I/P Engine, Inc. v. AOL, Inc. et al

Filing 334

Memorandum in Support re 333 MOTION in Limine Plaintiff I/P Engine, Inc.'s Second Motion in Limine to Preclude Non-Comparable License Agreements filed by I/P Engine, Inc.. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Proposed Order)(Sherwood, Jeffrey)

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Volume I

Pages 1 - 157

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Exhibits 1 - 20

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF VIRGINIA

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NORFOLK DIVISION

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I/P ENGINE, INC.,

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Plaintiff,

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Civil Action No.

Vs.

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2:11-cv-512

AOL, INC., et al.,

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Defendants.

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AUDIO/VISUAL DEPOSITION of LYCOS, INC.,

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by and through its designee MARK BLAIS

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Tuesday, July 31, 2012 at 9:00 a.m.

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Goulston & Storrs

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50 Rowes Wharf, 7th Floor

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Boston, Massachusetts

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------ Jacqueline P. Shields, RPR, CSR ------

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Job No. CS409539

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Page 147
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question?

Sorry.

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MS. O'BRIEN:

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for me, I don't know if I can.

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(Read back.)

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A.

No.

Would you mind rereading it

I have no reason to believe one way or

the other.
Q.

Do you have any reason to believe that

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Lycos wouldn't have licensed the patents in this

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agreement for $3.2 million in 2004?

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MS. ALBERT:
A.

Objection.

I have no reason.

Speculation.

What we would have done

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in 2004, I mean, like I said, a lot of this was

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internally driven.

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different company back then, larger in all respects,

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much bigger parent company, and just the overall

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business forces would have been different.

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largely driven by our lack of profitability at the

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time, our need for some cash, things like that.

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Circumstances being completely different, I have no

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idea what we would have done back then.

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Q.

We would have been a much

This was

And just to confirm, was Lycos profitable

in 2004?

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A.

No.

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Q.

Was Lycos profitable in 2005?

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