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`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`--------------------------------------------X
`SOLOCRON MEDIA, LLC,
` PLAINTIFF,
` -against-
`VERIZON, et al., CELLCO PARTNERSHIP d.b.a.
`VERIZON WIRELESS, AT&T, INC., AT&T MOBILITY,
`LLC, SPRINT CORPORATION, SPRINT
`COMMUNICATIONS COMPANY, L.P., SPRINT
`SOLUTIONS, INC., and T-MOBILE USA, INC.,
` DEFENDANTS.
`--------------------------------------------X
` ***HIGHLY CONFIDENTIAL
` ATTORNEYS' EYES ONLY***
`
` DEPOSITION OF KEITH LAMPRON
` Basking Ridge, New Jersey
` Thursday, March 19, 2015
`
`Reported by:
`Rebecca Schaumloffel, RPR, CLR
`Job No: 91584
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`Page 2048-001
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`DE-DESIGNATED BY VERIZON
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`Solocron Ex. 2048 - Verizon Wireless, AT&T Mobility - IPR2015-00349
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`Page 1
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`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`--------------------------------------------X
`SOLOCRON MEDIA, LLC,
` PLAINTIFF,
` -against-
`VERIZON, et al., CELLCO PARTNERSHIP d.b.a.
`VERIZON WIRELESS, AT&T, INC., AT&T MOBILITY,
`LLC, SPRINT CORPORATION, SPRINT
`COMMUNICATIONS COMPANY, L.P., SPRINT
`SOLUTIONS, INC., and T-MOBILE USA, INC.,
` DEFENDANTS.
`--------------------------------------------X
` ***HIGHLY CONFIDENTIAL
` ATTORNEYS' EYES ONLY***
`
` DEPOSITION OF KEITH LAMPRON
` Basking Ridge, New Jersey
` Thursday, March 19, 2015
`
`Reported by:
`Rebecca Schaumloffel, RPR, CLR
`Job No: 91584
`
`TSG Reporting - Worldwide 877-702-9580
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`Solocron Ex. 2048 - Verizon Wireless, AT&T Mobility - IPR2015-00349
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` March 19, 2015
` 9:06 a.m.
`
` Deposition of KEITH LAMPRON, held at
`the DOLCE BASKING RIDGE HOTEL, 300 N. Maple
`Avenue, Basking Ridge, New Jersey, before
`Rebecca Schaumloffel, a Registered
`Professional Reporter, Certified Livenote
`Reporter and Notary Public of the State of
`New York and the State of New Jersey.
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`A P P E A R A N C E S:
`
` TENSEGRITY LAW GROUP
` Attorneys for the Plaintiff
` 555 Twin Dolphin Drive
` Redwood Shores, California 94065
` BY: ANNAKA NAVA, ESQ.
`
` WILEY REIN
` Attorneys for the Defendant
` Cellco Partnership
` 1776 K Street, N.W.
` Washington, D.C. 20006
` BY: KARIN HESSLER, ESQ.
` KEVIN ANDERSON, ESQ.
