Polaris IP, LLC v. Google Inc. et al

Filing 275

RESPONSE to 253 Claim Construction Brief by AOL, LLC., America Online, Inc., Google Inc., Yahoo!, Inc.. (Attachments: # 1 Affidavit of Todd Kennedy, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, part 1, # 7 Exhibit 5, part 2, # 8 Exhibit 5, part 3, # 9 Exhibit 5, part 4, # 10 Exhibit 6, # 11 Exhibit 7, # 12 Exhibit 8, part 1, # 13 Exhibit 8, part 2, # 14 Exhibit 9, # 15 Exhibit 10)(Perlson, David)

Polaris IP, LLC v. Google Inc. et al

Doc. 275 Att. 15

Dockets.Justia.com

Page 1

IN THE UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA CASE NO. CV 04- 9484 AHM (SHx)

PERFECT 10, INC., a California: VIDEOTAPED corporation, DEPOSITION OF :ROSANNA PICCOLO

VS.

GOOGLE, INC., a corporation; and DOES 1 through 100, inclusive,

Defendants. .

T R A N S C R I P T of the stenographic notes of LISA FORLANO, CCR, CRR, RMR, Certified LiveNote Reporter and Notary Public, taken at the offices of Quinn, Emanuel, Urquhart, Oliver & Hedges, LLP, 51 Madison Avenue, 22nd Floor, New York, New York, 10010, on Thursday, July 9, 2009, commencing at 9:15 a.m.

Job No.: 206682

VERITEXT CORPORATE SERVICES [phone]
3d32852e - Of57-4981-91d4 - 8dc9807609c6

Page 24
1

Q

Yeah.

Why don't you just read that

2 3

claim and let me know when you're done. A
Q

I'm done.
okay. Do you know what a

non-interactive electronic message is?
6

A Q

No. Does that phrase have any meaning to

7

8
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

you? A Electronic message, yes , e-mail.

Non-interactive, I really don't want to guess as to what I believe it is. I don't know.
Q A Q EZ Reader? A No. Okay. You don't know what that means?

Non-interactive electronic message, no. Do you recall who came up with the name

1,

Q

Have you ever been a consultant for --

let me start over and my apologies if this is something duplicative of what I already read. Have you ever been a consultant for Bright Response, the plaintiff in this case?
A No.

Q
them?
A

Have you ever received any money from

No.

VERITEXT CORPORATE SERVICES (800) 567-865$
3d32852e -Of57-4984-9ld4- 8dc98076O9c6

I
2

CERTIFICATION

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4

I,

LISA FORLANO, a Certified Realtime

Reporter, Certified Shorthand Reporter and Notary Public, do hereby certify that I reported the deposition in the above-captioned matter, that the said witness was duly sworn by me; that the foregoing is a true and correct transcript of the stenographic notes of testimony taken by me in the above-captioned matters. I further certify that I am not an attorney or counsel for any of the parties, not a relative or employee of any attorney or counsel connected with the action, nor financially interested in the action.

5

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7

s
9 10 11 12 13 14

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16 17 18 19 20 21 22 23 24 25

LISA FORLANO, CCR, CRR, RMR

DATED:

July 21, 2009

VERITEXT CORPORATE SERVICES (800) . 567-8658
302852e - OW-+1981-91 N-WG98076M6