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 D
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STATES UNITED DISTRICT COURT
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EASTERN DISTRICT OF VIRGINIA
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NORFOLK DIVISION
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I/P ENGINE, INC.,
Plaintiff,
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v.
:
: Civ. Action No.
: 2:11-cv-512
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AOL, INC., et al.,
:
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Defendants.
:
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CONFIDENTIAL - OUTSIDE COUNSELS' EYES ONLY
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Videotaped Deposition of NICHOLAS FOX
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San Francisco, California
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Wednesday, September 12, 2012
9:10 a.m.
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Job No.: 25943
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Pages: 1 - 237
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Reported by:
GINA V. CARBONE, CSR#8249, RPR, CCRR
CONFIDENTIAL VIDEOTAPED DEPOSITION OF NICHOLAS FOX
CONDUCTED ON WEDNESDAY, SEPTEMBER 12, 2012
161
MR. CIMINO:
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Q.
revenue Google has earned from its advertisers?
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MR. PERLSON:
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MR. CIMINO:
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Objection.
Q.
03:25:15
03:25:16
Form.
03:25:20
Since Smart Ads came on
03:25:21
line?
03:25:24
A.
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Do you know how much
I don't have that number off the top of my
head.
03:25:35
03:25:36
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Q.
It's in the billions?
03:25:37
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A.
Yes.
03:25:38
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Q.
Is it confidential that the statement that the
03:25:44
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historical click-through rate of the keyword of the
03:25:49
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matched ad is a factor that makes up quality score is
03:25:51
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technically inaccurate?
03:26:04
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MR. PERLSON:
Objection.
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THE WITNESS:
I would say that's confidential.
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MR. CIMINO:
Q.
Form.
And that is also
03:26:06
03:26:10
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confidential, I assume, that the statement that the
03:26:16
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historical click-through rate of the keyword in the
03:26:19
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matched ad on the Google domain making up quality
03:26:21
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score is inaccurate using our definition from
03:26:24
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Dictionary.com.
Correct?
03:26:27
It's free of error.
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A.
I would say that's also confidential.
03:26:32
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Q.
Has Google ever discussed the technical
03:26:41
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inaccuracy with any advertiser about historical
03:26:45
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click-through rate?
03:26:50
CONFIDENTIAL - OUTSIDE COUNSELS' EYES ONLY
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