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` UNITED STATES DISTRICT COURT
` EASTERN DISTRICT OF TEXAS
` MARSHALL DIVISION
`
`SOLOCRON MEDIA, LLC,
` Plaintiff,
`vs. Case No.
`VERIZON, et al., CELLCO PARTNERSHIP 2:13-CV-1059-JRG
`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.
`
` HIGHLY CONFIDENTIAL
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` 30(b)(6) DEPOSITION OF VERIZON
` DESIGNEE: EDWARD RUTH
` Redwood Shores, California
` Tuesday, March 3, 2015
`
`REPORTED BY:
`JANIS JENNINGS, CSR 3942, CLR, CCRR
`JOB NO. 91064
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`Solocron Ex. 2016 - Verizon Wireless, AT&T Mobility - IPR2015-00390
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`Page 1
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` UNITED STATES DISTRICT COURT
` EASTERN DISTRICT OF TEXAS
` MARSHALL DIVISION
`
`SOLOCRON MEDIA, LLC,
` Plaintiff,
`vs. Case No.
`VERIZON, et al., CELLCO PARTNERSHIP 2:13-CV-1059-JRG
`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.
`
` HIGHLY CONFIDENTIAL
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` 30(b)(6) DEPOSITION OF VERIZON
` DESIGNEE: EDWARD RUTH
` Redwood Shores, California
` Tuesday, March 3, 2015
`
`REPORTED BY:
`JANIS JENNINGS, CSR 3942, CLR, CCRR
`JOB NO. 91064
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` VIDEOTAPED DEPOSITION OF EDWARD RUTH, taken
` on behalf of the Plaintiff, at 333 Twin Dolphin
` Drive, Suite 200, Redwood Shores, California,
` commencing at 9:12 a.m., Tuesday, March 3, 2015,
` before Janis Jennings, Certified Shorthand Reporter
` No. 3942, CLR, CCRR.
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` A P P E A R A N C E S:
`
` Attorneys for Plaintiff:
` TENSEGRITY LAW GROUP
` 555 Twin Dolphin Drive
` Redwood Shores, California 94065
` BY: WILLIAM NELSON, ESQ.
`
` On Behalf of Defendant Verizon:
` WILEY REIN
` 1776 K Street NW
` Washington, DC 20006
` BY: KEVIN ANDERSON, ESQ.
`
` ALSO PRESENT:
` JACK MINNEAR, ESQ., Verizon
` DWAYNE GROTH, Videographer
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` I N D E X
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`WITNESS
`30(b)(6) VERIZON
`DESIGNEE: EDWARD RUTH
`
` EXAMINATION
` BY MR. NELSON 7
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` E X H I B I T S
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`Page 5
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`NUMBER DESCRIPTION PAGE
`Exhibit 1 PowerPoint "Verizon Music"; 20
` VZW_SOLOCRON_00086742 - 86771
`
`Exhibit 2 Excel Spreadsheet; 29
` VZW_SOLOCRON_00151548 - 151656
`
`Exhibit 3 Real Networks Briefing Doc; 50
` VZW_SOLOCRON_00087973 - 87974
`
`Exhibit 4 PowerPoint "Tones & RBT Reporting" 55
` August 2009;
` VZW_SOLOCRON_00088177 - 88196
`
`Exhibit 5 PowerPoint "Tones & RBT Reporting" 60
` November 2011;
` VZW_SOLOCRON_00090699 - 90711
`
`Exhibit 6 PowerPoint "Music Business Review"; 65
` VZW_SOLOCRON_00142873 - 142893
`
`Exhibit 7 PowerPoint "2012 Kick-off Meeting"; 74
` VZW_SOLOCRON_00090227 - 90251
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` REDWOOD SHORES, CALIFORNIA; TUESDAY, MARCH 3, 2015;
` 9:12 A.M.
