SCOTT CHRISTOPHER SANDER
`
`12/78/2012
`
`Pa ge1
`
`UNITED STATES DISTR
`
`o
`
`T
`
`FOR THE VüESTERN DISTRICT OF PENNSYLVANTA
`
`---o0o---
`SIGHTSOUND TECHNOLOGIES I LLC'
`Plaintiff,
`
`VS.
`
`APPLE INC.,
`
`Defendant.
`
`CASE NO.:
`2: IIcv01292-DVüA
`
`,j
`
`3O(b) (6) VIDEOTAPED DEPOSITION OF
`
`SCOTT CHRISTOPHER SANDER
`
`Tuesday, December 18, 2012
`
`REPORTED BY: RACHEL FERR]ER, CSR 6948
`
`(r-448406)
`
`800-B 69-9732
`
`Merrill Corporation
`
`San Francisco
`www . merrí llcorp . com/ f aw
`
`Page 00001
`
`
`
`12/78/2012
`
`Pa ge1
`
`UNITED STATES DISTR
`
`o
`
`T
`
`FOR THE VüESTERN DISTRICT OF PENNSYLVANTA
`
`---o0o---
`SIGHTSOUND TECHNOLOGIES I LLC'
`Plaintiff,
`
`VS.
`
`APPLE INC.,
`
`Defendant.
`
`CASE NO.:
`2: IIcv01292-DVüA
`
`,j
`
`3O(b) (6) VIDEOTAPED DEPOSITION OF
`
`SCOTT CHRISTOPHER SANDER
`
`Tuesday, December 18, 2012
`
`REPORTED BY: RACHEL FERR]ER, CSR 6948
`
`(r-448406)
`
`800-B 69-9732
`
`Merrill Corporation
`
`San Francisco
`www . merrí llcorp . com/ f aw
`
`Page 00001
`
`
`
`Page 2
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`PAGE
`J, rll
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`PAGE
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`10
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`31
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`14
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`90
`
`94
`
`105
`
`SCOTT CHRISTOPHER SANDER
`
`L2/IB/20T2
`
`TNDEX OF EXAMTNATIONS
`
`EXAMTNAT]ON BY
`Mr. Batchelder
`
`EXHIBITS MARKED F'OR TDENTIFICATION
`
`NO.
`Exhibit
`
`I11
`
`DESCRIPTION
`Defendant Apple Inc. 's
`of 30(b) (6) Deposition
`Pfaintiff SlghtSound
`Technologies, LLC
`flB U.S. Patent No. 5,191,573
`Exhibit
`Exhibit 11 9 U. S. Patent No.
`Exhiblt 180 U.S. Patent No.
`5 , 966, 440
`Exhibit 181 Deposition Transcrlpt of
`Scott Sander dated 2/2L/07
`Exhibit 782 Deposition Transcript of
`Scott Sander dated 2/22/0I
`Reynolds to
`Exhiblt 183 E-Mall from John
`Scott Sander
`(Bates SST-3L541
`Exhibit 184 Screen shots from SightSound.com
`(Bates SST-2I831 27912)
`Exhibit 185 SightSound. com. safes
`(Bates STI-13695
`I3101)
`Exhibit 186 Arthur
`Hair Notes
`ssr-36864 36882)
`( Bates
`Exhib,it 187 Concept Plan for the Formation
`of Digital Sight/Sound Presented
`to Mr. Michael Milken
`(Bates SST-248L2 - 24BIB)
`
`Notice
`to
`
`5 , 6'15 ,'134
`
`31550)
`
`1 2 )J 4 5 6 1 B 9
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`10
`
`11
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`72
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`1')IJ
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`15
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`I6
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`T1
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`1B
`
`I9
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`20
`
`2L
`
`22
`.))
`
`LJ
`
`24
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`25
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`800-B 69-9132
`
`Merrill- Corporation
`
`San Francísco
`ww\^r . merri I Icorp . com/ f aw
`
`Page 00002
`
`
`
`Page 3
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`PAGE
`
`108
`
`128
`
`731
`
`14r
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`T4B
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`153
`
`756
`
`157
`
`r66
`
`716
`
`111
`
`181
`
`r97
`
`SCOTT CHRISTOPHER SANDER
`
`L2/rB/20L2
`
`EXHTBITS MARKED FOR IDENT]FICATTON
`
`NO.
`Exhíbit 1BB
`
`DESCRI PTION
`Business Plan for Digital
`SightSound, fnc.
`(Bates SST-25004 - 25\5I)
`Exhibit 189 Limlted Lj-cense to Henry Moore
`(Bates STI-13150 - 13159)
`Exhibit 190 Newco Offer
`(Bates SST-8119
`8181)
`Exhibit t9L Patent
`License Agreement
`ssT-7842 - 1B48)
`( Bates
`Exhibit Lez 3:"iä:;: Ë33i;:i"$"::r#Ei.oou*=
`(Bates SST-8856 - BB64)
`Exhibit 193 Two letters
`to Joel- Adams at
`Adams Capital Management
`dated IL/I0/95 and II/I1 /95
`(Bates SST-8865 - BB67 )
`Exhibit I94 Letter
`to Jeremy Pearce dated
`4/28/91
`ssr-24870)
`( Bates
`Exhibit 195 Board Prospectus
`(Bates SST-15891
`Exhibit 196 Template
`(Bates SST-BB6B
`I91 One-page document
`(Bates SST-8181)
`Exhibit 198 Document addressed to Ken Adams
`(Bates SST-8810 - BBL2)
`fnformation Memorandum,
`Goldman Sachs & Co., 3/9/98
`(Bates SST-8694 - B70B)
`Exhibit 200 Software License Agreement
`(Bates STl-L3I02 13116)
`
`dated B/15/91
`- 15915)
`
`BB69)
`
`Exhibit
`
`Exhibit 799
`
`1 2 3 4 5 6 1 B 9
`
`10
`
`11
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`I2
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`LJ
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`I4
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`15
`I6
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`I1
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`1B
`I9
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`20
`
`2I
`.)a
`LL
`
`23
`
`24
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`25
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`800-869-9732
`
`Merrill Corporatlon
`
`San Francisco
`www . merrif lcorp . com/1aw
`
`Page 00003
`
`
`
`SCOTT CHRISTOPHER SANDER
`
`T2/IB/2012
`
`EXHIBITS MARKED FOR IDENTIFICATION
`
`DESCRIPTION
`NO.