`
` ALSO PRESENT:
`
` Norman Minnear, Esq., Verizon
`
` Dale Swindell, videographer
`
` * * *
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` K. LAMPRON
` THE VIDEOGRAPHER: This is the 09:06AM
` start of media labeled number 1 of the 09:06AM
` videotaped deposition of Keith Lampron 09:06AM
` in the matter Solocron Media versus 09:07AM
` Verizon, et al. This deposition is 09:07AM
` being held at 300 North Maple Avenue, 09:07AM
` Basking Ridge, New Jersey on March 19, 09:07AM
` 2015, at approximately 9:06 a.m. 09:07AM
` My name is Dale Swindell from 09:07AM
` TSG Reporting, Incorporated. I am the 09:07AM
` certified legal specialist. The Court 09:07AM
` Reporter is Rebecca Schaumloffel in 09:07AM
` association with TSG Reporting. 09:07AM
` Will counsel please introduce 09:07AM
` yourselves. 09:07AM
` MS. NAVA: Annaka Nava from 09:07AM
` Tensegrity Law Group for plaintiff 09:07AM
` Solocron Media, LLC. 09:07AM
` MS. HESSLER: Karin Hessler from 09:07AM
` Wiley Rein for Verizon, and with me I 09:07AM
` have Kevin Anderson from the same firm 09:07AM
` and Jack Minnear who is in-house 09:07AM
` counsel with Verizon. 09:07AM
` THE VIDEOGRAPHER: Will the 09:07AM
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` K. LAMPRON
` Court Reporter please swear in the 09:07AM
` witness. 09:07AM
`K E I T H L A M P R O N, called as a
`witness, having been first duly sworn by a
`Notary Public of the State of New York, was
`examined and testified as follows:
`EXAMINATION BY
`MS. NAVA:
` Q. Good morning, Mr. Lampron. How 09:07AM
`are you? 09:07AM
` A. Good. How are you? 09:07AM
` Q. Very well, thank you. Could you 09:07AM
`please state your name and address for the 09:08AM
`record? 09:08AM
` A. Sure. It is Keith Lampron, 09:08AM
`1 Verizon Way, Basking Ridge, New Jersey. 09:08AM
` Q. And are you currently employed? 09:08AM
` A. Yes. 09:08AM
` Q. By whom? 09:08AM
` A. Verizon. 09:08AM
` Q. Do you know which entity 09:08AM
`employs you? 09:08AM
` A. Yes, it is the product and new 09:08AM
`business innovation department. 09:08AM
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` Q. Do you know which Verizon 09:08AM
`corporate entity employs you, for example, is 09:08AM
`it Cellco? 09:08AM
` A. It is known as PMB. 09:08AM
` Q. Got it. How does that relate to 09:08AM
`Cellco? 09:08AM
` A. It's a separate business unit 09:08AM
`from Verizon Wireless. 09:08AM
` Q. Is it under the same umbrella? 09:08AM
` A. It's under the Verizon corporate 09:08AM
`umbrella. 09:08AM
` Q. What is your current position? 09:08AM
` A. I am associate director for the 09:08AM
`core messaging commercial product management 09:08AM
`team. 09:08AM
` Q. How long have you had that 09:08AM
`position? 09:08AM
` A. Two and a half years. 09:08AM
` Q. What are your job 09:08AM
`responsibilities in that position? 09:08AM
` A. My primary responsibilities are 09:08AM
`to manage the current product life cycle as 09:09AM
`well as work with our product development 09:09AM
`team to set the roadmap for future products. 09:09AM
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` Q. What does core messaging 09:09AM
`commercial product management mean? 09:09AM
` A. Core messaging commercial product 09:09AM
`management is basically the commercial and 09:09AM
`product line management responsibility for 09:09AM
`all of the core messaging products which are 09:09AM
`primarily based on SMS and MMS. 09:09AM
` Q. Do you know what proportion of 09:09AM
`the core messaging products is comprised of 09:09AM
`MMS versus SMS? 09:09AM
` A. Can you be more specific as far 09:09AM
`as what proportion you are looking for? 09:09AM
` Q. With regards to your job 09:09AM
`responsibilities, how much of your job 09:09AM
`responsibilities relates to MMS versus SMS? 09:09AM
` A. That as posed is a little bit 09:09AM
`difficult to answer because for us, SMS and 09:10AM
`MMS are -- is a messaging product. We do in 09:10AM
`some cases have specific responsibilities 09:10AM