` 09:11
` THE VIDEOGRAPHER: Good morning. This is 09:11
`the start of disk 1 of the deposition of Edward Ruth 09:11
`in the matter of Solocron Media LLC versus Verizon, 09:11
`et al., in the United States District Court, Eastern 09:11
`District of Texas, Marshall Division, case number 09:11
`2:13-CV-1059-JRG. 09:11
` This deposition is being held at 333 Twin 09:12
`Dolphin Drive in Redwood Shores, California, 09:12
`on Tuesday, March 3rd, 2015, at approximately 09:12
`9:12 a.m. 09:12
` My name is Dwayne Groth from TSG Reporting 09:12
`Incorporated, and I'm the legal video specialist. 09:12
`The court reporter is Janis Jennings in association 09:12
`with TSG Reporting. 09:12
` Will all counsel please introduce yourselves 09:12
`for the record. 09:12
` MR. NELSON: William Nelson of Tensegrity 09:12
`Law Group on behalf of plaintiff Solocron Media. 09:12
` MR. ANDERSON: Kevin Anderson from Wiley 09:12
`Rein on behalf of the defendant Verizon entities, 09:12
`and with me I have Verizon's in-house counsel, 09:12
`Jack Minnear. 09:12
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` THE VIDEOGRAPHER: Will the court reporter 09:12
`please swear in the witness. 09:12
`
` EDWARD RUTH,
` the witness herein, was sworn and
` testified as follows:
`
` THE VIDEOGRAPHER: You may proceed. 09:13
` 09:13
` EXAMINATION 09:13
`BY MR. NELSON: 09:13
` Q. Good morning, Mr. Ruth. Thanks for coming 09:13
`in. 09:13
` A. Good morning. 09:13
` Q. Have you ever had your deposition taken 09:13
`before? 09:13
` A. I have. 09:13
` Q. Okay. How many times? 09:13
` A. Once. 09:13
` Q. Once. Okay. Can you tell me at a high 09:13
`level whether the previous time you had your 09:13
`deposition taken involved a litigation involving 09:13
`Verizon. 09:13
` A. Yes. It was with Verizon. 09:13
` Q. Okay. Was it a patent litigation? 09:13
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` A. No. 09:13
` Q. Okay. How long ago was that deposition? 09:13
` A. I will give you an approximation. My memory 09:13
`is foggy back then. It's probably 2008ish, 2007, 09:13
`so, yeah, eight years; seven, eight years. 09:13
` Q. What was the subject matter, at a high 09:13
`level, of your deposition? 09:13
` A. It was a publishing license, so I believe it 09:13
`was ASCAP/BMI. Or -- yeah. Yes, ASCAP/BMI. 09:14
` Q. Was it in connection with downloadable 09:14
`ringtones? 09:14
` A. It was either ringtones, ringback tones or 09:14
`full track music. It was one of the three. 09:14
` Q. Okay. Well, I would like to briefly go over 09:14
`some of the ground rules for the deposition today 09:14
`with you, if I can, please. 09:14
` First of all, do you understand that you are 09:14
`under oath today? 09:14
` A. I do. 09:14
` Q. Okay. Do you understand that the court 09:14
`reporter is taking down every question that I ask 09:14
`and every answer that you give? 09:14
` A. I do. 09:14
` Q. Okay. You're already pretty good at it, but 09:14
`will you try to give a verbal answer instead of, you 09:14
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`know, shaking your head, nodding or shrugging, 09:14
`because it helps to make a record. 09:14
` A. Yes. 09:14
` Q. Thank you. If there is anything you don't 09:14
`understand about a question of mine, will you just 09:14
`let me know, please? 09:14
` A. Yes. 09:14
` Q. Okay. If you need a break at any time, I'm 09:14
`happy to take one. Will you just please let me 09:15
`know? 09:15
` A. Yes. 09:15
` Q. Okay. Is there any reason you can think of 09:15
`why you can't proceed with your deposition today? 09:15
` A. Nope. 09:15
` Q. Okay. Did you meet with your counsel to 09:15
`prepare for your deposition today? 09:15
` A. I have, yes. 09:15
` Q. Okay. How many times have you met with 09:15
`counsel? 09:15
` A. We've had a number of phone calls, and we 09:15
`spent a good deal of time together yesterday in 09:15
`person. 09:15
` Q. Okay. Was yesterday's meeting with 09:15
`Mr. Anderson? 09:15
` A. No. 09:15
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` Q. Who did you meet with? 09:15
` A. Oh, excuse me. Yes, it was. The names of 09:15
`my attorneys are sort of fresh to mind, so -- 09:15
` Q. Sure. I can ask a better question. So you 09:15
`met in person with Mr. Anderson yesterday? 09:15
` A. Yes. 09:15
` Q. Was Mr. Minnear present? 09:15
` A. Yes. 09:15
` Q. Okay. Was any other attorney for Verizon 09:15
`present? 09:15
` A. There was one other attorney present via 09:15
`phone; I think part of our outside counsel. 09:16
` Q. Miss Hessler? 09:16
` A. Yes. 09:16
` Q. Okay. Did you review any documents 09:16
`yesterday in preparation for testimony? 09:16
` A. I did. 09:16
` Q. Did you review any that reviewed your 09:16