`Exhibit 20I Memo to Atlantic Records
`(Bates SST-24634 24631)
`Exhibit 202 SightSound Press
`(Bates STI-13148
`
`Release
`r3r49)
`
`trxhibit 203
`
`Memorandum
`å:ï:3t; /r+)'r"r^""t
`(Bates SST-842I - 8453)
`Exhibit 204 Minutes of Special Meet-ing of
`Directors of SightSound.com
`Incorporated
`---o0o---
`
`Page 4
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`PAGE
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`19s
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`202
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`204
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`23
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`Merrill Corporation
`
`San Francisco
`ww\iú. merrillcorp. com/f aw
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`Page 00004
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`
`
`SCOTT CHR]STOPHER SANDER
`
`72/rB/2012
`
`Page 5
`
`BE IT REMEMBERED that, pursuant to the faws
`governing the taking and use of depositions, on Tuesday,
`December 18, 2072, comlnencing at 9: 33 a.m. thereof , ât
`Ropes & Gray, 1900 University Avenue, 6th Floor, East
`Palo Al-to, California 94303, before me, RACHEL FERRIER,
`a Certified Shorthand Reporter, personally appeared
`SCOTT CHRISTOPHER SANDER, called as a witness by
`Defendant, who, being by me first duly sl/vorn, was
`thereupon examined as a witness in said action"
`APPEARANCES OF COUNSEL
`and the Witness:
`For the Pfaintiff
`ARNOLD & PORTER LLP
`BY: JAMES A. DiBOISE, Attorney at Law
`Three Embarcadero Center, lth Floor
`San Francísco, Californla 94III
`Telephone: 4I5. 41I.328I
`james.diboiseGaporter.com
`Emaif :
`For the Defendant:
`
`ROPES & GRAY
`BY: JAMES R. BATCHELDER, Attorney at Law
`1900 University Ave, 6th Floor
`East Palo Alto, California 94303
`TeJ-ephone: 650. 611 .4078
`james.batchelderGropesgray.com
`Emaif :
`
`ALSO PRESENT:
`
`PETER HIBDON, Videographer
`-- -o0o---
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`20
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`2L
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`22
`
`23
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`24
`)\
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`800-869-9732
`
`MerriIl Corporation
`
`San Francisco
`\ivww,merrillcorp " com/f aw
`
`Page 00005
`
`
`
`SCOTT CHRISTOPHER SANDER
`
`12/78/2072
`
`Page 6
`
`EAST PALO ALTO, CALIFORNIA
`TUESDAY, DECEMBER 18, 2OI2
`9:33 A.M.
`-o0o---
`
`PROCEEDINGS
`
`09 :34 z 28
`
`THE VIDEOGRAPHER: Good morning.
`Here begins Disc 1 in the deposition of Scott
`in the matter of
`Sander in the maLter regarding
`Sightsound Technologies, LLC, versus Apple fnc"
`Today's date is December 18th, 2012, and the
`time is 9:33 a.m.
`My name is Peter Hibdon, and the court reporter
`is Rachef Ferrier of Merrilf Court Reportlng.
`Counsel-, please identify yourselves and state
`whom you represent.
`MR. BATCHELDER: My name is James Batchelder
`from the l-aw firm of Ropes & Gray on behalf of
`defendant, Apple.
`MR. DiBOISE: James DiBoise.
`and the witness.
`THE VIDtrOGRAPHER: Thank you.
`s\^i ear in the witness.
`úüould the court reporter
`-o0o---
`
`I represent the
`
`plaintiff
`
`09:34 :39
`
`09:34 :53
`
`09:35:02
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`24
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`800-B 69-9132
`
`MerrilJ- Corporation
`
`San Francrsco
`www. merr j-llcorp. com/l-aw
`
`Page 00006
`
`
`
`SCOTT CHRISTOPHER SANDER
`
`72/78/2012
`
`Page 1
`
`SCOTT CHRISTOPHER SANDER
`
`cal-led as a witness, having been
`sworn, was examined and testified
`---o0o---
`
`first duly
`as follows:
`
`09:.21:22
`
`EXAMINATION
`
`BY MR. BATCHELDER:
`A Would you please state your fuII name for the
`record
`A Scott Christopher Sander.
`a And
`what is your home address?
`A
`Valley View Road.
`851
`a What
`is your business address?
`A
`South Craig Street, Pittsburgh,
`311
`Pennsylvania.
`a Mr.
`there's anything that I say or
`Sanders , íf
`ask you today that confuses you
`in any !ùay, will you
`please say so?
`A
`I will.
`O Thank you.