`related to one or the other, but primarily, 09:10AM
`we treat messaging as a product. 09:10AM
` Q. Verizon -- 09:10AM
` A. Both SMS and MMS. 09:10AM
` Q. So Verizon treats SMS and MMS 09:10AM
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`together as a unified product? 09:10AM
` A. From a job responsibility 09:10AM
`perspective. From a commercial product 09:10AM
`management perspective, yes. 09:10AM
` Q. What was your position before you 09:10AM
`were associate director? 09:10AM
` A. I was with the device marketing 09:10AM
`team. 09:10AM
` Q. And did you have a specific title 09:10AM
`in the device marketing team? 09:10AM
` A. I was associate director for the 09:10AM
`device marketing. 09:10AM
` Q. How long did you have that 09:10AM
`position? 09:10AM
` A. I was in that role for 09:10AM
`eight years. 09:10AM
` Q. So starting around 2005? 09:10AM
` A. 2004. 09:11AM
` Q. And what were your 09:11AM
`responsibilities in that position? 09:11AM
` A. I had responsibility for working 09:11AM
`with device manufacturers and internal 09:11AM
`organizations to establish and deliver on the 09:11AM
`device roadmap. 09:11AM
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` Q. Did this position relate to MMS? 09:11AM
` A. The position didn't specifically 09:11AM
`relate to MMS. MMS was one feature of many 09:11AM
`that was supported by the devices that we 09:11AM
`manufactured -- that we worked with the 09:11AM
`manufacturers on. 09:11AM
` Q. When you worked with device 09:11AM
`manufacturers and internal organizations to 09:11AM
`establish and deliver on device roadmaps, did 09:11AM
`that include establishing and delivering 09:11AM
`on MMS? 09:12AM
` A. MMS was one of the features that 09:12AM
`was delivered with the device, yes. 09:12AM
` Q. What was your position before you 09:12AM
`were in device marketing? 09:12AM
` A. I was with Alcatel -- or 09:12AM
`actually, at the time, it was Lucent. 09:12AM
` Q. When did you begin your position 09:12AM
`with Lucent? 09:12AM
` A. When Lucent was formed in 1996. 09:12AM
`I was part of the company prior to that, and 09:12AM
`when they split off Lucent, I was part of 09:12AM
`Lucent. 09:12AM
` Q. Can you just tell me generally 09:12AM
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`what your job responsibilities were at 09:12AM
`Lucent? 09:12AM
` A. There were a variety of roles 09:12AM
`that I was in. Quite a few. Most of them 09:12AM
`related to some form of either product 09:12AM
`management or product development. 09:12AM
` Q. Did you have the opportunity to 09:12AM
`work with MMS at all in your position at 09:12AM
`Alcatel Lucent? 09:12AM
` A. No. 09:12AM
` Q. Can you briefly describe your 09:12AM
`educational background? 09:13AM
` A. Yes. I have a bachelors and a 09:13AM
`masters of electrical engineering as well as 09:13AM
`an MBA. 09:13AM
` Q. Where did you get your MBA at? 09:13AM
` A. Cornell University. 09:13AM
` MS. NAVA: I am going to mark 09:13AM
` the first exhibit. For the record, it 09:13AM
` is the 30(b)(1) notice of 09:13AM
` Keith Lampron. 09:13AM
` (Whereupon, Lampron Exhibit 1, 09:13AM
` 30(b)(1) Notice of Keith Lampron was 09:13AM
` marked for identification as of this 09:13AM
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` K. LAMPRON
` date by the Reporter.) 09:13AM
`BY MS. NAVA: 09:13AM
` Q. Mr. Lampron, have you seen 09:13AM
`Exhibit 1 before? 09:13AM
` A. Yes, I have. 09:13AM
` Q. Do you understand that you have 09:13AM
`been noticed for your deposition today in 09:13AM
`your personal capacity for matters that are 09:13AM
`personally known to you? 09:13AM
` A. Yes, I do. 09:14AM
` Q. You can put this to the side. 09:14AM
` MS. NAVA: I would like to mark 09:14AM
` Exhibit 2, please. 09:14AM
` (Whereupon, Lampron Exhibit 2, 09:14AM
` Plaintiff 30(b)6 Notice was marked for 09:14AM
` identification as of this date by the 09:14AM
` Reporter.) 09:14AM
`BY MS. NAVA: 09:14AM
` Q. Mr. Lampron, have you seen 09:14AM
`Exhibit 2 before? 09:14AM
` A. Yes, I have. 09:14AM
