J.T. Colby & Company, Inc. et al v. Apple, Inc.
Filing
174
DECLARATION of Todd Anten in Support re: 77 MOTION to Preclude the Testimony of Defendant's Rebuttal Expert Witness Stephen M. Nowlis., 73 MOTION to Preclude the Testimony of Defendant's Expert Witness E. Deborah Jay.. 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)(Chattoraj, Partha)
EXHIBIT E
Page 1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
-------------------------------------X
JT COLBY AND COMPANY, INC., D/B/A
BRICK TOWER PRESS, J. BOYLESTON AND
COMPANY PUBLISHERS, LLC, AND
IPICTUREBOOKS, LLC,
Plaintiffs,
-against-
Index No.
11-CV-4060(DLC)
APPLE, INC.,
Defendant.
-------------------------------------X
VIDEOTAPED DEPOSITION OF
SUSAN SCHWARTZ MCDONALD
New York, New York
December 12, 2012, 9:56 a.m.
Reported By:
Nicole Sesta
Ref: 8606
TransPerfect Legal Solutions
212-400-8845 - depo@transperfect.com
Page 75
1
S. Schwartz McDonald
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web surfing.
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much discussed in the marketing world.
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Q
But Apple, as I told you, is much,
And what did you do other than
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read the complaint to investigate plaintiffs'
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business before forming your expert opinions?
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MR. RASKOPF:
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the form of the question.
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A
Objection to
What I know -- most of what I know
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about plaintiffs' business, I think, has been
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articulated in the complaint, at least what is
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relevant.
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do for a living has to be credited with the
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mental agility to interpolate and extrapolate
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based on that fact pattern, that a company that
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is in the business of publishing iBooks, a
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company that has a significant digital library,
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a company who, in the end, whose survival, like
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all book publishers, is going to depend upon
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their presence in the digital space, that they
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and a mega brand called iBooks from Apple are
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going to collide in that space.
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Q
And I think someone who does what I
What -- did you do any
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investigation to test whether the allegations in
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plaintiffs' complaint were actually true?
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212-400-8845 - depo@transperfect.com
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