ARTHUR ROBERT HAIR
`
`12/IT/2012
`
`Page 1
`
`UNTTED STATES DISTRICT COURT
`
`FOR THE WESTERN D]STRICT OF PENNSYLVANIA
`
`---o0o---
`STGHTSOUND TECHNOLOGTES, LLC,
`Plaint i ff,
`
`174
`
`APPLE INC.,
`Defendant.
`
`ffiffiHfl&Hru&-Ë*
`
`CASE NO.:
`2: IIcv0I292-DWA
`
`'
`
`t"-'
`
`VIDEOTAPED DEPOS]T]ON OF
`
`ARTHUR ROBERT HAIR
`
`Tuesday, December II, 2012
`
`REPORTED BY: RACHET FERRIER, CSR 6948
`
`(r-448339)
`
`B 0 0-B 69-9132
`
`Merrill Corporation
`
`San Francisco
`w\^/\^/ . merri I Icorp . com/ l-aw
`
`Apple Exhibit 1027 Page 00001
`
`
`
`12/IT/2012
`
`Page 1
`
`UNTTED STATES DISTRICT COURT
`
`FOR THE WESTERN D]STRICT OF PENNSYLVANIA
`
`---o0o---
`STGHTSOUND TECHNOLOGTES, LLC,
`Plaint i ff,
`
`174
`
`APPLE INC.,
`Defendant.
`
`ffiffiHfl&Hru&-Ë*
`
`CASE NO.:
`2: IIcv0I292-DWA
`
`'
`
`t"-'
`
`VIDEOTAPED DEPOS]T]ON OF
`
`ARTHUR ROBERT HAIR
`
`Tuesday, December II, 2012
`
`REPORTED BY: RACHET FERRIER, CSR 6948
`
`(r-448339)
`
`B 0 0-B 69-9132
`
`Merrill Corporation
`
`San Francisco
`w\^/\^/ . merri I Icorp . com/ l-aw
`
`Apple Exhibit 1027 Page 00001
`
`
`
`ARTHUR ROBERT HAIR
`
`12/r7/2012
`
`INDEX OF EXAM]NATIONS
`
`EXAMINATION BY
`Ms - Fukuda
`
`EXHIBITS MARKED FOR IDENT]F'ICAT]ON
`
`NO.
`Exhibit 111
`
`DESCRIPTION
`Deposition Transcript of
`Arthur Hair dated 9/6/00, with
`exhibits
`Exhibit II2 Letter dated I0/21 /00 from
`Christopher J. Reese to
`Alderson Reporting Company
`Exhibit 113 Defendant Apple fnc.'s Notice of
`30(b) (6) Deposition to
`Plaintiff SightSound Technologies,
`LLC
`
`Exhibit
`
`I14 Defendant Apple fnc.'s Notice of
`Deposition to Arthur R. Hair
`for U. S.
`Exhibit 115 Prosecution History
`Patent 5,I9I,5'13
`Exhibit 116 May
`1992 Declaration Under
`5th,
`Section 7.I32
`31 C
`.F.R
`3Oth, 1993 Decl-aration
`December
`C. F. R. Section 7.732
`Under 31
`Exhibit 118 Document entitled "SightSound
`Technologies "
`(Bates SST-070449 - 70542)
`II9 SíghtSound Technologies
`Confidential Offering Memorandum
`March 2004
`(Bates SST-0L0821 - 10851)
`
`Exhibit
`
`IIl
`
`Exhibit
`
`Page 2
`
`PAGE
`B, 734
`
`PAGE
`
`o
`
`13
`
`I1
`
`I1
`
`51
`
`7I
`
`-1 )
`
`163
`
`L73
`
`1 2 )J 4 5 6 1 B 9
`
`10
`
`11
`I2
`
`13
`
`L4
`
`15
`I6
`
`I1
`
`1B
`t9
`
`20
`
`27
`))
`
`24
`
`25
`
`800-B 69-9132
`
`Merrill- Corporation
`
`San Francisco
`\^/\^/w . merri I I co rp . com/ 1 aw
`
`Page 00002
`
`
`
`ARTHUR ROBERT HAIR
`
`12 / LI/ 2OT2
`
`EXH]BITS MARKED FOR IDENTIF]CAT]ON
`
`NO.
`Exhibit
`
`I20
`
`Exhibit I2I
`
`Exhibit I22
`
`Exhibit I23
`
`Exhibit I24
`
`DESCRI PTTON
`Sightsound/McM Due Diligence
`April 4-5, 200I, Agenda
`(Bates SST-I09I1 - I0925)
`WhaL is SightSound Technologies?
`(Bates SST-10934 - L0942)
`Facsimife Cover Sheet dated
`to HaI Richardson
`L2/IB/0I
`from Scott Sander, with
`attachment
`(Bates SST-15052 - 15058)
`Screen Shots of the SightSound
`I¡üebsite
`(Bates SST*02]-831 - 02L972)
`Patent License Agreement
`Between Parsec Sight/Sound, Inc.
`And Digital Sight/Sound, Inc.
`(Bates SST-7842 7851)
`GE - SightSound Signing and
`in Connection
`Closing Deliveries
`with the Asset Purchase Agreement,
`dated as of November 10, 2005, by
`and Between DMT Licensing, LLC,
`and SightSound Technologies, Inc.