` Q. Do you understand it to be 09:14AM
`plaintiff's, Solocron Media's 30(b)6 Notice 09:14AM
`of Deposition to defendant Verizon? 09:14AM
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` A. Yes, I do. 09:14AM
` Q. And do you understand that you 09:14AM
`have been designated as a 30(b)6 corporate 09:14AM
`representative of Verizon to give testimony 09:14AM
`as to specific topics delineated in 09:15AM
`Exhibit 2? 09:15AM
` A. Yes, I do. 09:15AM
` Q. And do you understand that you 09:15AM
`have been designated on Topics 11 through 15, 09:15AM
`29, 32, 44 and 45 as it relates to MMS? 09:15AM
` A. What were the last two, I am 09:15AM
`sorry? 09:15AM
` Q. I will just say them all again to 09:15AM
`be clear, if that's all right with you? 09:15AM
` A. That's fine. 09:15AM
` Q. Do you understand that you have 09:15AM
`been designated on Topics 11 through 15, 29, 09:15AM
`32, 44 and 45 as it relates to MMS? 09:15AM
` A. Yes, I do. 09:15AM
` Q. And did you prepare to give 09:15AM
`testimony relating to these topics today? 09:15AM
` A. I did. 09:16AM
` Q. What did you do to prepare? 09:16AM
` A. So there were a few things. 09:16AM
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`First off, as part of my daily 09:16AM
`responsibilities, I have a number of 09:16AM
`responsibilities and reports that are 09:16AM
`generated that I review that are related to 09:16AM
`both SMS and MMS. And the products 09:16AM
`associated with those. So that's number one. 09:16AM
` Number two, I did also do some 09:16AM
`specific homework, so to speak, for -- 09:16AM
`related to this, and speaking with a number 09:16AM
`of individuals as well as getting some 09:16AM
`additional reports and some interaction with 09:16AM
`a number of individuals. 09:16AM
` Q. Who were the individuals that you 09:16AM
`spoke with in preparation? 09:16AM
` A. Sure. So I spoke with my current 09:16AM
`director, Alice Yan -- had the same role as 09:16AM
`me prior to me taking that role in the 09:16AM
`messaging team. I spoke with Kelly Laratta 09:17AM
`who had and has responsibility for pricing 09:17AM
`and promotions. Particularly as it relates 09:17AM
`to messaging pricing and promotions. I spoke 09:17AM
`with both Jack VanderClock and Ray Hwang on 09:17AM
`device marketing to get more information 09:17AM
`about the devices as they relate to the 09:17AM
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`features that were in question. And from a 09:17AM
`finance perspective, there were a number of 09:17AM
`folks that generated some reports, and so I 09:17AM
`spoke with them as well as getting the 09:17AM
`reports from them. That was Bruce Filak, 09:17AM
`Susan Cassidy and William Quon. 09:17AM
` Q. Did you speak with anyone else in 09:17AM
`preparation for your deposition? 09:17AM
` A. Yes, I did. So in addition to 09:17AM
`that, we had a number of phone calls, E-mail 09:17AM
`discussions and face-to-face preparation with 09:18AM
`our legal team. 09:18AM
` Q. Did you speak with anyone else in 09:18AM
`preparation for the deposition? 09:18AM
` A. Just as far as the legal team 09:18AM
`itself, I spoke with Jack Minnear, 09:18AM
`Mike Holden, Kevin Anderson and Karin 09:18AM
`Hessler, and we had, again, face-to-face 09:18AM
`meetings as well as telephone calls and 09:18AM
`e-mails. 09:18AM
` Q. You mentioned that you review 09:18AM
`reports within the normal course of your job 09:18AM
`responsibilities; is that correct? 09:18AM
` A. Yes. 09:18AM
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` Q. What type of reports do you 09:18AM
`normally review as part of your job? 09:18AM
` A. Generally speaking, it's related 09:18AM
`to what we call KPIs, which are key 09:18AM
`performance indicators, and those include 09:18AM
`message volume, message revenues. We also 09:19AM
`look at customer feedback as far as, for 09:19AM
`example, the ratings of our application in 09:19AM
`various app stores, and so there are a 09:19AM
`variety of other details we look at, but 09:19AM
