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And then there were the people who

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ran the various estates that Brian had, and

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from time to time we would interact with them,

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and I don't remember their names either.

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Q.

I want to go back briefly to our

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discussion regarding whether a book such as

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Moby Dick that was already published would be

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available through Family Systems ibook.

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You mentioned that Brian Reynolds

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wanted to encourage people to use the software

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in different ways, but Family Systems would

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never offer a published book as an ibook

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product, such as Goldhor 10 and Goldhor 11?

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MS. RAY:

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foundation.

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A.

Lack of

to form.

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Objection.

Calls for speculation.

Objection

They certainly never did during the

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time when I was there, and from what I know of

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Brian's interests, it would have to be a very

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unusual circumstance.

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The reason -- one reason I believe

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that is that, as I say, Brian's interest was

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focused on communities of contributors.

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would have to be the sort of situation where a

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high school class was going to read Moby Dick
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So it

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and make comments, and the material was being

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put up on the web to be a foundation or a

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framework for those comments.

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Q.

experience?

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It would be a collaborative interactive

MS. RAY:

Objection to form, lack of

foundation and calls for speculation.

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A.

That's correct.

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Q.

Did you work on other projects for

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Family Systems outside of ibook?

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A.

Yes.

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Q.

What projects?

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A.

Well, and this may give you a good idea

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of the range of activities, at one point --

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and I forget the year -- but Brian married

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Betsy Johnson, a clothing designer.

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Q.

Yes.

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A.

And the wedding was in Yorkshire and he

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invited friends from all over the world, and

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he had his technical staff come over to set up

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a sound stage in a residence he had in

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Yorkshire for use before the wedding, and

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he created an ibook to record the wedding

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activities, and he had us prepare a

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demonstration of all of the various things
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