`(Bates SST-10196 - 10424)
`Draft Non-Exclusive Patent
`Lícense Agreement
`(Bates SST-7983 - 79BB )
`Facsimile Message dated IL/22/93
`From C.D. de Jongh to R. Hamersma
`(Bates SST-031049 37050)
`Exhibit I2B Letter dated I7/30/93 from
`Ansel- Schwartz Lo Arthur Hair
`Exhibit I29 Letter dated I/IB/94 from
`Michaef Marion to Arthur Hair
`(Bates SST-02 4433)
`
`Exhibit 725
`
`Exhibit 126
`
`Exhibit I21
`
`Page 3
`
`PAGE
`
`180
`
`181
`
`TB4
`
`185
`
`1BB
`
`193
`
`208
`
`209
`
`2II
`
`214
`
`1 2 )J 4 5 6 1 B 9
`
`10
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`11
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`T2
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`13
`I4
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`15
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`I6
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`I1
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`1B
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`I9
`20
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`2I
`22
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`23
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`)A
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`25
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`B 0 0- 869-9]-32
`
`Merrill Corporation
`
`San Francisco
`h/h/w . merri I l-corp . com/ l-aw
`
`Page 00003
`
`
`
`ARTHUR ROBERT HAIR
`
`12/17/2012
`
`NO.
`Exhibit 130
`
`EXHIB]TS MARKED FOR IDENT]FICATION
`DESCRIPTION
`Letter
`dated I/26/94 from
`Schwartz Lo Arthur Hair
`Ansel
`dated I/28/94 from
`Exhibit 131 Letter
`Hair to Michaef Marion
`Arthur
`ssr-02 4424)
`( Bates
`Exhibit I32 Letter dated 3/9/94 from
`R. Hamersma to Arthur Hair
`Exhibit 133 Letter dated 3/25/94 from
`Ansel Schwartz to Arthur Hair
`Exhibit 134 Letter
`dated 3/37/94 from
`Hair to Robert Hamersma
`Arthur
`ssr-2 4425)
`( Bates
`Exhibit 135 Letter
`dated 7/15/91 from
`Sachs to Arthur Hair
`Robert
`ssr-031064 - 37065)
`( Bates
`Exhibit 136 Letter
`dated I0/l/91 from
`Hair to J. J. Rosen
`Arthur
`N2K 1s9 - 165)
`( Bates
`Exhibit L31 Letter dated I/22/98
`Christopher Reese to
`(Bates N2K I13 - IB2)
`Exhibit 138 Letter dated 5/6/98 from
`Richard Rinaldo to Arthur Hair
`(Bates SST-025984 )
`Exhibit 139 Memo Pad for Arthur
`R. Hair
`(Bates SST-02151 4
`21 5Br)
`Exhibit I40 White Paper, February 26, 1999
`(ssr-7695 - 1914)
`Exhibit I4L InformaLion Memorandum,
`March 9th, 1998
`(Bates SST0B694 - B70B)
`
`from
`J. J. Rosen
`
`Page 4
`
`PAGE
`
`2r1
`
`2IB
`
`2IB
`
`279
`
`220
`
`22r
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`222
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`223
`
`224
`
`225
`
`229
`
`¿JZ
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`1 2 3 4 t
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`rJ
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`6 1 B 9
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`10
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`11
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`L2
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`13
`
`I4
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`15
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`t6
`
`I1
`
`1B
`
`19
`
`20
`2I
`))
`
`24
`
`25
`
`800-B 69-9132
`
`MerriÌl- Corporation
`
`San Francisco
`www. merrillcorp. com/law
`
`Page 00004
`
`
`
`ARTHUR ROBERT HAIR
`
`12/II/20L2
`
`EXH]BTTS MARKED FOR ]DENTTFICATION
`
`DESCRIPTION
`Letter dated LL/1 /03 to
`Alex LePore and Chris Reese from
`BMW Technology, Inc.
`(Bates SST-37598 - 37599)
`I43 Document entitl-ed "SightSound
`Technol-ogies "
`(Bates SST-31I40 - 3171L)
`
`NO.
`Exhibit 742
`
`Exhibit
`
`Page 5
`
`PAGE
`
`233
`
`234
`
`---o0o---
`
`1 2 J 4 t
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`tôIO
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`79
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`20
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`2L
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`ZZ
`
`a')
`
`24
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`25
`
`800-B 69-9]-32
`
`Merrill- Corporation
`
`San Francisco
`v/ww . merri l- l- corp . com/ Iaw
`
`Page 00005
`
`
`
`ARTHUR ROBERT HAIR
`
`12/rr/20t2
`
`Page 6
`
`BE IT REMEMBERED that, pursuant to the laws
`governing the taking and use of depositions, oû Tuesday,
`December II, 2012, commencing at 9204 a.m. thereof, ât
`Ropes & Gray, 1900 University Avenue, 6th Floor, East
`Pafo Alto, Calífornia 94303, before me, RACHEL FERRIER,
`a Certified Shorthand Reporter, personally appeared
`ARTHUR ROBERT HAIR, call-ed as a witness by Defendant,
`who, being by me first duly s\,vorn, was thereupon
`examined as a witness in said action.
`APPEARANCES OF COUNSEL
`For the Plaintiff
`and the Witness:
`ARNOLD & PORTER LLP
`BY: JAMES A. DiBOISE, Attorney at Law
`Three Embarcadero Center, JLin Floor
`San Francisco, California 94II1
`Telephone: 4I5. 417.328I
`Email-: j ames. diboiseGaporter. com
`For the Defendant:
`
`ROPES E GRAY
`BY: CHING-LEE FUKUDA/ Attorney at Law
`72L! Avenue of the Americas
`New York, New York 10036
`Telephone: 2I2.596.9000
`Email: ching-lee. fukudaGropesgray.com
`
`ALSO PRESENT:
`
`PATRTCIA GUERRERO, Videographer
`---o0o---
`
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`L9
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`20
`2I
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`¿J
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`24
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`25
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`800-B 69-9132
`
`MerriÌI Corporation
`
`San Francisco
`ww\.r . merri I lcorp . com/ law
`
`Page 00006
`
`
`
`ARTHUR ROBERT HAIR
`
`L2/rr/2072
`
`Page 1
`
`EAST PALO ALTO, CALIFORNIA
`TUESDAY, DECEMBER LI, 2OL2
`9:04 A. M.
