Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Filing 1342

TRIAL BRIEF DEFENDANTS' OFFER OF PROOF REGARDING TIME LIMITATION FOR INVALIDITY TRIAL by Adobe Systems Incorporated, Amazon.com Inc., CDW Corporation, Google Inc., J.C. Penney Corporation, Inc., Staples, Inc., The Go Daddy Group, Inc., Yahoo! Inc., YouTube, LLC. (Attachments: # 1 DECLARATION OF JENNIFER HALTOM DOAN IN SUPPORT OF, # 2 DECLARATION OF ANDREW L. PERITO IN SUPPORT OF, # 3 Exhibit A, # 4 Exhibit B, # 5 Exhibit C, # 6 Exhibit D, # 7 Exhibit E, # 8 Exhibit F, # 9 Exhibit G, # 10 Exhibit H, # 11 Exhibit I, # 12 Exhibit J, # 13 Exhibit K, # 14 Exhibit L)(Doan, Jennifer)

EXHIBIT L

Case Clip(s) Detailed Report
Saturday, February 04, 2012, 9:54:31 AM

Radjev_Sunita

Rajdev, Sunita (Vol. 01) - 01/10/2012

1 CLIP (RUNNING 00:03:52.901)

Rajdev_Defendants
SR01

27 SEGMENTS (RUNNING 00:03:52.901)

1. PAGE 6:07 TO 6:09 (RUNNING 00:00:03.472)

07
08
09

Q
Will you please state your full name for
the record?
A
Sunita Rajdev.

2. PAGE 7:03 TO 7:05 (RUNNING 00:00:05.660)

03
04
05

Q
Dr. Rajdev, what is your position with the
University of California?
A
I'm a senior licensing officer.

3. PAGE 78:24 TO 79:04 (RUNNING 00:00:16.206)

24
25
00079:01
02
03
04

Q
Have you ever spoken to the technical
expert, David M. Martin, in this case?
A
Not the inventor?
Q
There is two David Martins: One is
David C. Martin and one is David M. Martin.
A
I have not spoken to David M. Martin.

4. PAGE 80:11 TO 80:17 (RUNNING 00:00:16.187)

11
12
13
14
15
16
17

Q
A

Have you read the '985 patent?
I have not read. I know what it covers,
but I have not read it.
Q
Same thing with respect to the '906
patent. Have you actually read that patent or do
you know what it covers?
A
I've looked at it.

5. PAGE 81:02 TO 81:04 (RUNNING 00:00:04.547)

02
03
04

Other than that, have you ever read the
'906 patent?
A
No.

6. PAGE 88:05 TO 88:20 (RUNNING 00:00:29.287)

05
06
07
08
09
10
11
12
13
14
15
16
17
18
19
20

Q
Do you know how many claims are included
in the '906 patent?
A
I do not.
Q
Okay.
Do you know how many claims are in the
'985 patent?
A
No, I do not.
Q
Do you know what technologies are covered
by the '985 patent?
A
It's the use of plug-ins.
Q
Okay.
And what -- what about with respect to the
use of plug-ins?
A
I do not know the details. It's the use
of specific Ajax and plug-in, and I do not know the
specific details.

7. PAGE 89:22 TO 89:23 (RUNNING 00:00:02.474)

22
23
CONFIDENTIAL

Q
Do you know how many claims are in the
'985 patent?
page 1

Case Clip(s) Detailed Report
Saturday, February 04, 2012, 9:54:31 AM

Radjev_Sunita
8. PAGE 89:25 TO 89:25 (RUNNING 00:00:01.792)

25

THE WITNESS:

I do not recall right now.

9. PAGE 130:15 TO 130:17 (RUNNING 00:00:04.906)

15
16
17

Do you know of any university or
institution that is teaching with the AnatLab
product?

10. PAGE 130:19 TO 130:19 (RUNNING 00:00:01.189)

19

THE WITNESS:

I do not know.