`to use in this deposition the word
`I'm likely
`"communicate" or various forms of that word,
`f just want to
`"communicatì-ng, " eLc.
`"communication, "
`outset by -- that by those terms, I'm
`be clear at the
`to communications in their broadest sense,
`referring
`
`09:35:17
`
`09:35 .21
`
`09:35:35
`
`09:35: 53
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`1B
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`79
`
`20
`2I
`aaLL
`
`23
`
`24
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`25
`
`800-869-9132
`
`MerriIl Corporation
`
`San Francisco
`ww\^/ . merr i I 1 corp . com/ law
`
`Page 00007
`
`
`
`SCOTT CHRISTOPHER SANDER
`
`12/rB/2012
`
`Page B
`
`whether oral, wrítten, eì-ectronic, or otherwise.
`Does that make sense to you?
`I understand.
`A
`O Also, I understand there have been several
`that used the name or word "SightSound, " and I
`entitles
`I intend a question to be
`want to be cfear that if
`then I will
`directed to a particular SightSound entity,
`cafl that out in the question, but, otherwise, f'll
`use
`the term "SightSound" to refer to any and all SiqhtSound
`entities.
`
`Does that make sense to you?
`I understand.
`A
`and if your ansv/er to any
`O Okay. And
`to a given SightSound entity,
`question is particular
`would you please try to specify that in your answer so
`vüe have a clear record?
`A Yes.
`MR. BATCHELDER: Thank you.
`(Exhibit 178 was marked for identification
`the Court Reporter. )
`MR. BATCHELDER: I've had marked as Exhibits 2
`through 4 in this deposition the patents-in-suit
`in this
`oh, I'm sorry.
`matter
`THE WITNESS: Yeah.
`MR. BATCHELDER: Yeah, TJB, 7'19, and 180. So
`
`by
`
`09:36:04
`
`O9 :,36:24
`
`09:36:34
`
`09:36:38
`
`09:36:59
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`19
`
`20
`2I
`')a
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`23
`
`24
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`.ELJ
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`800-869-9132
`
`Merrill Corporation
`
`San Francisco
`vvww . merril- l- corp . com/ law
`
`Page 00008
`
`
`
`09:31 :,25
`
`09:37:57
`
`09:38:03
`
`09:38: 17
`
`09 :38 :24
`
`SCOTT CHRISTOPHER SANDER
`
`12/LB/2072
`
`Page 9
`
`Il B is Patent No. 5 ,I9I ,5'13 .
`have that before you?
`Do you
`
`O A O
`
`Yes.
`Okay. And
`MR. DiBOTSE: Can you hold on a second. We're
`not scrolling.
`Thank you.
`BY MR. BATCHELDER:
`a So to the extent \^/e need to refer to that
`patent during the course of the deposition, would you
`I refer to it as the "'573 patent"?
`understand if
`A Yes.
`(Exhibit
`I19 was marked for identification
`the Court Reporter. )
`And we have also
`MR. BATCHELDER: All right.
`marked, âS Exhibit 119, Patent No. 5,6'15,134.
`A Do you have that before you?
`A Yes.
`O And can we refer
`A Yes.
`(Exhibit 180 was marked for identification
`the Court Reporter. )
`MR. BATCHELDER: And we have marked, âs
`Exhibit 180, Patent No. 5,966,440.
`O Do you have that before you?
`A Yes.
`
`by
`
`by
`
`to that as the tttJ34 patent"?
`
`1 2 3 4 5 6 1 B o
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`20
`2I
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`a')
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`Merrill Corporation
`
`San Francisco
`www . merri I lcorp . com/-Iaw
`
`Page 00009
`
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`
`SCOTT CHR]STOPHER SANDER
`
`12/LB/2012
`
`Page 10
`
`And can we refer to that as the '440 patent?
`Yes.
`can we refer to those three
`And, colfectively,
`as "the patents-in-suit"?
`Yes.
`(Exhibit L71 was marked for identification
`the Court Reporter. )
`MR. BATCHELDER: I al-so had marked, as
`I1'7, Defendant Apple fnc.'s Notice of 30 (b) (6)
`Exhibit
`SightSound Technologies, LLC.
`Deposition to Plaintiff
`a Do you have that before you?
`A Yes"
`O Have you seen that document before?
`I don't know.
`I don't
`A
`famifiar
`to you?
`fs it
`a
`A No.
`f could ask you, within
`that RuIe 30(b) (6)
`If
`A
`IJ'1, to turn to
`Deposition Notlce that is Exhibit
`Schedule A, which lays out a set of 32 topics.
`Have you seen this
`list of topics before?
`I don't believe I have.
`A
`O Do you understand that you have been
`today orr SightSound's behalf as to
`to testify
`these topics?
`A Yes.
`
`O A a
`
`patents
`
`A
`
`by
`
`des ignated
`any of
`
`09:38:33
`
`09:38:48
`
`09:39:01
`
`09:39:40
`
`09:39:58
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`20
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`ZI
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`1a
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`a)LJ
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`24
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`t5
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`800-869-9132
`
`Merril-l Corporation
`
`San Franci,sco
`w\,vw. merrif lcorp. com/1aw
`
`Page 00010
`
`
`
`SCOTT CHRISTOPHER SANDER
`
`T2/LB/20L2
`
`Page 11
`
`[ühich ones ?
`a
`'7, B, and 72.
`J, B, and 12.
`A
`O As between you and Mr. Hair, who is more
`knowledgeable about Topíc 1?
`MR. DiBOISE: Objection.
`THE IdITNESS : Yeah, I don ' t know. I
`I couldn't specuJ-ate.