`o0o---
`
`PROCEEDINGS
`
`THE VIDEOGRAPHER: Good morning.
`Here begins Videotape No. 1, Volume 1 in the
`deposition of Arthur Hair in the matter of SightSound
`Technologies, LLC, versus AppIe fnc. in the
`U.S. District Court, Western Division of Pennsylvania.
`The case number is 2:I7cv0I292-DVüA.
`Today's date is December 11th, 2012. The time
`on the video monltor is 9:04.
`The videographer today is Patricia Guerrero, a
`notary pubtic employed by Merrlll Court Reporting,
`San Francisco.
`This video deposition is taking place at the
`Law Offices of Ropes & Gray, 1900 University Avenue,
`East Palo Alto, California.
`Counsel-, please voice identify yourse-Lves and
`state whom you represent.
`MS. FUKUDA: Ching-Lee Fukuda with Ropes &
`Gray, representing defendant, Apple.
`MR. DiBOISE: James DiBoise with Arnold &
`Porter/ represent.ing the witness and the plaintiff.
`
`09:04:10
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`09:.04:.21
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`09:04 :39
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`09:04 :50
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`2I
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`z5
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`24
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`25
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`800-B 69-9L32
`
`Merril-I Corporation
`
`San Franci-sco
`www. merrillcorp . com/1aw
`
`Page 00007
`
`
`
`ARTHUR ROBERT HAIR
`
`L2/17/2012
`
`Page B
`
`THE VIDEOGRAPHER: Thank you.
`The court reporter today is Rachel Ferrier of
`Merrill Court Reporting.
`Would the court reporter please sv/ear 1n the
`
`witness.
`
`.UU(J__-
`
`ARTHUR ROBERT HAIR
`
`calfed as a witness, having been first duly
`sworn, was examined and testified as foflows
`o0o---
`THE VIDEOGRAPHER: Thank you.
`Please begin.
`
`EXAM]NATION
`
`BY MS. FUKUDA:
`O Good morning, Mr. Halr.
`A Good morning.
`O Would you just state your fulÌ name for the
`record, please.
`A Arthur Robert Hair,
`a And where do you currently
`reside?
`In Westl-ake Vil-Iage, California.
`A
`O Could I have the full address, please.
`2009 Channelford Road, Westlake Village,
`A
`California 9136L.
`
`09:04:59
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`09 z 2''l :22
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`09:05:06
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`09:05:12
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`no.nq.?¿
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`24
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`B 0 0-B 69-9132
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`Merril-l Corporation
`
`San Francisco
`www . merrí11corp . com/ Iaw
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`Page 00008
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`09:05:31
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`09:05:43
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`09:06:05
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`09:06:37
`
`09 z 06: 49
`
`ARTHUR ROBERT HA]R
`
`L2/L7/2012
`
`Page 9
`
`a
`
`testimony
`
`Thank you.
`Mr. Hair, you have given prior deposition
`be fore ?
`
`Yes.
`About how many times?
`
`A O A
`
`Twice.
`describe under what
`O Can you tell me
`cj-rcumstances you provided the testimony 1n those two
`depositions ?
`A What do you mean bY
`in?
`O What what cases dld You testifY
`in the N2K case and this case.
`I testified
`A
`O Okay. Anything el-se?
`A Not that I can recaff.
`MS. FUKUDA: Okay. I am going to mark, for
`II1., a copy of your
`purposes of the record, Exhibit
`deposition testimony in the N2K case, âs welf as the
`associated exhibits, and T'm just going to put that in
`I have a coupl-e questions for you
`front of you.
`regarding that.
`MR. DiBOISE: Thank you.
`(Exhibit 111 was marked for identification
`the Court Reporter. )
`BY MS. FUKUDA:
`O Mr. Hair, have you had a chance to review the
`
`by
`
`1 2 )J 4 5 6 1 B 9
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`24
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`25
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`
`Merrill- Corporation
`
`San Francisco
`\^/w\^r . merri f l- corp . com/ l-aw
`
`Page 00009
`
`
`
`ARTHUR ROBERT HAIR
`
`12/LI/2012
`
`Page 10
`
`deposition testimony that you had given Ín the N2K case?
`MR. DiBOISE: Objection.
`THE VIITNESS: Can you tell me what you mean by
`tt review it " ?
`BY MS. FUKUDA:
`did -- have you had an opportunity to
`O Have
`read through it at any time in the past?
`A An opportunity or did I? because I did not
`did not read through it.
`O You've never read through your deposition
`testimony?
`A Recently or back then?
`O At any time.
`I possibly might have read t.hrough it after
`A
`right now.
`I can't recall
`this deposition.
`O Okay. Are you aware of any corrections
`you had made to this deposltion transcript?
`objection.
`MR. DiBOISE: Object
`Go ahead.
`THE WITNESS: That is a possibitity.
`right now.
`recall
`BY MS. FUKUDA:
`as far as yolt know, sitting
`O Okay. And as
`here today, is there anything in your prior N2K
`testimony that is noL true or inaccurate?
