`
`Exhibit C
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Case 1:14-cv-02396-PGG-SN Document 191-3 Filed 11/01/19 Page 2 of 4
`9/6/2019
`Network-1 Technologies, v. Google LLC and Youtube LLC
`B. Halpern 30(b)(6)
`Confidential
`
`Page 1
`
` UNITED STATES DISTRICT COURT
` SOUTHERN DISTRICT OF NEW YORK
`
`--------------------------------------x
`NETWORK-1 TECHNOLOGIES, INC.,
` Plaintiff,
` vs.
`GOOGLE LLC and YOUTUBE, LLC,
` Defendants.
`--------------------------------------x
`
` C O N F I D E N T I A L
`
` September 6, 2019 at 9:36 a.m.
`
` Deposition of BENJAMIN HALPERN 30(b)(6),
`held at the offices of Amster Rothstein &
`Ebenstein, LLP,90 Park Avenue, New York,
`New York, before David Henry, a Certified
`Court Reporter and Notary Public of the
`State of New York.
`___________________________________________
` DIGITAL EVIDENCE GROUP
` 1730 M Street, NW, Suite 812
` Washington, D.C. 20036
` (202) 232-0646
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2019
`
`202-232-0646
`
`
`
`Case 1:14-cv-02396-PGG-SN Document 191-3 Filed 11/01/19 Page 3 of 4
`9/6/2019
`Network-1 Technologies, v. Google LLC and Youtube LLC
`B. Halpern 30(b)(6)
`Confidential
`
`Page 142
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`after closing, do you see that?
` A. Yes.
` Q. What does enforcement mean there?
` A. I assume it means the common
`definition of enforcement in the context of
`patents, that you are going to assert
`patents, or you know, if somebody is
`infringing your patents, you're going to
`pursue the rights under the patents.
` Q. So does enforcement mean
`litigation here?
` A. I mean, that's not a synonym for
`litigation, but it could lead to litigation,
`sure.
` Q. So it's broader than just
`litigation?
` A. I think so.
` Q. What else does it cover?
` A. Licensing and you know, and other
`things. The common term for enforcement in
`the context of patent law, it's -- yeah.
` Q. So the parties weren't
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2019
`
`202-232-0646
`
`
`
`Case 1:14-cv-02396-PGG-SN Document 191-3 Filed 11/01/19 Page 4 of 4
`9/6/2019
`Network-1 Technologies, v. Google LLC and Youtube LLC
`B. Halpern 30(b)(6)
`Confidential
`
`Page 143
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`specifically contemplating litigation at
`this time with respect to the Cox patent
`portfolio?
` A. Not that I am aware of, no.
` Q. Do you know if the parties
`negotiated this waiver of conflicts
`provision at all?
` A. Negotiated?
` Q. Yes.
` A. I don't know.
` Q. Do you know if the parties during
`these negotiations discussed the potential
`infringement of the Cox patent portfolio?
` A. I'm not sure.
` Q. Do you know if the parties
`discussed the potential validity or
`invalidity of any patents in the Cox
`portfolio during their negotiations?
` A. Well, they discussed prior art,
`so in that context I assume that they did,
`but the answer to the question is I don't
`know. I really don't know.
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2019
`
`202-232-0646
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