`couldn't
`BY MR. BATCHELDER:
`O So it might be you; it might be him?
`A Perhaps.
`a As to Topic B, who is more knowledgeable,
`or Mr. Hair?
`MR. DiBOfSE: Objection.
`THE WITNESS: I -- f can't
`determine.
`BY MR. BATCHELDER:
`Might be you; might be him?
`
`I canrt
`
`O A O
`
`Yes.
`As to Topic 12, who is more knowledgeable, yoü
`or Mr. Hair?
`MR. DiBOISE:
`
`THE WITNESS:
`
`Obj ection.
`Yeah, f don't know.
`
`1 z 3 4 5 6 1 B 9
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`)')
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`25
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`O9: 40 :,34
`
`09:40:45
`
`you
`
`09:40:55
`
`09:41:01
`
`O9:47:,04
`
`BY MR. BATCHELDER:
`Might be you,' might be him?
`
`Yes.
`
`O A
`
`800-B 69-9132
`
`Merrill Corporation
`
`San Francisco
`w\^/w . merri I 1 corp . com/ l-aw
`
`Page 00011
`
`
`
`SCOTT CHRISTOPHER SANDER
`
`12/LB/2012
`
`Page L2
`
`O To prepare to
`behalf on Topics J, B,
`counsel ?
`
`Ã
`
`Vac
`
`testify
`and 12,
`
`today on SightSound' s
`did you
`meeL with
`
`O Did counsel provide you with any information in
`those meetings that refreshed your recolfection
`regarding any information responsive to those topics?
`MR. D1BOISE: Objection.
`THE WITNESS: No.
`I -- no.
`BY MR. BATCHELDER:
`O Aside from meeting with counsel, what did you
`do to prepare t.o testify on SightSound's behalf today
`regarding Topic 1?
`to prepare.
`A
`I did nothing extraordinary
`O Whether or not it was extraordinary, did you do
`anythlng?
`A No.
`O Aside from meeting with counsel, what did you
`or excuse me.
`do to prepare today to testify
`Aside from meetinq with counsef, what did you
`do to prepare to testify
`today on SightSound's behaff
`regarding Topic B?
`A Nothing.
`A Aside from meeting with counsel, what did you
`today on SiqhtSound's behalf
`do to prepare to testify
`
`09 z 41:.20
`
`09: 4I: 39
`
`09:41:51
`
`09: 42:,02
`
`09: 42:75
`
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`10
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`11
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`72
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`15
`I6
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`1B
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`79
`
`20
`
`21,
`))
`
`1_3
`
`24
`
`atrLJ
`
`800-B 69-9]-32
`
`Merrill Corporation
`
`San Francisco
`www . merril lcorp . com/law
`
`Page 00012
`
`
`
`09: 42:29
`
`09: 42:52
`
`09:43:00
`
`09,. 43:34
`
`09:43:53
`
`SCOTT CHR]STOPHER SANDER
`
`12/78/2012
`
`Page 13
`
`regarding Topic 72?
`A Nothing.
`Q How long did you meet with counsel to prepare
`today on SightSound's behalf regarding
`to testlfy
`Topic 'l , B, and 72?
`A Couple of hours.
`Q Have you read any depositlons that have been
`taken in this matter?
`A Tn this matter? No.
`O No?
`Have you read any depositions taken in any
`other matter?
`
`Yes.
`
`Which ones?
`own, in the matter of N2K.
`BATCHELDER: Vùhy don't we go ahead and mark
`order, please.
`you mark ít, wouJ-d you call out the number
`
`My
`
`MR.
`in
`
`Vühen
`
`THE REPORTER:
`
`181 .
`
`MR
`
`MR
`
`BATCHELDER:
`D1BOISE: B1?
`
`Thank
`
`you.
`
`THE REPORTER: 181.
`(Exhibits 181 and IB2 \,vere marked for
`identification by the Court Reporter.)
`
`A
`
`a A
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`that next
`
`for me.
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`SCOTT CHRTSTOPHER SANDER
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`T2/IB/2012
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`Page 14
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`09: 44: 12
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`O9:44:.22
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`09 : 44 :34
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`09: 44 : 48
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`O9:44:56
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`had marked, as
`of your deposition in
`
`MR. BATCHELDER: So I've
`Exhibits 181 and IB2, two volumes
`litigation.
`the N2K
`Are these the transcripts you were just
`to?
`Yes, I befieve so.
`
`a
`re ferring
`
`A
`
`Okay.
`
`0 A O A O A 0
`
`Yes.
`And you have read both of these transcripts?
`11 years ago.
`Have you read them since?
`No.
`I scanned them.
`When did you scan them?
`A Yesterday.
`O Other than scanning them yesterday and reading
`them 11 years ago, have you read or scanned these
`transcripts?
`A No.
`O Are you aware of any inaccuracies in your
`in Exhibits 181 and IB2?
`testimony in
`MR. DiBOTSE: Objection.
`THE WITNESS: I don't know.
`BY MR. BATCHELDER:
`O Well, the question is whether, âS you sit here,
`you are aware?
`
`1 az
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`- 3 4 5 6 1 B 9
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`wwv/. merril lcorp . com/ law
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`
`
`SCOTT CHRTSTOPHER SANDER
`
`72 / rB /2072
`
`Page 15
`
`here today, âfr f aware of inaccuracies
`I read 11 years ago? No.
`I mean, I
`
`A AsIsit
`of something that
`don't know.
`MR. DiBOISE: So now I'm objecting to your
`questions.