`
`that
`
`I can't
`
`I
`
`0920'7 202
`
`09:07:11
`
`09:01:27
`
`09:07:35
`
`09:07:48
`
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`Merrill Corporation
`
`San Francisco
`\¡/ww . merri I l corp . com/ l-aw
`
`Page 00010
`
`
`
`ARTHUR ROBERT HAIR
`
`12/L7/2012
`
`Page 11
`
`MR. DiBOISE: Objection. The question cafls
`to be able to
`for him to read through the transcript
`gíve you a present-day answer to that..
`Do you really want him to read through it aÌl
`and look for anything he wants to change?
`MS. FUKUDA: That's not my question.
`is your question. LeL's
`MR. DiBOISE: Yes, it
`
`j ust
`
`Jamie, let's stick to object.ion to
`
`MS. FUKUDA:
`form, please.
`MR. DíBO]SE:
`You can answer
`
`If you persist in the question
`it if you think you can.
`I don't recall.
`
`sitting here today, are you aware
`your prior N2K testimony?
`Obj ection.
`Sitting here today, I don't
`
`09:07:59
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`09:08:07
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`09:08:14
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`09:08:23
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`THE W]TNESS:
`
`BY MS. FUKUDA:
`O Okay. Well,
`of any inaccuracies in
`MR. DiBOISE:
`
`THE WTTNESS:
`
`recaff.
`BY MS. FUKUDA:
`O Okay. But are
`MR. DiBOISE:
`
`THE Vü]TNESS:
`
`BY MS. FUKUDA:
`a Okay. Do you
`
`you aware of any inaccuracies?
`Obj ection.
`I don't recal-I.
`
`remember
`
`if you could turn
`
`09:08:30
`
`B 0 0- 869-9132
`
`Merrill- Corporation
`
`San Francisco
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`Page 00011
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`
`
`ARTHUR ROBERT HAIR
`
`12/77/2012
`
`Page 12
`
`I
`
`IS
`
`may
`
`the fourth document in that pile?
`I think it's
`to
`think you're looking at t.he fifth one, so the fourth
`document in that pile.
`what that document is?
`Do you recognrze
`I just want to state
`that
`MR. DiBOISE: So
`pile" in
`to it as the "fourth document in the
`referring
`it again
`is really not going to help us find
`the record
`Here, let me
`MS. FUKUDA:
`That's okay. The heading
`MR. D1BO]SE:
`deposition of Arthur Hair
`"CorrecLion sheet for
`having Production Nos. ST
`September 6-8, 2000, "
`0I23I2 through I4.
`b,e an tr f 'r
`Yes. I confirm it's STI 72312
`MS. FUKUDA:
`through I23I4.
`O Do you see that document?
`A Mm-hmm. Yes, I do.
`O Do you remember providing any information to be
`submitted with this document?
`I don't recall a date or dates or anything like
`A
`I'm not saying I didn't,
`that as far as doing it.
`f'm
`just saying I don't recalt it.
`O Do you know who Christopher Reese is?
`A Yes, I do.
`O Okay. And do you remember whether Mr. Reese
`had submitted an errata sheet on your behalf with
`
`09:08:59
`
`09:09:14
`
`09:09:54
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`09:l-0:06
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`Merril-1 Corporation
`
`San Francisco
`www . merri l1 corp . com/ l-a\^I
`
`Page 00012
`
`
`
`ARTHUR ROBERT HAIR
`
`72/rr/2012
`
`Page 13
`
`to your deposition testimony
`
`respect to any corrections
`in t.he N2K case?
`"Yes" or "no. "
`MR. DiBOISE: Hol-d on,
`THE WTTNESS: f -- I don't recalf, but, again,
`f'm not saying it didn't happen.
`MS. FUKUDA: Let me just mark, as Exhibit LL2,
`a document dated October 27Lh, 2000 from Christopher J.
`Reese to Alderson Reporting Company. I apologize that
`is the one copy f have, but you may share that with
`this
`your counsel , if you could take a look at that.
`(Exhibit
`II2 was marked for identification
`the Court Reporter. )
`BY MS. FUKUDA:
`0 So, Mr. Hair, do you recalf around the time of
`October of 2000 whether Mr. Reese had asked you to
`in the N2K to provide
`review your deposition transcript
`for this errata sheet?
`any corrections
`MR. DiBOISE: Objection; instruction.
`Attorney-cfient privilege, work product.
`You don't have to ansh/er that question.
`MS. FUKUDA: Are you instructing
`the witness
`not to answer?
`MR. DíBOISE: I think that's what I just said.
`BY MS. FUKUDA:
`O Are you going to follow your counsel-'s advice?
`
`by
`
`09:.70:.41
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`Merril-1 Corporation
`
`San Francisco
`\^/w\,v . merri 1 lcorp . com/ 1aw
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`Page 00013
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`09:13:54
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`09:14:11
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`09:. 14 :56
`
`ARTHUR ROBERT HAIR
`
`72/7r/2072
`
`Page 14
`
`Reese
`
`Yes,
`
`Did
`
`MR.
`
`A O
`
`O
`testimony
`
`I will.
`you provide any corrections to Mr
`DiBOISE: Objection; instruction.
`BY MS. FUKUDA:
`around Oct.ober of 2000 for your deposition
`in the N2K?
`MR. DiBOISE: Objection; instruction.
`You don't have to answer.
`I disagree that that's privileged
`MS. FUKUDA:
`the witness not to
`are instructing
`information, but you
`answer,' correct ?
`MR. DiBOISE:
`
`Correct.
`
`BY MS. FUKUDA:
`O And you are
`advi ce ?
`
`À
`
`Vac
`
`goíng to follow your counsel's
`
`a Okay. So just
`through this,
`to short-círcuit
`sit.tíng here today, are you av/are of anything that's
`in your testimony in the N2K case?
