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`Original Version Filed: May 18, 2023
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`Public Version Filed: May 25, 2023
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`Case 1:13-cv-00919-JLH Document 555 Filed 05/25/23 Page 2 of 2 PageID #: 56820
`Case 1:13-cv-00919-JLH Document 555 Filed 05/25/23 Page 2 of 2 PagelD #: 56820
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`knowingly violated a protective order. Prior to Apple’s motionin the above-referenced case, I was
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`never accused of having violated such an order.
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`Ds
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`During myredirect testimony on April 26, 2023, I was asked by counsel for Arendi,
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`“Do the differences between the real-world rates that were agreed to and the hypothetical rates
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`impact your assessment of whether your multiplier was conservative?” I understand that Apple
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`asserts that I improperly included in my response the amount of Arendi’s license agreement with
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`Apple (“Settlement Amount”) and my projection of the reasonable royalty owed in Arendi’s prior
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`lawsuit against Apple (“DamagesFigure”).
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`6.
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`In answering counsel’s question,
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`I was focused on providing a truthful and
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`complete answer. I did not have prior knowledge of counsel’s question and my response was not
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`rehearsed. My reference to the Settlement Amount and DamagesFigure while the courtroom was
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`unsealed was my best answerat the time to the question asked.
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`Se
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`Throughout the remainder of my extendedtestimony, I was careful not to reference
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`either figure until an attorney first moved to seal the courtroom. I did so pursuant to counsel’s
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`guidance before I began testifying. As far as I am aware,this testimony during spontaneousredirect
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`examination is the sole instance of a deviation from that practice.
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`I declare under penalty of perjury that the ferégoing
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`Executed on f4 /
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`(VN dedP
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`maeWS
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`Roy W
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