`Waít for a question.
`BY MR. BATCHELDER:
`A So we have a clear record, the question is
`to Exhibits 181 and 782, as you sit here today, are
`aware of any inaccuracies in the testimony provided
`those two exhibits?
`MR. DiBOISE: Objection.
`THE WITNESS: f don't know.
`
`09:45:15
`
`f1>
`
`you
`in
`
`09:. 45 :25
`
`are
`
`BY MR. BATCHELDER:
`a WelI, ei't-her you are or you're not
`either you are or you are not al/vare of
`you
`inaccuracies.
`Are you or are you not?
`MR. DiBOISE: Objection.
`it's
`THE I^IITNESS: I wouldn't know if
`an
`I don't think f understand the questlon.
`inaccuracy
`Are you saying is everything in here accurate?
`I don'
`
`t
`
`09: 45: 4I
`
`09: 45: 49
`
`know.
`
`BY MR. BATCHELDER:
`O The question is: Are you aware of anything in
`
`09:.46:.06
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`Merrill Corporation
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`San Francisco
`ví\^/w . merri I I corp . com/ law
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`
`
`SCOTT CHR]STOPHER SANDER
`
`12 / 78 /20L2
`
`Page L6
`
`to that, âs you
`782 that you testified
`Exhibit 181 and
`believe is inaccurate?
`sit here today,
`you
`Obj ection.
`MR. DÍBOISE:
`I don't know.
`
`THE WITNESS:
`
`BY
`
`MR. BATCHELDER:
`O Vrlhy don't you
`MR. DiBOISE:
`
`THE VüITNESS:
`
`know?
`Obj ection.
`It was 11 years ago
`
`BY
`
`MR. BATCHELDER:
`O Vlhen you scanned them recently, did you notice
`any inaccuracies?
`MR. DiBOISE: Objection.
`THE WITNESS: I don't
`
`I don't think so.
`
`BY MR. BATCHELDER:
`O Other than Exhibits 181 and IB2, have you read
`any other deposítions?
`A No.
`A Your deposltion v/as taken earJ-ier in this case.
`Have you read over that transcript?
`A No, I have not "
`O Have you read any of the testímony of Mr. Hair?
`A No.
`O Mr. LePore?
`A No.
`A How much time have
`
`have you taken
`
`strike
`
`O9 : 4 6:22
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`09:.46:.44
`
`09|46|51
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`09 : 41 :1-6
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`Page 00016
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`
`
`SCOTT CHRISTOPHER SANDER
`
`72/rB/2072
`
`Page I1
`
`that, please.
`
`time have you spent reading the
`
`How much
`patent s-in-suit ?
`the time necessary
`to review them
`A
`I suppose
`and
`you know,
`when they issued.
`back in 1993 and 'J
`your best estimate of how much
`Can you give me
`
`O
`tíme that
`
`taken
`
`A
`
`O
`
`wds I
`I don't recall
`
`how much time it woufd have
`
`Can you give
`MR. DiBOISE:
`
`THE WITNESS:
`
`me an estimate?
`Obj ection.
`I don't
`
`I don't recalf"
`
`BY MR. BATCHELDER:
`a Have you spent
`patent s-in-suit ?
`MR. D1BOISE:
`
`THE WITNESS:
`
`BY MR. BATCHELDER:
`A Have you spent
`patent s- in-suit ?
`MR. D1BOISE:
`
`THE VüITNESS:
`
`more than 10 hours reading the
`
`Obj ect ion .
`I -- f don't think so.
`
`more than five hours reading the
`
`Obj ection.
`I don't know.
`
`BY MR. BATCHELDER
`a Have you ever read any of the prosecution
`for any of the patents-in-suit?
`hlstories
`
`09:48:09
`
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`www . merrif f corp . com/law
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`09:49:33
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`09: 49: 47
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`09:50:00
`
`09 :50 :26
`
`SCOTT CHRTSTOPHER SANDER
`
`72/rB/2012
`
`Paqe 18
`
`f don't
`
`what do you mean by "prosecution
`
`A
`history" ?
`
`a
`Patent
`
`The back-and-forth between appllcant and the
`connection with securing a patent.
`in
`Office
`believe I
`I don't
`have.
`any portion of the
`never read
`You t ve
`history of any
`of the patents-in-suit?
`prosecution
`I may have,
`that was
`but I real-l-y don't
`AI
`of focus.
`not my area
`you sit here today, you don't remember doing
`OAs
`
`A O
`
`so?
`
`I do not.
`A
`Is Arthur Hair your best friend?
`O
`A Yes.
`O How long has that been true?
`today, so someone could do
`I'd say 791 6 until
`A
`the math.
`O And
`A
`16.
`he's been your best friend
`A So he's your
`you were L6 years old?
`A Yes, that's correct.
`0 Where are you currently employed?
`A Pense Productions and SightSound Technologies,
`
`and how ofd were you in 1916?
`
`sfnce
`
`LLC.
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`
`
`SCOTT CHRISTOPHER SANDER
`
`12/IB/20L2
`
`Page L9
`
`A Has your employment status changed in any way
`since you were last deposed in this matter?
`I don't befíeve so.
`A
`same responsibilities?
`A Same titfe,
`A Yes.
`O What are your current sources of income?
`A SightSound Technologies, LLC, and Pense
`Productions.
`O Anything else?
`A No.
`O And what is your current salary from Sightsound
`Technologies, LLC?
`I -- I don't receive a salary, per
`A
`there is a consulting arrangement that
`
`I have
`se "
`provides me
`
`a
`
`r^^
`^
`d ree.