`incorrect
`MR. DiBOISE: Asked and answered.
`THE VJITNESS: Not that I can recall- .
`MS. FUKUDA: You can put that aside for now.
`question: Do you recall whether your
`O One more
`in the
`deposition
`N2K case \^ras videotaped?
`AI
`it
`\^Ias videotaped.
`if
`I can't reca]I
`
`800-869-9732
`
`Merrill Corporation
`
`San Francisco
`wu/w . merri J-lcorp . com/ l-aw
`
`I 2 J 4 t
`
`rJ
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`6 1 oo 9
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`09:15:07
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`09:15:16
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`09:15:36
`
`ARTHUR ROBERT HAIR
`
`72/Lr/2012
`
`Page 15
`
`O Have you ever
`your deposition?
`MR. DíBO]SE:
`
`MS. FUKUDA:
`
`THE WITNESS:
`
`seen videotape associated with
`
`In the N2K case?
`In the N2K case
`f do not recafl.
`
`BY MS. FUKUDA:
`videotapes for your deposition in
`If
`there l¡Jere
`O
`you know who would have
`the N2K case, do
`I can't
`think of who would have
`recaff who your counsel
`Do you
`
`them?
`
`them.
`I¡/as in the N2K
`
`A a
`
`case?
`
`A Yes.
`And who was that?
`Kenyon & Kenyon.
`lawyer that you remember?
`Any particular
`Bill Wells.
`Did BiIl WeÌfs defend you during that
`the N2K case?
`deposition in
`MR. DiBOISE: Objection.
`THE WITNESS: Was he my lawyer?
`MS. FUKUDA: At the deposition.
`THE VüITNESS: He
`he was the SightSound
`the deposition.
`
`lawyer
`
`clL
`
`O A a A O
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`24
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`BY MS"
`
`O
`
`FUKUDA
`Okay. So you understand that, today, yoü are
`
`09:15:46
`
`800-869-9132
`
`Merril-1 Corporation
`
`San Francisco
`www . merrillcorp . com/ law
`
`Page 00015
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`
`
`ARTHUR ROBERT HAIR
`
`12/II/2012
`
`Page 16
`
`stitt under oath to testify?
`A Yes.
`MR. DiBOISE: From what. deposition?
`MS. FUKUDA: Today's deposition.
`MR. DiBOISE: Okay.
`THE W]TNESS: YCS.
`BY MS. FUKUDA:
`O Okay. And you understand the general rules of
`the deposition. You have to verbal-ly answer "yes" or
`"no" to my questions?
`A Yes.
`O And if you need a break at any time, let me
`there's something you need me to clarify,
`know. If
`me know as wefl.
`Is that all right?
`A Yes.
`O Okay. And is there any reason why you can't
`testify completely and truthfully
`today?
`A
`I do not believe so.
`MS. FUKUDA: Let me just mark a couple of
`Deposition Notices.
`Exhibit 113 is Defendant Apple Inc.'s Notice of
`30 (b) (6) Deposit.ion to Pl-aintif f SightSound
`Technol-ogies, LLC.
`
`Iet
`
`09:15:54
`
`09:16:01
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`09:16:14
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`09: 16:34
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`
`Merrill- Corporation
`
`San Francisco
`www. merrif lcorp . com/1aw
`
`Page 00016
`
`
`
`ARTHUR ROBERT HAIR
`
`72/7L/20L2
`
`Page 11
`
`identification by
`
`is Defendant Apple
`R. Hair.
`identification by
`
`09:17:31
`
`(Exhibit 113 was marked for
`the Court Reporter. )
`MS. FUKUDA: And Exhibit II4
`Inc. ' s Notice of Deposition t.o Arthur
`(Exhibit 7I4 was marked for
`the Court Reporter. )
`MR. D1BOISE: Thanks.
`BY MS. FUKUDA:
`O Mr, Hair, did
`to testify
`pursuant to
`capacity?
`
`you understand you are here today
`Exhibit 113 in your individual
`
`09:18:02
`
`MR
`
`MS.
`
`DiBOISE: Obj ection.
`FUKUDA: My apologies
`
`I have that.
`
`backwards.
`lt's pursuant
`O
`individual capacity?
`MR. DíBOISE:
`
`THE WITNESS:
`
`to II4, Exhibit
`
`II4,
`
`in your
`
`09:18:11
`
`Obj ection.
`So what is your question?
`
`BY MS. FUKUDA:
`O Are you here
`individuaf capacity in
`of Deposition of Arthur
`A Yes.
`And have you also been designated as
`witness on behalf of SightSound to
`
`to testify
`response
`
`today in your
`to Exhibit II4, Notice
`
`09: 18:25
`
`Hair?
`
`O
`corporate
`
`a
`testi fy
`
`09:18:41
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`1 2 3 4 5 6 1 B 9
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`San Francisco
`ww,/ú . merri llcorp . com/ law
`
`Page 00017
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`09:19:30
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`09:19:43
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`09:19:59
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`09 z 20 :31
`
`ARTHUR ROBERT HAIR
`
`12/1r/2012
`
`Page 18
`
`certain topics in Exhibit 113, the
`
`with respecL to
`30 (b) (6) notice?
`A Can you
`O Sure.
`
`A
`
`tell me which topics?
`Topics 7, 6, B, 10, and 12.
`believe those are the ones.
`I
`designated with respect to
`And have you been
`O
`this notice?
`any of the other topics in
`he has not.
`MR. DiBOISE: No,
`that I'm aware of.
`
`THE WTTNESS: NOt
`
`1 2 .