`recollection on facts? 09:16
` A. Yes. 09:16
` Q. What documents were those ones? 09:16
` A. I don't remember the exact documents, but 09:16
`they were documents that were related to actual 09:16
`figures that were reported from our data warehouse 09:16
`on revenues and units sold of our ringtones, also 09:16
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`some operational documents that were presented as 09:16
`part of the course of doing business as well as some 09:16
`third-party documents that sort of showed state of 09:16
`the union or state of the industry itself. 09:16
` Q. Okay. Anything else? 09:16
` A. There may have been a few others. 09:16
` Q. Okay. 09:16
` A. Those are the ones I recall. 09:16
` Q. Do you understand that you're here today as 09:16
`Verizon's designated representative on certain 09:17
`topics for which my client, Solocron, requested that 09:17
`Verizon present a witness? 09:17
` A. Yes. 09:17
` MR. NELSON: Okay. I'm happy to take a 09:17
`representation from you, Kevin, as to what those 09:17
`topics are. Is -- I can read them to you. Is 09:17
`Mr. Ruth here today, subject to your objections, 09:17
`regarding topics 30, 33, 35, and 43? 09:17
` MR. ANDERSON: Yes. Also, I think, on 36 09:17
`there's some clarification about whether 36 intended 09:17
`to encompass vendor agreements or, like, litigation 09:17
`licenses. If it's litigation licenses, it's not 09:17
`him. If it's vendor agreements, which I think 09:17
`actually is one of the prior ones -- 09:17
` MR. NELSON: Yeah. 09:18
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` MR. ANDERSON: -- then it is him. 09:18
` MR. NELSON: Okay. So he's on 36? 09:18
` MR. ANDERSON: For vendor agreements, yeah. 09:18
` MR. NELSON: Okay. 09:18
` MR. ANDERSON: But I think 35 is already 09:18
`vendor agreements, so you have got him already on 09:18
`that. 09:18
` MR. NELSON: Okay. Thank you. 09:18
`BY MR. NELSON: 09:18
` Q. So are you an employee of Verizon? 09:18
` A. I am. 09:18
` Q. Which entity? 09:18
` A. I'm not sure exactly which entity. I know 09:18
`that I work for Verizon and I do a good deal of work 09:18
`on their behalf. 09:18
` Q. Okay. The only reason I ask is I just want 09:18
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`and I don't want there to be any confusion between 09:18
`us. 09:18
` A. Understood. 09:18
` Q. Okay. Thank you. So could you tell me your 09:18
`job title, please, today, your current job title. 09:18
` A. New business development and partner 09:18
`development. 09:18
` Q. How long have you had that title? 09:18
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` A. Well, that job description has probably 09:18
`morphed and changed over the last three, three and a 09:19
`half years, but that's approximately how long I have 09:19
`been in this particular role. 09:19
` Q. Okay. Since about 2011? 09:19
` A. Yes. 09:19
` Q. Okay. 09:19
` A. Later -- later half of 2011. 09:19
` Q. What are your responsibilities in connection 09:19
`with your title of new business development and 09:19
`partner development? 09:19
` A. My core responsibility is to look for new 09:19
`markets and new business opportunities for Verizon 09:19
`and then determine how we get to market, whether 09:19
`that be through partnership and, if it is, structure 09:19
`those relationships or investment or acquisition, in 09:19
`which case I would partner with other parts of the 09:19
`organization. 09:19
` Q. Are you a technical person? 09:19
` A. Reasonably. I'm not an engineer. 09:19
` Q. Do your responsibilities -- so are you a 09:20
`director-level employee? 09:20
` A. Uh-huh. Yes. 09:20
` Q. Okay. Did your responsibilities in new 09:20
`business development and partnerships -- let me see 09:20
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`if I got that right -- partner development include 09:20
`responsibility for ringtones? 09:20
` A. Not currently, no. 09:20
` Q. Let's make sure we're sharing a common 09:20
`vocabulary. Do you know what a "ringtone" is, sir? 09:20
` A. Yeah. It's essentially a sample of a song 09:20
`that's delivered to a mobile device to be used as a 09:20
`ringer instead of the standard ringer on the device. 09:20
` Q. Okay. Is it the case that as we sit here 09:20
`today Verizon makes available to Verizon subscribers 09:20
`ringtones for purchase and download to Verizon 09:20
`subscriber units? 09:21
` A. Yes. 09:21
` Q. Okay. But -- and I'm just trying to 09:21
`clarify. Today your responsibilities don't include 09:21
`ringtones? 09:21
` A. Today my responsibilities do not include 09:21
`ringtones. 09:21
` Q. Have they ever included ringtones? 09:21