`those were the primary factors. 09:19AM
` Q. When you mentioned customer 09:19AM
`feedback as far as the ratings of your 09:19AM
`application, can you please explain what you 09:19AM
`mean by that? 09:19AM
` A. Yes. So we have a number of 09:19AM
`channels for receiving feedback from 09:19AM
`customers. One of them is through the 09:19AM
`application stores, both the Google Play 09:19AM
`store and the Apple app store that provide 09:19AM
`not only a number rating like, you know, four 09:19AM
`or five stars out of five stars, but also the 09:19AM
`opportunity to provide actual feedback. So 09:19AM
`we look at that primarily for the feedback 09:20AM
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`to, you know, determine what, if anything, we 09:20AM
`can do to improve our products. 09:20AM
` Q. Are you aware of customer 09:20AM
`feedback relating to MMS specifically? 09:20AM
` A. The feedback is normally general, 09:20AM
`not related specific to MMS or SMS, so it is 09:20AM
`pretty generic as far as that is concerned. 09:20AM
` Q. How does Verizon -- withdrawn. 09:20AM
` What is the terminology that 09:20AM
`Verizon uses to describe its MMS product? 09:20AM
` A. We actually call it multi-media 09:20AM
`messaging. 09:20AM
` Q. In discussing multi-media 09:20AM
`messaging, would it be always in conjunction 09:20AM
`with MMS -- so, for example, if during the 09:21AM
`deposition today I refer to Verizon's 09:21AM
`messaging product, will you understand that 09:21AM
`to mean MMS? 09:21AM
` A. No, I would understand it to mean 09:21AM
`a variety of products that use SMS and MMS as 09:21AM
`their core function. 09:21AM
` Q. So for the deposition today, I 09:21AM
`will refer to MMS as referring to only 09:21AM
`multi-media messaging and messaging products 09:21AM
`
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`to refer to those products that include MMS 09:21AM
`as well as SMS or other types of messaging. 09:21AM
` Is that okay? 09:21AM
` A. Okay. 09:21AM
` Q. And to be clear, are you aware of 09:21AM
`any customer feedback relating to MMS 09:21AM
`specifically? 09:21AM
` A. We don't carve it out 09:21AM
`specifically. As I said, there are a variety 09:21AM
`of comments that are general in nature. 09:22AM
`There are occasions where we can see that, 09:22AM
`for example, their customer is saying 09:22AM
`something about group messaging and so that's 09:22AM
`something that we would typically relate to 09:22AM
`MMS because we use a combination of SMS and 09:22AM
`MMS to deliver group messages. 09:22AM
` Q. If I were to search for documents 09:22AM
`related to customer feedback on Verizon's 09:22AM
`messaging products, what types of documents 09:22AM
`would I be looking for? 09:22AM
` A. Can you repeat that question, 09:22AM
`please? 09:22AM
` Q. Sure. Does Verizon possess 09:22AM
`documents showing customer feedback of 09:22AM
`
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` K. LAMPRON
`Verizon's messaging products? 09:22AM
` A. Documents is a little bit of a -- 09:23AM
`I guess you can say yes, because we have 09:23AM
`e-mails and the ratings are generally, you 09:23AM
`know, publicly available on Google Play and 09:23AM
`Apple app store. So I guess the answer to 09:23AM
`that question is yes. We don't have 09:23AM
`specific, you know, documents that collect 09:23AM
`that in one place. 09:23AM
` Q. When you say "e-mails," do you 09:23AM
`mean e-mails from customers or internal 09:23AM
`e-mails among Verizon employees? 09:23AM
` A. E-mails from customers. 09:23AM
` Q. Are those e-mails form e-mails 09:23AM
`pursuant to Verizon, like putting out a 09:23AM
`survey or a blank form that customers fill in 09:23AM
`or is it just random e-mails? 09:23AM
` A. Random e-mails that we get from 09:23AM
`customers. 09:23AM
` Q. Understood. Can you please 09:23AM
`describe the organizational structure of the 09:24AM
`department that you are in? 09:24AM
` A. Can you be more specific on 09:24AM