`
`>
`
`J 4 5 6 1 B 9
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`20
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`2L
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`24
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`25
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`BY MS. FUKUDA:
`O Okay. Now, yoü understand that there have been
`various different corporaLe entities with the name
`SightSound over t.he years; correct?
`7\
`V¿c
`] am.
`r vJ,
`O Okay. With respecL to your corporate wiLness
`testimony today in response to the 30(b) (6) topics, do
`you understand that. you have been designated to testify
`on behaÌf of aII the different SightSound entities over
`the years?
`A Yes, that's my understanding.
`O Okay. And you are knowledgeable to testify on
`those topics?
`A Up until July of 2006.
`O And what happened j-n July of 2006?
`A
`I l-eft SightSound.
`
`800-869-9132
`
`Merril-J- Corporation
`
`San Francisco
`ww\.{ . merrí I lcorp . com/ law
`
`Page 00018
`
`
`
`ARTHUR ROBERT HA]R
`
`L2/rr/20t2
`
`Page 79
`
`O So your corporate testj-mony today will be
`t.o the time period of July 2006 and earlier?
`limited
`MR. DiBOISE: Objection.
`THE WITNESS: That is my belief.
`BY MS. FUKUDA:
`a Okay. After you left SightSound in July of
`2006, did you continue to have contact with members of
`SightSound?
`A Yes.
`O And did you continue to have knowledge about
`after July of 2006?
`Sightsound's various activities
`A Nothing other than what shareholders were
`receiving in the mail.
`after JuIy of 2006, you no
`O Okay. Did you
`J-onger worked with anyone affiliated with SightSound?
`A Up untiJ- a point. There needs to be a
`the board of one of
`because I did rejoin
`cfarification,
`I
`T believe it was in,
`the SightSound entlties.
`belíeve, 20II?
`O Okay. So I -- but for purposes of your
`30(b) (6) testimony today, it
`is limited
`to July 2006 and
`earl ier
`
`MR. DiBOISE: Object
`BY MS. FUKUDA:
`is that right?
`
`O
`
`09:.20:.56
`
`09:.2L:. II
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`09:.21- z 29
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`
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`
`San Francisco
`v\¡w\^/ . merri 1 l-corp . com/ law
`
`Page 00019
`
`
`
`ARTHUR ROBERT HAIR
`
`L2/LL/20L2
`
`Page 20
`
`y\
`
`that's
`
`MR. DiBOISE: Objection.
`1ç .-ru know.
`f !
`THE WITNESS: Again, I believe that's
`why f'm here.
`BY MS. FUKUDA:
`when you prepared for
`O Okay. Vühen you v/ere
`your 30(b) (6) testimony today, did you discuss with
`anyone what took place at Sightsound aft.er July of 2006
`for purposes of preparing you to testify as a corporate
`wítnes s ?
`
`MR. DiBOISE: "Yes" or "no."
`THE VIITNESS: I do not believe so.
`BY MS. FUKUDA:
`In those parts of the deposition where you are
`O
`I ask you a question
`if
`testifying on those five topics,
`that says "you, " what f mean is not just You,
`personally, but also you as in the SlghtSound entlty.
`A That is my understanding.
`MR. DiBOISE: Vüeff, for clarity purposes, I
`would like you to identify which questions are
`to the 30(b) (6) notice and whích are
`pertaining
`to the witness in his individuaf capacity.
`pertaining
`BY MS. FUKUDA:
`O Okay. Vlell-, if you are confused about in which
`capacity you are answering, please let me know. I will
`
`09:22: 19
`
`aìo.t,).'ìo
`
`09:22:54
`
`09:23: 14
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`z5
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`24
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`
`Merril-l Corporation
`
`San Francisco
`w\^/w . merrif Icorp . com/1aw
`
`Page 00020
`
`
`
`ARTHUR ROBERT HAIR
`
`72/L7/2012
`
`Page 27
`
`do my best to be cfear that I'm asking for your
`testimony as a corporate witness as opposed to an
`individuaf capacity.
`Is that all right?
`A That's all- right.
`In some of my questions today, I may ask you
`O
`questions that use the word "communicate" or
`f want you to take
`"communicationsr " and when I do that,
`forms of
`an expansive meaníng of that Lerm to cover all
`communications, including wril-ten, oraf, paper'
`electronic, and so forth.
`Is that afl right?
`A That's fine.
`O Okay. In preparing for your testimony as a
`30(b) (6) witness today, did you have any discussions
`with anybody?
`A Legal counsel.
`a Okay. Can you identify
`A
`Jamie DiBoise.
`O Anyone efse?
`A Forgot his name.
`O An attorney from Arnold & Porter?
`A Correct.
`O Okay. Did you have any discussions with anyone
`efse in preparation for your testimony today?
`
`them, please?
`
`09:.23:39
`
`09:24 :0I
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`09 :,24 : I1
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`2I
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`San Francisco
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`Page 00021
`
`
`
`ARTHUR ROBERT HA]R
`
`72/77/2012
`
`Page 22
`
`A Not that I can think of.
`O And t.hese discussi-ons with Jamie and somebody
`else at Arnold & Porter, how long did they last?
`ft's
`MR. DiBOISE: Objection.
`compound.
`THE WITNESS: Rouqhly five hours.
`BY MS. FUKUDA:
`A When -- which day?
`A That would be yesterday.
`O Was that an in-person meeting or by phone?
`MR. D1BOISE: Objection; compound.
`THE WITNESS: One in person, one by phone.
`BY MS. FUKUDA:
`and the lawyer by phone 1s the
`O Okay. And
`other lawyer, not Jamie; correct?
`A Correct.
`Isitaheorashe?
`O
`A
`It's a he.
`O Okay. Did you do anything else to prepare that
`we haven't covered?