` A. Yes. 09:21
` Q. Okay. So when have your responsibilities 09:21
`included ringtones? 09:21
` A. Approximately the years 2005 through 2009, 09:21
`2010 approximately. I don't remember at which point 09:21
`I moved to a new role specifically, but it was 09:21
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`around 2009, 2010. 09:21
` Q. Okay. And so let's move backward in time a 09:21
`little bit in terms of your jobs. 09:21
` A. Uh-huh. 09:21
` Q. Prior to taking on the position the second 09:21
`half of 2011 relating to new business development 09:21
`and partner development, what was your title at 09:21
`Verizon? 09:21
` A. I will give you a little for continuity and 09:21
`context. 2005 originally was -- my responsibility 09:21
`was solely music. It was a set of four products: 09:22
`ringtones, ringback tones, we sold music videos, and 09:22
`we also sold downloadable full tracks. From there, 09:22
`approximately in 2007, 2008 I took on the additional 09:22
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`sort of product lines that required business 09:22
`development activities and extended that work 09:22
`through to 2009, 2010. 09:22
` Q. Okay. And so you transitioned off of 09:22
`responsibility for ringtones around 2009 or 2010, if 09:22
`I understand? 09:22
` A. Uh-huh. Yes. 09:22
` Q. Okay. So during the -- and when did you 09:22
`start at Verizon? 09:22
` A. 2000. 09:22
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`TSG Reporting - Worldwide (877) 702-9580
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`Page 16
` Q. 2000? Okay. And when did you first take on 09:23
`a role at Verizon that included some responsibility 09:23
`for Verizon's ringtone stores? 09:23
` A. That was 2005. 09:23
` Q. Okay. And so that period between 2005 and, 09:23
`let's say, 2009 where you had some responsibility 09:23
`for ringtones, what was the nature of your 09:23
`responsibilities? 09:23
` A. I had essentially all the responsibility, 09:23
`everything but specifically the product design. So 09:23
`I was responsible for the marketing. I was 09:23
`responsible for the licensing of the content that 09:23
`was sold through the store. And I was responsible 09:23
`for some aspects of the -- some sponsorship or 09:23
`marketing of that content and, joint -- jointly with 09:23
`the product team, helped design some of the user 09:23
`experience. 09:23
` Q. By "user experience," do you mean the user 09:23
`experience, let's say, on the client side of looking 09:24
`for and purchasing ringtones? 09:24
` A. Yeah. It's commonly referred to as "UX," 09:24
`but it's sort of the user experience design of, you 09:24
`know, what is the appropriate number of clicks as an 09:24
`example to get the content on the phone, really 09:24
`optimizing for user design, user experience. 09:24
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` DEPOSITION ERRATA SHEET
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` TSG Reporting Assignment No. 91064
` Case Caption: Solocron Media vs. Verizon, et al.
`
` DECLARATION UNDER PENALTY OF PERJURY
` I declare under penalty of perjury
` that I have read the entire transcript of
` my Deposition taken in the captioned matter
` or the same has been read to me, and the same
` is true and accurate, save and except for changes and/or
` corrections, if any, as indicated by me on the
` DEPOSITION ERRATA SHEET hereof, with the understanding
` that I offer these changes as if still under oath.
`
` Signed on the ______ day of ____________, 20___.
`
` ___________________________________
` EDWARD RUTH
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`HIGHLY CONFIDENTIAL
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` DEPOSITION ERRATA SHEET
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` Page No._____Line No._____Change to:______________
` __________________________________________________
` Reason for change:________________________________
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` Reason for change:________________________________
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` Reason for change:________________________________
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` __________________________________________________
` Reason for change:________________________________
` Page No._____Line No._____Change to:______________
` __________________________________________________
` Reason for change:________________________________
` SIGNATURE:_______________________DATE:___________
` EDWARD RUTH
`
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`DE-DESIGNATED BY VERIZON
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