`department, as far as, I guess, how high up 09:24AM
`
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` K. LAMPRON
`you think that should go? 09:24AM
` Q. Do you have people who report 09:24AM
`to you? 09:24AM
` A. I do, yes. 09:24AM
` Q. How many? 09:24AM
` A. I have two. 09:24AM
` Q. Two direct reports? 09:24AM
` A. Yes. 09:24AM
` Q. And how many people are under 09:24AM
`those direct reports, either directly or 09:24AM
`indirectly? 09:24AM
` A. It's just those two. 09:24AM
` Q. And then do you report to 09:24AM
`someone? 09:24AM
` A. Yes. 09:24AM
` Q. And -- 09:24AM
` A. That's my director Alex Yan that 09:24AM
`I mentioned earlier. 09:24AM
` Q. Who does Alex Yan report to? 09:24AM
` A. She reports to Alissa Van Volkom. 09:24AM
` Q. Understood. If you can please 09:24AM
`turn to Exhibit 2, that's the Deposition 09:24AM
`Notice. And I would like to start with 09:25AM
`Topic 11 that is on page 6. Topic 11 says, 09:25AM
`
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`"Identification of all telephones and mobile 09:25AM
`devices identified in Topic No. 10 featuring 09:25AM
`a WAP or other web browser capable of 09:25AM
`connecting to an Internet site." 09:25AM
` And I understand that you are 09:25AM
`prepared to talk about this? 09:25AM
` A. Yes, I am. 09:25AM
` Q. Do you recall who you spoke with, 09:25AM
`if anyone, regarding your preparation of this 09:25AM
`specific topic? 09:25AM
` A. This was primarily Ray Hwang and 09:25AM
`Jack VanderClock that I mentioned earlier. 09:25AM
` Q. What did Ray Hwang tell you 09:25AM
`regarding this topic? 09:25AM
` A. He is responsible for a database 09:25AM
`that provides a history, so to speak, of the 09:25AM
`devices that have launched as well as 09:26AM
`upcoming devices. 09:26AM
` Q. Do you know the name of that 09:26AM
`database? 09:26AM
` A. Pretty sure it is the device 09:26AM
`database. 09:26AM
` Q. What else did Ray Hwang tell you 09:26AM
`about this topic? 09:26AM
`
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` K. LAMPRON
` A. Basically, he mentioned that it 09:26AM
`only goes back to, I believe it is 2011. I 09:26AM
`think that's when they started that database, 09:26AM
`so, you know -- you know, that's as far as 09:26AM
`back as he can go with that. 09:26AM
` Q. Are you aware of whether, prior 09:26AM
`to the device database, there was another 09:26AM
`method of tracking phones that have launched? 09:26AM
` A. Yes, I am. 09:26AM
` Q. What was that method? 09:26AM
` A. That -- the method that I was 09:26AM
`able to uncover by talking with 09:26AM
`Jack VanderClock was the feature list, device 09:26AM
`feature list that he produced that listed 09:27AM
`essentially all of the devices as well 09:27AM
`against the whole set of features that they 09:27AM
`supported. 09:27AM
` Q. Do you know who created the 09:27AM
`device feature list? 09:27AM
` A. That was Jack himself that kept 09:27AM
`those. 09:27AM
` Q. Do you know how long Jack has 09:27AM
`been working at Verizon? 09:27AM
` A. I don't. But I know he has been 09:27AM
`
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` K. LAMPRON
`here since before me so quite a long time. 09:27AM
` Q. And did Jack Hwang mention -- 09:27AM
` A. Jack VanderClock. 09:27AM
` Q. Excuse me. Did Jack VanderClock 09:27AM
`mention how long the device feature list has 09:27AM
`been maintained? 09:27AM
` A. I know it went back as far as 09:27AM
`2007. And he discontinued it after the 09:27AM
`device database was put in place. 09:28AM
` Q. Did I get that right, was it 09:28AM
`Jack VanderClock who discussed the device 09:28AM
`feature list or was it Ray Hwang? 09:28AM
` A. Ray is database. Jack is the 09:28AM
`device feature list. 09:28AM
` Q. Thank you. Did Mr. VanderClock 09:28AM
`give you any other factual information in 09:28AM
`preparation for your deposition today with 09:28AM
`regards to Topic 11? 09:28AM
` A. It was focused on that device 09:28AM
`feature list.
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