`
`O
`
`A
`
`VJhat is that fee?
`It's approximately 13
`
`I think it's $13,500 a
`
`ft's my
`
`month.
`A And do you receive a salary from Pense
`Productions ?
`It depends.
`really.
`A Not
`not
`entrepreneur, so I --
`company, so I'm an
`myself; sometimes I
`don't, depending on
`business.
`with the
`happening
`And how much do you anticipate Pense
`
`r pay
`sometimes
`what's
`
`what
`
`a
`
`09:50:37
`
`09:50:51
`
`09:51:13
`
`09:51:33
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`09 :5I: 41
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`20
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`Merrill Corporation
`
`San Francisco
`www . merri llcorp . com/law
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`Page 00019
`
`
`
`SCOTT CHRISTOPHER SANDER
`
`72/78/2072
`
`Page 20
`
`Productions will have paid you for 2072 by early 2073?
`A For calendar year 2012?
`o Yes.
`I suppose around 200
`around $200,000.
`A
`A How many employees does Pense Productions have?
`i-t's variable because it's a motion
`A
`It
`picture production company, so it expands and con-
`contracts based on whether we are doing a project.
`A How many does it have today?
`A Five.
`in 2012, have you received
`O Do you receive
`any consulting from any entities other than Pense or
`SightSound?
`A No.
`O What is your current equity stake in
`SightSound?
`Ilr7el1, I have
`A
`MR. D1BOISE: Objection.
`THE WITNESS: Could you clarify?
`The
`I own a small portion of SightSound
`Sightsound
`Technol-ogies Holdings, LLC, which owns one half of
`SightSound Technologies, LLC.
`BY MR. BATCHELDER:
`A And what is your stake in SightSound Holdíngs?
`A Approxlmately three and a half percent.
`
`09 :52:22
`
`09 :,52:35
`
`09:52:55
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`09:53:39
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`Merrifl Corporation
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`San Francisco
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`Page 00020
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`
`
`SCOTT CHRISTOPHER SANDER
`
`T2/IB/20T2
`
`Page 2I
`
`O And do you have an ownership stake ín any other
`SightSound entity?
`A No.
`O Do you have any outstanding loans to any
`SightSound entity?
`I don't believe I do. Well, I stand corrected.
`A
`I glress
`Monthly travel expenses incurred, or briefly.
`one coufd express it as a debt that the company ol,^/es me'
`so like
`
`MR. DiBOISE: I think you meant the other way
`around. Have you loaned SightSound any money?
`THE WITNESS: Have I foaned SightSound any
`
`money?
`
`09:54:03
`
`09 :54 :22
`
`MR. BATCHELDER: That's what I meant.
`
`THE WTTNESS: No.
`
`09 :54 :,32
`
`BY MR. BATCHELDER:
`O Have you at any time loaned SightSound money?
`f canrt recall.
`A
`to having a
`O And when you referred earlier
`three-and*a-ha1f-percent stake, is that your personal
`stake or the stake of some trust or a combination?
`A My personal stake.
`a Okay. And is there a
`Sander name?
`
`a trust
`
`that bears the
`
`09:54:39
`
`À
`
`Vac
`
`09:54 :53
`
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`1B
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`20
`2I
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`24
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`
`Merrilf Corporation
`
`San Francisco
`\ivr^r\,v . merri I lcorp . com/ I aw
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`Page 00021
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`
`
`SCOTT CHRISTOPHER SANDER
`
`12/rB/2072
`
`Page 22
`
`O And does that trust have a separate stake in
`some SightSound entity?
`It does.
`A
`lrJhat's the name of that trust?
`O
`A Sander Chifdren's Trust.
`O And what stake does Sander Children's Trust
`have in a Sightsound entity?
`A About 7/10ths of a percent.
`O And in which entity? SightSound Holdings?
`A Yes.
`O Okay. So aside from your
`three-and-a-half-percent stake and the
`Sightsound Children's Trust, is there
`any SightSound entity with which you
`affi Iiated?
`A Yes.
`O Vühat is that?
`A Pense Productlons.
`A And could you explain that connection?
`A Pense Productions owns approximately a little
`than 2 percent of Holdings.
`O And do you own Pense?
`A A portion of it.
`O What portion?
`A Approxímately 60 percent.
`
`more
`
`7/1Oths stake of
`any other stake in
`are somehow
`
`09:55:00
`
`09:55:20
`
`09:55:34
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`09:.55: 42
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`09:56:03
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`1B
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`I9
`)n
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`2I
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`22
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`23
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`24
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`25
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`
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`
`San Francisco
`r/,/ww . merrill corp . com/ l-aw
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`SCOTT CHRISTOPHER SANDER
`
`12/IB/2012
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`Page 23
`
`09:56:26
`
`09:51 :,02
`
`09:57:18
`
`09:57:35
`
`09251:56
`
`O How much of your own money have you invested Ín
`Siqhtsound over time?
`A Of my own money?
`O Yes.
`I invested my time
`I was not a cash investor.
`A
`T think it did
`that's not
`wel-l, that
`and effort
`vary, the formation of the very first entity,
`the
`T wrote a check of some kind, but
`predecessor entity.
`my investment was sweat equity, âs what they caII it.
`O What was that check for?
`I can't recall as I sit here today.
`A
`perhaps, 500 bucks.
`O And did that money get paid back to you?
`A No.
`O But
`equity, but
`A Thank you.
`in terms of money contribution, other than
`A
`that $500, yoü never provided any money to SightSound as
`an investment?