11. PAGE 140:01 TO 140:02 (RUNNING 00:00:11.296)

00140:01
02

Do you know of any product that Eolas
currently has on the market?

12. PAGE 140:04 TO 140:07 (RUNNING 00:00:02.545)

04
05
06
07

THE WITNESS:
BY MS. DOAN:
Q
Yes, ma'am.
A
No.

Actually on the market?

13. PAGE 156:04 TO 156:09 (RUNNING 00:00:22.516)

04
05
06
07
08
09

What date did Dr. Martin and Dr. Cheong
[sic] and Michael Doyle tell the University of
California that they first conceived of the
invention which later became the '906 patent?
A
I think it was sometime in 1994, but I
can't recall the exact date.

14. PAGE 175:05 TO 175:08 (RUNNING 00:00:15.806)

05
06
07
08

Q
What documents is the University aware of
that Pei Wei provided to Dr. Doyle prior to the
University of California applying for the '906
patent?

15. PAGE 175:10 TO 175:14 (RUNNING 00:00:04.270)

10
11
12
13
14

THE WITNESS: Prior to the University
applying?
BY MS. DOAN:
Q
Yes, ma'am.
A
I do not know.

16. PAGE 187:22 TO 187:25 (RUNNING 00:00:10.127)

22
23
24
25

Q
Do you know if the Viola browser or any
information about Pei Wei was sent to the -- the
patent -- patent office during the patent
prosecution of the '906 patent?

17. PAGE 188:02 TO 188:08 (RUNNING 00:00:15.270)

02
03
04
05
06
07
08

THE WITNESS: I do not know.
BY MS. DOAN:
Q
Have you ever seen any documents that the
University of California submitted to the patent
office during the patent prosecution of the '906
patent that would reflect disclosure of Pei Wei's
invention or the Viola browser?

18. PAGE 188:11 TO 188:11 (RUNNING 00:00:01.648)

11

CONFIDENTIAL

THE WITNESS:

I do not know.

page 2

Case Clip(s) Detailed Report
Saturday, February 04, 2012, 9:54:31 AM

Radjev_Sunita
19. PAGE 189:24 TO 190:01 (RUNNING 00:00:08.256)

24
25
00190:01

Q
And did the University of California
submit any documents with respect to the '906 patent
prosecution with respect to the Viola browser?

20. PAGE 190:03 TO 190:03 (RUNNING 00:00:01.632)

03

THE WITNESS:

I do not know.

21. PAGE 191:02 TO 191:06 (RUNNING 00:00:14.204)

02
03
04
05
06

Did the University of California ever tell
the United States Patent Office that Pei Wei claimed
to have invented the technology that Michael Doyle
is claiming is in the '906 patent during the patent
prosecution of the '906 patent?

22. PAGE 191:09 TO 191:14 (RUNNING 00:00:20.975)

09
10
11
12
13
14

THE WITNESS: I do not know.
BY MS. DOAN:
Q
Have the University of California Regents
ever conducted a review or analysis as to whether
Pei Wei invented the Viola browser before Michael
Doyle applied for the '906 patent?

23. PAGE 191:16 TO 191:16 (RUNNING 00:00:01.341)

16

THE WITNESS:

Not that I know of.

24. PAGE 210:02 TO 210:04 (RUNNING 00:00:05.498)

02
03
04

What steps did the University of
California engage in to look for prior art when it
applied for the '906 patent?

25. PAGE 210:07 TO 210:07 (RUNNING 00:00:01.380)

07

THE WITNESS:

I do not know.

26. PAGE 240:15 TO 240:18 (RUNNING 00:00:09.201)

15
16
17
18

Do you know who at the University of
California, separate and apart from its counsel, has
reviewed the prior art that's been produced by the
Defendants in this litigation?

27. PAGE 240:21 TO 240:21 (RUNNING 00:00:01.216)

21

THE WITNESS:

I do not know.

TOTAL: 1 CLIP FROM 1 DEPOSITION (RUNNING 00:03:52.901)

CONFIDENTIAL

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