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

Filing 89

DECLARATION 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 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13, # 14 Exhibit 14, # 15 Exhibit 15, # 16 Exhibit 16, # 17 Exhibit 17, # 18 Exhibit 18, # 19 Exhibit 19, # 20 Exhibit 20, # 21 Exhibit 21, # 22 Exhibit 22, # 23 Exhibit 23, # 24 Exhibit 24, # 25 Exhibit 25, # 26 Exhibit 26, # 27 Exhibit 27, # 28 Exhibit 28, # 29 Exhibit 29, # 30 Exhibit 30, # 31 Exhibit 31, # 32 Exhibit 32, # 33 Exhibit 33, # 34 Exhibit 34, # 35 Exhibit 35, # 36 Exhibit 36, # 37 Exhibit 37, # 38 Exhibit 38, # 39 Exhibit 39, # 40 Exhibit 40, # 41 Exhibit 41, # 42 Exhibit 42, # 43 Exhibit 43, # 44 Exhibit 44, # 45 Exhibit 45, # 46 Exhibit 46, # 47 Exhibit 47, # 48 Exhibit 48, # 49 Exhibit 49, # 50 Exhibit 50, # 51 Exhibit 51, # 52 Exhibit 52, # 53 Exhibit 53, # 54 Exhibit 54, # 55 Exhibit 55, # 56 Exhibit 56, # 57 Exhibit 57, # 58 Exhibit 58, # 59 Exhibit 59, # 60 Exhibit 60, # 61 Exhibit 61, # 62 Exhibit 62, # 63 Exhibit 63, # 64 Exhibit 64, # 65 Exhibit 65, # 66 Exhibit 66, # 67 Exhibit 67, # 68 Exhibit 68, # 69 Exhibit 69, # 70 Exhibit 70, # 71 Exhibit 71, # 72 Exhibit 72, # 73 Exhibit 73, # 74 Exhibit 74, # 75 Exhibit 75, # 76 Exhibit 76, # 77 Exhibit 77, # 78 Exhibit 78, # 79 Exhibit 79, # 80 Exhibit 80, # 81 Exhibit 81, # 82 Exhibit 82, # 83 Exhibit 83, # 84 Exhibit 84, # 85 Exhibit 85, # 86 Exhibit 86, # 87 Exhibit 87, # 88 Exhibit 88, # 89 Exhibit 89, # 90 Exhibit 90)(Chattoraj, Partha)

EXHIBIT 55

From:
To:

CC:
Sent:
Subject:

Gundersen, Glenn
Thomas La Perle
Borden, Hal
1/29/2010 6:44:07 PM
IBOOKS publishing imprint-- John Colby

Attorney Client Privilege

From: Thomas La Perle [mailto:[e-mail]]
Sent: Friday, January 29, 2010 5:46 PM
To: Gundersen, Glenn
Subject: Fwd: Fr Johnn Colby R: ibooks + J. Boylston & Company, Publishers- iBooks

Attorney Client Privilege

Thomas R. La Perle
Director, Legal
Apple Inc.
1 Infinite Loop, MS: 3 TM
Cupertino, California 95014
Phone: [phone]
Fax:[phone]

Begin forwarded message:

From: Kevin Saul <[e-mail]>
Date: January 29, 2010 2:26:47 PM PST
To: Tom La Perle <[e-mail]>
Subject: Fwd: Fr Johnn Colby R: ibooks + J. Boylston & Company, Publishers
CONFIDENTIAL

APPLE-IBOOKS0024021

!Attorney Client Privi I
Begin forwarded message:

From: Steve Dowling <[e-mail]>
Date: January 29, 2010 2:21:14 PM PST
To: Kevin Saul <[e-mail]>

Subject: Fwd: Fr Johnn Colby R: ibooks + J. Boylston & Company,
Publishers

I Attorney Client Privill
Begin forwarded message:
From: [e-mail]
Date: January 29, 2010 2:17:35 PM PST
To: [e-mail]
Subject: Fr Johnn Colby R: ibooks + J. Boylston & Company, Publishers
408-974-1896

Hi Mr. Dowling,
I just left a message on your mac hire.
rm trying to find the right person to talk with at Apple. We are book publishers and have used the imprint "ibooks"
since the mid 1990s in the book trade. ibooks are distributed through National Book Network but had been
distributed by Simon & Schuster for many years. S&S relped build the brand in the book trade taking over from
Diamond Comics in the late 1990s.
We also license book product to Harper, S&S, Penguin, Macmillan, and Hachette among many others tmler our
Byron Preiss Visual Publications (BPVP) imprint Our ibooks titles are also in ebook format, sold through six
different ebook distributors under our ipicturebooks entity. We have several tlx>usand titles in the backlist
I was hoping you could pass this along to the right person at Apple in order to discuss our ibooks brand and ebook
titles for use on the new iPad.
Best wisres,
John
John T. Colby Jr.
Publisher
J. Boylston & Company, Publisrers
1230 Park Avenue, Ste. 8A
New Yolk, New York 10128
Tel: [phone] Fax: [phone]
BrickTowerPress.com
booknuuruscriptcom
cyberbookworks.com

CONFIDENTIAL

APPLE-I BOOKS0024022