`A As an investment of cash, Do.
`a For a given dolfar awarded to SightSound in
`how much would go to
`litigation,
`you ?
`MR. D1BOISE: Objection.
`THE llùf TNESS: As I sit here noh¡, I couldn't
`
`I understand your point about sweat
`
`It was,
`
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`Merrilf Corporation
`
`San Francisco
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`Page 00023
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`
`
`SCOTT CHRISTOPHER SANDER
`
`12/rB/201,2
`
`Page 24
`
`are liabífities
`people that stand
`
`cal-culate it precisely because there
`that the company has, etc., and other
`in a preferential position.
`BY MR. BATCHELDER:
`O Can you even estimate it?
`A Yes.
`O Would yoü, please.
`A The percentages I just expressed to You, if you
`summed them up, and then that woufd represent less than
`half of what would be distributed, as you put it,
`for a
`given dollar, and it depends greatly on the size of
`transaction
`of the actual award or whatever financial
`those ratios move as
`woufd take place, so it moved
`the numbers increase or decrease.
`O You began your answer by saying that the
`percentages that you just expressed, if
`I summed them
`up, they woufd represent less than half of what would be
`distributed.
`Is that what you meant?
`A No. Allow me to clarify.
`Those percentages
`ownership in one half
`are my ownership or related-entity
`of SightSound Technologies HoI-
`SightSound
`Technologies, LLC. So if a doffar came in, half of it
`would go to another entity, other expenses and
`preferences would be paid, and then that remaining
`
`09:58:15
`
`09:58:36
`
`09:58:59
`
`09:59:15
`
`09:59:40
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`))
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`23
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`24
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`Merrifl Corporation
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`San Francisco
`\^/ww . merrlllcorp . com/1aw
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`Page 00024
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`
`
`SCOTT CHRISTOPHER SANDER
`
`12/78/2012
`
`Page 25
`
`f or legal
`
`portion one coufd apply the percentages that I gave you
`the enumerator woufd be less
`before to that. So the
`than half of that doffar that comes in, and then those
`percentages could be applied to it.
`If SightSound were awarded the damages that
`O
`j-t's seeking in thís
`how would that affect
`litlgatlon,
`your personal finances?
`I4R. DiBOISE: Ob j ection; may call
`concfusion.
`THE WITNESS: If SightSound were awarded the
`litiqation,
`how woufd 1t
`damages it's seeking in this
`affect my personal finances?
`MR. BATCHELDER: That's the question.
`them favorably.
`THE WITNESS: It would affect
`BY MR. BATCHELDER:
`Is it
`fair
`O
`wealthy man?
`I don't
`A
`MR. D1BOISE: Objection.
`THE WITNESS: It depends on your definition of
`
`to say that you would become a very
`
`wealthy.
`
`BY MR. BATCHELDER:
`A Using your definítion of wealthy, can you
`answer the questlon?
`MR. DiBOfSE: Objection.
`
`10:00:08
`
`70: O0 :22
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`Page 26
`
`THE WITNESS: Certainly not by Sil-icon Valley
`standards.
`
`BY MR. BATCHELDER:
`O How much money do you think Apple should pay
`litigation?
`Sightsound in this
`MR. D1BOISE: Objection.
`THE WITNESS: I don't know. That's a job for
`our damages experts, and that's not my responsibilíty.
`BY MR. BATCHELDER:
`O Can you round it
`A No.
`MR. DiBOISE: Ob¡ection.
`BY MR. BATCHELDER:
`O No?
`A No, I don't believe I can.
`MR" D1BOISE: Objection.
`BY MR. BATCHELDER:
`O Can you round it
`doll-ars ?
`
`to the nearest $100 million?
`
`to the nearest billion
`
`MR. D1BOISE: Objection.
`THE VüITNESS: As I said, that' s not my
`to determine damages in this case.
`responsibility
`BY MR. BATCHELDER:
`O So you can't round it
`dol lars ?
`
`to the nearest bilfion
`
`10:01:32
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`800-869-9132
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`Merril-l Corporation
`
`San Francisco
`wvvw . merril lcorp . com/f aw
`
`Page 00026
`
`
`
`SCOTT CHRISTOPHER SANDER
`
`12/IB/2012
`
`Paqe 21
`
`MR. DiBOISE: Objection. Object.
`
`Go ahead.
`THE WITNESS: No, I don't believe I can.
`BY MR. BATCHELDER:
`a Do you recafl an initial
`communication between
`you and Mr. Hair in which he described what SightSound
`his invention?
`litigation
`in this
`is calling
`MR. D1BOISE: Objection.
`THE VüITNESS: Could you rephrase the question
`in a l-ess offensive manner?
`in a
`BY MR. BATCHELDER:
`lühat what do you find offensive?
`O
`MR. DiBOISE: Objection.
`THE WITNESS: Your dismissive use of the term
`"invention. "
`BY MR. BATCHELDER:
`O Why do you characterize
`MR. DiBOISE: Must we?
`BY MR. BATCHELDER:
`
`it as dismissive?
`Seriousl-y.
`
`a
`
`Pl-ease.
`
`MR. DiBOTSE:
`
`THE Vù]TNESS:
`dismissive?
`
`Obj ection.
