Case 1:07-cv-00605-JJF
Document 51
Filed 06/11/2008
Page 1 of 4
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ) ) ) ) ) ) ) ) ) )
AMERICAN PATENT DEVELOPMENT CORPORATION, LLC, Plaintiff, v. MOVIELINK, LLC, Defendant.
C.A. No. 07-605-JJF
NOTICE OF DEPOSITIONS PLEASE TAKE NOTICE that plaintiff American Patent Development Corporation, LLC, by counsel, pursuant to Rule 30(b)(6) of the Federal Rules of Civil Procedure, will take the deposition of defendant Movielink, LLC at the law offices of Reed Smith LLP, 3110 Fairview Park Drive, Suite 1400, Falls Church, Virginia 22042, as follows: Deponent's Name Bruce Anderson Ali Ozgun Movielink, LLC (by its designee) Date of Deposition June 25, 2008 June 26, 2008 June 27, 2008 Time 10:00 a.m. 10:00 a.m. 10:00 a.m.
The party who has been noticed to appear by its designee shall, pursuant to Rule 30(b)(6), designate one or more officers, directors, managing agents, or other persons who consent to testify on its behalf, regarding the matters set forth on Schedule A attached hereto. TAKE FURTHER NOTICE that pursuant to Rule 30(b)(2) of the Federal Rules of Civil Procedure, the defendant shall produce at the deposition all documents previously requested but not produced in this action.
Case 1:07-cv-00605-JJF
Document 51
Filed 06/11/2008
Page 2 of 4
AMERICAN PATENT DEVELOPMENT CORPORATION, LLC By Counsel
REED SMITH LLP
By:
/s/ Thad J. Bracegirdle Thad J. Bracegirdle (Del. No. 3691) 1201 Market Street Suite 1500 Wilmington, Delaware 19801 (302) 778-7500 (Telephone) (302) 778-7575 (Fax) E-mail: [email protected]
Mark W. Wasserman (admitted pro hac vice) Matthew R. Sheldon (admitted pro hac vice) Reed Smith LLP 3110 Fairview Park Drive Suite 1400 Falls Church, Virginia 22042 (703) 641-4200 (Telephone) (703) 641-4340 (Fax) E-mail: [email protected] [email protected] Counsel for Plaintiff, American Patent Development Corporation, LLC
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Case 1:07-cv-00605-JJF
Document 51
Filed 06/11/2008
Page 3 of 4
SCHEDULE A DEFINITIONS A. "System" or "Systems" have the same meaning as set forth in Plaintiff's First Set of Interrogatories. B. "License" and "license string" refer to the items so named in ML03479 and ML03482 previously produced therein. MATTERS FOR EXAMINATION 1. The architecture, structure, functionality, operation and design of Movielink's Systems including, without limitation, (i) how the video product is delivered to Movielink; (ii) how Movielink transmits the video product to the end user; (iii) the creation, content, transmission and storage of any license or license string; (iv) the operation of the Movielink Manager software and Movielink website; and (v) the determination of the authority to play and the playback of the transmitted video product. 2. Any documents produced by Movielink relating to the matters described in paragraph 1 above. 3. The revenue Movielink has received in connection with its Systems from January 1, 2001 to the present from rental of video content (Movielink's Video-on-Demand, or VOD, service), and the gross and net profit associated therewith. 4. Movielink's future revenue projections in connection with its Systems for rental video content (Movielink's Video-on-Demand, or VOD, service), and the gross and net profit associated therewith. 5. The extent and nature of any communications between APDC and Movielink prior to this action.
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Case 1:07-cv-00605-JJF
Document 51
Filed 06/11/2008
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6.
Any actions Movielink took between September 12, 2002 and the filing of this action to determine whether it was infringing the '402 patent.
7. 8.
Movielink's responses to APDC's interrogatories in this action. The nature, location, and extent of all documents and information reflecting, referring, or relating to the above matters, and the genuineness of such documents and/or information.
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Case 1:07-cv-00605-JJF
Document 51-2
Filed 06/11/2008
Page 1 of 1
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ) ) ) ) ) ) ) ) ) ) ) )
AMERICAN PATENT DEVELOPMENT CORPORATION, LLC, Plaintiff, v. MOVIELINK, LLC, Defendant.
Civil Action No. 07-605-JJF
CERTIFICATE OF SERVICE I hereby certify that on June 11, 2008, I electronically filed the foregoing Notice of Depositions with the Clerk of Court using CM/ECF which will send notification of such filing to the following counsel of record: Jeffrey L. Moyer, Esq. Richards, Layton & Finger, P.A. One Rodney Square Wilmington, Delaware 19899 Scott W. Breedlove, Esq. Vinson & Elkins LLP Trammel Crow Center 2001 Ross Avenue, Suite 3700 Dallas, Texas 75201 REED SMITH LLP By: /s/ Thad J. Bracegirdle Thad J. Bracegirdle (Del. No. 3691) 1201 Market Street, Suite 1500 Wilmington, Delaware 19801 (302) 778-7500 E-mail: [email protected]
WILLIB-56218.2