`A Not
`MR. DiBOISE: Objection.
`THE V\IITNESS: Not that I can think of .
`BY MS. FUKUDA:
`O Now, Mr. Hair, just a couple of foJ-low-up on
`your background.
`
`09 z 25: 14
`
`09 :,25:25
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`09:.25:38
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`Merrill Corporation
`
`San Francisco
`\^/ww . merri 1 lcorp . com/ Iaw
`
`Page 00022
`
`
`
`ARTHUR ROBERT HATR
`
`12/r7/2072
`
`Page 23
`
`Who are you currently employed by?
`f am a consuftant for Pense Productions.
`A
`O And has your rol-e for Pense changed in any way
`since your l-ast deposition in this case?
`A No, I do noL believe so.
`O Do you have any current affifiations with
`SightSound?
`MR. DiBOISE: Object.ion.
`THE WITNESS: Yes.
`BY MS. FUKUDA:
`O What is that?
`I am a board member of one of the SightSound
`A
`entities.
`O Do you know which SightSound entity?
`A Off the top of my head, I don't know the exact
`is described.
`way the SightSound entity
`you have been a board
`is
`O Okay. And this
`member of that SightSound entity since 20II?
`I believe that is the case, sometime in 20II.
`A
`O Okay. Do you know if
`it was early or late
`
`20\r?
`
`I would have to guess, so I -- I don't recaff.
`A
`a And what is
`your role on the board of the
`SiqhtSound entity?
`MR. DiBOISE:
`
`Obj ection
`
`09 :26:,30
`
`09 :,26: 41
`
`09:.26:55
`
`09 :,21 :, 11
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`1B
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`79
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`20
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`a1z,r
`)t
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`24
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`Merrill Corporati-on
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`San Francisco
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`Page 00023
`
`
`
`ARTHUR ROBERT HATR
`
`12/II/20T2
`
`Paqe 24
`
`board member
`
`THE WITNESS: I am a board member.
`BY MS. FUKUDA:
`O What kind of thì-ngs do you do as a
`of SightSound?
`A Att.end board meetings.
`A Anything else?
`A Not really.
`O Do you make declsíons?
`A Yes.
`O Vúhat. kind of decisions do you make
`SightSound?
`caII for the
`MR. DiBOISE: Objection. May also
`information.
`discl-osure of confidentlal attorney-client
`that you made
`If you can separate any decisíons
`I woul-d
`legal advice,
`that involve legal device
`If
`there
`caution you not to reveal those decisions.
`in
`were any decísions that you participated
`that did not
`invol-ve legal advice, feel free to ansr,^/er the question.
`Do you undersLand my instruction?
`THE WITNESS: Yes.
`MR. D1BOISE: Can you answer the question?
`
`on behalf of
`
`THE VüITNESS: NO.
`MR. D1BOISE: Then I instruct you.
`BY MS. FUKUDA:
`A You can't answer any part of my question even
`
`09:21:40
`
`09:21:52
`
`09 :28 :06
`
`aìo. tQ, r1
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`20
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`2L
`)')
`
`23
`
`24
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`25
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`B 0 0- 869-9732
`
`Merrifl Corporation
`
`San Francisco
`www. merrillcorp . com/f aw
`
`Page 00024
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`
`
`ARTHUR ROBERT HAIR
`
`T2/TI/2012
`
`Page 25
`
`at a high-level about the type of decisions you make on
`behal-f of SightSound as a board member?
`from counsel, [o.
`A Based on instruction
`O Okay. Are you able to tel-l me whether your
`or business?
`decisions are with respect to litigation
`MR. DiBOISE: Objection; compound, lacks
`foundation.
`THE WITNESS: Again, based on direction
`counsel, I can't answer that.
`MS. FUKUDA: Yeah, I don't think your counsel
`just now.
`objected on the basis of privilege
`O So my question is: Do you make decisions on
`behalf of SightSound with respect to litigation
`or
`SightSound business?
`MR. DiBOISE: The question is compound, and
`If he
`that I gave him.
`the instruction
`he's followíng
`If he can't ansl¡/er it, he'f I
`can ans\^/er it, he wif 1.
`abide by the instruction.
`THE WTTNESS: I'm abiding by instruction
`
`from
`
`from
`
`09:28 : 42
`
`09:28:58
`
`09 z 29 :09
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`09 :29 : 19
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`counsel.
`BY MS. FUKUDA:
`O Does SightSound
`apart from litigation?
`A At this time, I
`a How often do you
`
`have any business separate and
`
`do not believe so.
`have board meetings?
`
`09 :,29 :,36
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`1 2 3 4 5 6 1 B 9
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`10
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`B 00-B 69-9132
`
`Merrill- Corporation
`
`San Francisco
`www . merri l- l-corp . com/ law
`
`Page 00025
`
`
`
`ARTHUR ROBERT HA]R
`
`T2/II/2012
`
`Page 26
`
`the past several
`board of
`
`A
`say two,
`
`O
`
`r vu,
`
`They are not
`routinely scheduled, so I woul-d
`year at most.
`three times a
`been the case for
`And has that
`at least since you joined the
`years, or
`SightSound?
`I believe so.
`A
`O Vrlho attends these board meetings for
`SightSound?
`A Board members.
`O Just the board members?
`a Yac I believe So.
`O No other entities?
`MR. DiBOISE: You mean people?
`BY MS. FUKUDA:
`O No people affiliated with other entities other
`than board members?
`A There could be times when counsel was invofved.
`I can't recall-.
`Other than that,
`a When you say "counsel, " who are you referring
`
`1 2 3 4 t
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`09:30:02
`
`09:30:17
`
`09:30:32
`
`09:3I:, 12
`
`09:3I:23
`
`to?