`did you not mean it
`Did
`
`to be
`
`10 :02 2 28
`
`I0:02:52
`
`10:03: 10
`
`10:03:30
`
`BY MR. BATCHELDER
`O Sightsound is alleging in 1-his lltigation
`
`that
`
`10: 03: 41
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`800-869-9732
`
`Merrilf Corporation
`
`San Franc:-sco
`www. merrl llcorp . com/ Iaw
`
`Page 00027
`
`
`
`10:03:53
`
`10:04:07
`
`SCOTT CHR]STOPHER SANDER
`
`12/78/2072
`
`Page 28
`
`recall an initiaf
`that subject matter?
`
`Mr. Hair invented something; correct?
`A Yes.
`O My question is: Do you
`conversation with Mr. Hair about
`A Yes.
`O Vrlhen was that conversation?
`the '80s.
`A Back in
`be more precise?
`Can you
`remember exactly or precisely, no.
`I don't
`Was it in person?
`
`O A O A
`
`No.
`
`MR. DiBOISE:
`
`Obj ection.
`
`THE WITNESS:
`
`No.
`
`MR. D1BOISE:
`
`Slow down.
`
`BY MR. BATCHELDER
`
`10:04 : 1B
`
`7O:. O4 :,21
`
`Telephone?
`Yes, I believe it
`l¡/as.
`But you are not sure?
`I befleve it v/as a telephone cal-l
`a telephone call?
`that it was
`O Are you certain
`MR. DiBOISE: Objection.
`THE VüITNESS: As I sit here
`many years â9o, but I believe
`
`today, that was
`it vüas a telephone
`
`O A O A
`
`many,
`
`ca11.
`
`BY MR. BATCHELDER:
`
`10:04 :37
`
`1 aL '
`
`)
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`J 4 5 6 1 B 9
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`
`Merrill Corporation
`
`San F rancísco
`www . merrillcorp . com/1aw
`
`Page 00028
`
`
`
`SCOTT CHRISTOPHER SANDER
`
`L2/IB/20T2
`
`Page 29
`
`O
`
`But you are
`MR. DiBOISE:
`
`THE I'üITNESS:
`standard to
`is a high
`decades ago.
`
`not certain?
`Obj ection.
`I think so.
`Itm
`use for something
`
`certain is a
`that happened
`
`BY MR. BATCHELDER:
`O How long was the conversation?
`I don't recall.
`A
`O Can you give me your best estimate?
`I don't recall-.
`A
`O Could it have been as short as one minute?
`MR. DiBOISE: Objection.
`THE V\IITNESS: I f ind that
`
`I don't
`
`I doubt
`
`that.
`BY MR. BATCHELDER:
`O Coul-d it have been as short as five minutes?
`MR. DiBOISE: Objection.
`THE WITNESS: Perhaps.
`
`BY MR. BATCHELDER:
`O Perhaps?
`MR. DiBOISE: Objection.
`THE IlTITNESS: I don' 1- recal-1.
`
`10:04:49
`
`10:04:55
`
`10:05:06
`
`10:05: 17
`
`BY MR. BATCHELDER:
`O And did Mr. Hair say he had this
`was at a party?
`
`idea when he
`
`10:05:33
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`1 2 '
`
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`
`MerriIl Corporation
`
`San Francisco
`\^IW\^/ . merri I lcorp . com/ law
`
`Page 00029
`
`
`
`SCOTT CHRISTOPHER SANDER
`
`12/IB/20T2
`
`Page 30
`
`MR. DiBOISE: Objection.
`THE VJITNESS: I belleve so.
`BY MR. BATCHELDER
`O Do you know anything aboui- that party?
`A No.
`MR. D1BOTSE: Objection.
`BY MR. BATCHELDER:
`O Do you have any reason
`anything to drink before he had
`MR. D1BOISE: Objection
`THE VTIf TNESS: You would
`
`to think that he had
`his idea?
`
`have to ask Mr. Hair.
`
`any reason to
`
`to speculate,
`significant.
`
`if
`
`f had
`or not
`
`any reason to befieve that he
`other mind-altering substances
`
`BY MR. BATCHELDER:
`A The question is whether you have
`befieve that one v'/ay or the other?
`MR. DIBOISE: Objection.
`THE WITNESS: I would
`not likely or
`I would say not
`Art's not a big drinker.
`BY MR. BATCHELDER:
`0 And do you have
`would have ingested any
`before having his idea?
`MR. DiBOTSE:
`
`THE VI]ITNESS:
`
`BY MR. BATCHELDER:
`
`Obj ection.
`Absolutely not.
`
`10:05: 4 9
`
`10:06:00
`
`10:06:10
`
`I0 :.06:.21
`
`10:06:36
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`1 2 .
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`
`Merrill Corporatlon
`
`San Francisco
`www . merrillcorp . com/law
`
`Page 00030
`
`
`
`SCOTT CHRISTOPHER SANDER
`
`12/IB/20L2
`
`Page 31
`
`the party did you have your
`
`O Do you have any reason to bel-ieve that at that
`party, he told anyone, any of the party guests or hosts,
`about the idea that he had at the party?
`A
`I don't know.
`O How soon after
`conversation with him?
`A
`I don't know.
`O Could it have been weeks later?
`A
`I don't know.
`A Did you know at one point?
`I knew at. one point the
`if
`I can't recall
`A
`I
`distance between the party and the -- what I recall,
`bel-ieve, was a phone call. No, I don't. Perhaps I did.
`f don't know, ãs I sit here today, whether I knew the
`I inkage .
`O Would you please recounL for me, in as much
`detail as you do remember, what Mr. Hair said about his
`idea.
`
`MR. DiBOISE: Objection.
`THE WITNESS: Recount for you? I generally
`\^/as going to revofutionize
`that it
`recal.l- that
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