I/P Engine, Inc. v. AOL, Inc. et al
Filing
771
NOTICE by I/P Engine, Inc. Proffer of Evidence Related to Laches (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 PX 176, # 10 PX 408, # 11 PX 409, # 12 PX 410, # 13 PX 411, # 14 PX 412, # 15 PX 413, # 16 PX 414, # 17 PX 415, # 18 PX 416, # 19 PX 417 I, # 20 PX 417 II, # 21 PX 418, # 22 PX 419 I, # 23 PX 419 II, # 24 PX 421, # 25 DX 21, # 26 DX28, # 27 DX 255)(Sherwood, Jeffrey)
Exhibit C
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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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-------------------------x
I/P ENGINE, INC.,
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Plaintiff,
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v.
Civil Action No. 2:11-cv-512
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GOOGLE INC., et al.,
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Defendants.
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CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER
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Videotaped Deposition of DONALD M. KOSAK
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Washington, D.C.
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Thursday, May 31, 2012
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9:04 a.m.
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Reported by:
Amy E. Sikora, RPR, CRR, CSR-NY, CLR
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Job No. CS397174
Veritext Corporate Services
800-567-8658
973-410-4040
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1
Q.
Sure.
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A.
Google AdSense is what I had heard
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about.
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product names that are both advertising, I got
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them confused.
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The -- the two terms are -- you know, the
Q.
I'm sorry.
All right.
Well, with respect to
Google AdSense, you knew about it by 2005?
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A.
Right.
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Q.
And that was because you used it at
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Lycos?
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A.
Right, right.
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Q.
Did you have an understanding of how
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Google AdSense worked?
A.
I don't know how it worked internally.
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We knew enough to put the required tags on the
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page to call those ads, but what happens after
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that, I don't know.
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Q.
selected?
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MS. ALBERT:
Q.
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Did you have any idea how ads were
In Google AdSense?
MR. BILSKER:
Q.
Objection, vague.
Let me withdraw that.
Did you have any idea how ads were
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selected in Google AdSense in the 2005 time
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frame?
Veritext Corporate Services
800-567-8658
973-410-4040
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A.
No.
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Q.
Did you do anything to try to
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determine how ads were selected in the 2005 time
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frame in Google AdSense?
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A.
No.
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Q.
Is there a reason that you didn't do
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anything to try to identify how they were
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selected?
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A.
Yes.
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Q.
What was that reason?
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A.
There was no business reason for me to
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spend time on analy -- analyzing something that
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was, you know, wasn't a revenue stream for us.
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Why -- why would I analyze it?
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Q.
At that time in 2005, who owned the
two patents that are part of this case?
A.
In 2005, I'm not sure the ownership.
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I -- I believe it was probably Dom Communications
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Corporation.
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Q.
Not Lycos?
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A.
Well, Lycos was owned by Dom
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Communication Corporation at the time.
Hence, my
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uncertainty about the ownership, whether they
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were owned by a subdivision or the parent company
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or -- I don't know exactly who had the ownership
Veritext Corporate Services
800-567-8658
973-410-4040
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