`
`A A lawyer.
`f understand, but which lawyer?
`O
`I don't recall which one at
`A Again, I
`any specific situation.
`O You have no recolfection of who had attended in
`
`in
`
`800-869-9L32
`
`Merril-1 Corporation
`
`San Francisco
`www . merril lcorp . com/ l-aw
`
`Page 00026
`
`
`
`ARTHUR ROBERT HAIR
`
`L2/II/20T2
`
`Page 21
`
`the past as a lawyer during these board meetings?
`A Thatrs correct.
`O When was the l-ast board meeting you had at
`SightSound?
`the date.
`I don't recall
`A
`O Do you know approximately when?
`I believe it was a few months âgo, but f don't
`A
`recal-I the specific date.
`a Aff right. Mr. Hair, I'm going to ask you a
`series of questions ln your capacity as a 30(b) (6)
`witness that relates to at least Toplc 1 and may touch
`is where f would
`upon some of the other topics, so this
`Iike to make clear that you are not answering;ust as an
`individual with individual knowledge but also on behal-f
`of SightSound. Okay?
`MR. D1BOISE: And just the -- make the record
`the witness r^/as prepared through today's date.
`clear,
`in 2006 in terms of his preparation
`There \^ras no cutoff
`on these topics.
`MS. FUKUDA: Okay. T guess, let me just
`that.
`Vüith respect to all- five topics?
`DiBOISE: Yes.
`BY MS. FUKUDA:
`O Okay. So, Mr. Halr, you
`
`cl-arify
`
`MR
`
`09:31:41
`
`09:.32:09
`
`O9:.32:26
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`09 :32: 41
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`
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`
`24
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`B 0 0- 869-9732
`
`Merrill Corporation
`
`San Francisco
`ww\^/ . merrillcorp . com/1aw
`
`Page 00027
`
`
`
`ARTHUR ROBERT HAIR
`
`12/17/2012
`
`Page 28
`
`09:33:01
`
`09:33:15
`
`09:33:37
`
`09:34 :38
`
`09:.34 : 47
`
`MR. DiBOfSE: Subject to the objections that
`your topics.
`by SightSound to
`were interposed
`BY MS. FUKUDA:
`O Mr. Hair, you understand that you've been
`designated as Sightsound's corporate witness on these
`five topics without regard to any time limit.
`Understood?
`A That's fine.
`O Okay. For your convenience, let me just
`I
`in front of
`to put the three patents-in-suit
`would tike
`you, and you should feel free to refer to them if you
`to have them t.here for your
`I woufd like
`need to.
`reference.
`the '573 patent, which was previously
`So it's
`the '134 patent, which was previously
`Exhibit 68;
`and the '440 patent, previously
`Exhibit 69;
`Exhibit 10.
`(Discussion off the stenographic
`BY MS. FUKUDA:
`O So, Mr. Hair, you have reviewed
`patents-in-suit in their entirety
`before
`before, haven't you?
`A Yes, I have.
`O Okay. What was the most
`you had the occasion to view these
`
`marked
`
`marked
`
`marked
`
`1 2 3 4 5 6 1 B o
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`1-0
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`11
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`11II
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`1B
`
`19
`
`20
`
`21
`
`22
`
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`
`24
`
`LJ
`
`record. )
`
`the three
`
`sometime
`
`recent instance when
`patents-in-suit ?
`
`800-869-9]-32
`
`Merrj-ll- Corporation
`
`San Francisco
`ww\¡/ . merri I I corp . com/ l-aw
`
`Page 00028
`
`
`
`ARTHUR ROBERT HAIR
`
`72/rL/2012
`
`Page 29
`
`read through a
`
`A Can you describe "review"?
`O Read through them --
`A What you mean by "reviev,/"?
`O Read through them sub--
`substantial- portion.
`I'd say it's been several- years to read through
`A
`thoroughly.
`O Okay. And do you remember why you \,vere reading
`through them thoroughly several- years ago?
`A No, I don't recal-I.
`O And have you read through parts of each of
`since severaf years ago?
`these patents-in-suit
`A No.
`f understand that you had
`I
`O Now, Mr. Hair,
`that you conceived of your invention back in
`testlfied
`1986 during a friend's party;
`is that correct?
`f or a J-ega1
`MR. DiBOISE: Ob j ection; calls
`conclusion.
`THE WITNESS: I came up wlth an idea.
`or I wouldn't put it
`in
`it a J-egal
`wouldn't call
`I would just say, in layman's terms, I
`legal terms.
`came up with the idea.
`BY MS. FUKUDA:
`O Okay. And did you consider that idea t.o be
`excuse me.
`
`it
`
`the
`
`09:34 :51
`
`09:35:06
`
`09:35:36
`
`09:35:52
`
`09:36:06
`
`I
`
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`11
`I2
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`13
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`
`1tr
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`I6
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`71
`
`1B
`
`L9
`
`20
`
`27
`
`22
`
`)?
`
`24
`
`25
`
`800-869-9732
`
`Merrill Corporation
`
`San Francisco
`www . merrill- corp . com/ law
`
`Page 00029
`
`
`
`ARTHUR ROBERT HAIR
`
`12/r1/2012
`
`Page 30
`
`up with
`these
`
`consider the idea
`invent.ion that is
`
`that you came
`described in
`
`Did you
`in t9B6 to be the
`patents-in-suit
`?
`MR. DiBOISE: Objectj-on; form.
`THE VüITNESS: Are you saying did I have the
`in one moment and everything that I thought
`idea afl
`Is that what you are saying
`or as
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