Free Notice to Take Deposition - District Court of Delaware - Delaware

Case 1:04-cv—O1373-KAJ Document 152 Filed O2/O2/2006 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
)
AMPEX CORPORATION, )
)
Plaintmf )
)
v. )
) C.A. N0. 04-1373 (KAJ)
EASTMAN KODAK COMPANY, )
ALTEK CORPORATION, and )
CHINON INDUSTRIES, INC., )
)
Defendants. )
)
NOTICE OF DEPOSITION OF DEFENDANT EASTMAN KODAK COMPANY
RE: IMAGE QUALITY AND USER INTERFACE SPECIFICATIONS
TO: All Parties and their Attorneys of Record:
PLEASE TAKE NOTICE: Pursuant to Federal Rule of Civil Procedure
30(b)(6), Ampex will take the deposition of Defendant Eastman Kodak Company
("Kodak"), commencing on February 27, 2006, at 9:00 a.m., at the Alliance Building,
183 East Main Street, Suite 1500, Rochester, NY 14604, or at such other time and place
agreed upon by the counsel to the parties.
Kodak shall designate one or more of its officers, directors or managing
agents,.or other persons with knowledge of the matters set forth in Schedule A of this
notice to appear and testify on its behalf at the deposition. The persons so designated
shall testify as to matters known or reasonably available to Kodak.

Case 1 :04-cv—O1373-KAJ Document 152 Filed O2/O2/2006 Page 2 of 4
This examination will be taken before a Notary Public or other person
authorized to administer oaths and will be recorded stenographieally and/or by video and
shall continue from day to day until completed.
You are invited to attend.
MORRIS NICHOLS ARSHT & TUNNELL LLP
/s/ Julia Heaney
Jack B. Blumenfeld (#1014)
Julie Heaney (#3052)
1201 North Market Street
P.O. Box 1347
Wilmington, DE 19899-1347
(302) 658-9200
[email protected]
[email protected]
Attorneys for Plaintw"Ampex Corporation
OF COUNSEL:
Jesse J. Jenner
Sasha G. Rao
Ropes & Gray LLP
1251 Avenue of the Americas
New York, New York 10020
(212) 596-9000
Norman H. Beamer
Gabrielle E. Higgins
Ropes & Gray LLP
525 University Avenue
Palo Alto, California 94301
(650) 617-4000
James E. Hopenfeld
Ropes & Gray LLP
One Metro Center
700 12th Street, NW
Washington, DC 20005
(202) 508-4600
February 2, 2006
2

Case 1 :04-cv—O1373-KAJ Document 152 Filed O2/O2/2006 Page 3 of 4
SCHEDULE A
INSTRUCTIONS AND DEFINITIONS
Ampex incorporates by reference the instructions and definitions set forth
in its First Set of Document Requests to Defendant Eastman Kodak Company (1-70) and
its Fourth Set of Document Requests to Defendant Eastman Kodak Company (92-136).
SUBJECT MATTER CATEGORIES
1. The image quality testing of the Kodak Devices, including without limitation the
results of all image quality tests performed on each of the Kodak Devices.
2. The use of "image experts" (see, e. g., Sasson 4/27/2005 Tr. at 39:7-16) during the
development or production of any of the Kodak Devices, including but not limited
to the identity any such "image expe1ts" and the evaluation perfonned by any
such "image experts."
3. User interface requests from the design group in Rochester to KDPC (see Domen
1/20/2006 Tr. at 18-20 ("Q: From whom do you receive user interface requests?
A: Mainly from design group in Rochester")), including without limitation the
source of such requests, how decisions are made with respect to such requests,
and any data or other information on which decisions to make such requests are
based.
4. The development of user interaction specifications (see, e. g., Domen Dep. Ex.
360, EKCNYI005093324-818) for each of the Kodak Devices, including without
limitation any data or other information on which requirements in such
specifications are based.
5. Kodak’s specification of the display time for Multi-up mode (see, ag., Domen
Dep. Ex. 360 at 273 (EKCNY1005093596) ("Full display of multi-up screen
showing all nine still pictures . . . should take no longer than 4.5 seconds."))
including, but not limited to, the specified display time for that Device in Multi-
up mode, why the speed with which the multi-up screen is displayed is important
(see, ag., Domen 1/20/2006 Tr. at 49:11-15), and the reason(s) Kodak specified
that display time including, but not limited to, any data, surveys, or market studies
Kodak used in determining a specified display time.

Case 1 :04-cv—O1373-KAJ Document 152 Filed O2/O2/2006 Page 4 of 4
CERTIFICATE OF SERVICE
I, Julia Heaney, hereby certify that on February 2, 2006, I caused to be
electronically filed the foregoing Notice of Deposition of Defendant Eastman Kodak
Company with the Clerk of the Court using CM/ECF, which will send notification of
such filing(s) to the following:
Paul M. Lukoff, Esquire
David E. Brand, Esquire
Prickett, Jones & Elliott, P.A.
and that I caused copies to be served upon the following in the manner indicated:
BY HAND
Paul M. Lukoff, Esquire
Prickett, Jones, Elliott,
1310 King Street
Wilmington, DE 19899
BY FEDERAL EXPRESS
Michael J. Summersgill, Esquire
Wilmer Cutler Pickering Hale and Dorr LLP
60 State Street
Boston, MA 02109
/s/ Julia Heaney
Julia Heaney (#3052)