WI-LAN Inc. v. Alcatel-Lucent USA Inc. et al

Filing 475

MOTION for Attorney Fees by Alcatel-Lucent USA Inc., Ericsson Inc., Exedea INC., HTC America, Inc., HTC Corporation, Sony Mobile Communications (USA) Inc., Sony Mobile Communications AB, Telefonaktiebolaget LM Ericsson. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Text of Proposed Order)(Sostek, Bruce)

EXHIBIT A

CONFIDENTIAL - ATTORNEYS' EYES ONLY

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF TEXAS
TYLER DIVISION
-----------------------------X
)
WI-LAN INC.,
)
)
Plaintiff,
)
)
Vs.
) Civil Action No.
) 6:10-CV-521-LED
ALCATEL-LUCENT USA INC.;
)
TELEFONAKTIEBOLAGET LM
)
ERICSSON; ERICSSON INC.;
)
SONY MOBILE COMMUNICATIONS
)
AB; SONY MOBILE
)
COMMUNICATIONS (USA) INC.;
)
INC.; HTC CORPORATION; HTC
)
AMERICA INC.; EXEDEA INC.,
)
)
Defendants.
)
-----------------------------X

CONFIDENTIAL - ATTORNEYS' EYES ONLY
DEPOSITION OF JOHN C. JAROSZ
Friday, July 5th, 2013, 9:05 a.m.

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Page 25

24
25

Q.

When did you come up with this

litigation expense approach, for lack of a

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09:28

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better way of describing it?

2

A.

This more specific approach, since

3

last Friday and the filing or the issuance of

4

the court's order in this matter.

5

Q.

6

that right?

7

A.

8

So I think Friday was June 29th; is

09:28

I don't have reason to dispute that.

That sounds right.

9

Q.

10

I want to make sure I get that.
MS. HUTTNER:

11

Count backwards from

09:29

July 4th yesterday.

12

MS. HEFFERNAN:

13

counting backwards, Connie.

14

A.

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I'm not good at

Or July 5th, today.

BY MS. HEFFERNAN:

16

Q.

Okay.

09:29
So Friday's date was June

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28th.

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order on June 28th and July -- the morning of

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July 3rd, you came up with this litigation

20

expense approach; is that fair?

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22

So sometime between the issuance of the

A.

Yes, this more specific approach to

figure out U.S. versus worldwide value.

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09:29

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.
24
25

Q.

So is it fair to say that the

presentation of your methodology has changed

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09:43

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somewhat but your methodology has remained the

2

same?

3

A.

Yes, that's generally true.

Some

4

inputs have changed, but the methodology is the

5

same.

09:43

6

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