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

Filing 78

DECLARATION of Claudia T. Bogdanos in Support re: 77 MOTION to Preclude the Testimony of Defendant's Rebuttal Expert Witness Stephen M. Nowlis.. 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, # 10 Exhibit J, # 11 Exhibit K)(Chattoraj, Partha)

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EXHIBIT H CONFIDENTIAL Page 1 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, No. 11-cv-4060 vs. APPLE, INC., Defendant. ----------------------------- x CONFIDENTIAL VIDEOTAPED DEPOSITION OF 30(b)(6) JOHN T. COLBY, JR. New York, New York Wednesday, July 18, 2012 10:20 a.m. Reported by: Jennifer Ocampo-Guzman, CRR, CLR Ref: 7845 TransPerfect Legal Solutions 212-400-8845 - Depo@TransPerfect.com CONFIDENTIAL Page 313 1 2 3 Confidential-Colby Q. There's no reference on this list to the name of the imprint; isn't that true? 4 A. On this list, that's right. 5 Q. And that's because it's not 6 important to consumers to even tell them what 7 the imprint is, you just told them the name 8 of book and the author and the price, right? MR. CHATTORAJ: Objection. 9 10 11 12 The website is designed to help the A. authors market their own books. Q. And isn't it true that even if you 13 were to click on one of the codes next to 14 these titles, it still wouldn't tell you the 15 name of the imprint? MR. CHATTORAJ: Objection. 16 The way the site works right now, 17 A. 18 that's true. 19 Q. And so on your own website, 20 BrickTowerPress.com , there's only a reference 21 to a single iBooks and none of the books 22 listed in the book sellers' section even give 23 the imprint; isn't that right? MR. CHATTORAJ: Objection. 24 25 A. As the site works right now, yes, TransPerfect Legal Solutions - Depo@TransPerfect.com 212-400-8845

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