`Corel Software, LLC v. Microsoft Corporation
`
`Page 1
`
` IN THE UNITED STATES DISTRICT COURT
` FOR THE DISTRICT OF UTAH, CENTRAL DIVISION
`_______________________________________________________
`COREL SOFTWARE, LLC, )
` )
` Plaintiff, )
` )
` vs. ) No. 2:15-cv-00528-JNP-PMW
` )
`MICROSOFT CORPORATION, )
` )
` Defendant. )
` )
`_______________________________________________________
` VIDEOTAPED
` 30(B)(6) DEPOSITION UPON ORAL EXAMINATION
` OF
` JIM ROSS
` INDIVIDUALLY
` AND AS
` MICROSOFT 30(B)(6) DESIGNEE
` HIGHLY CONFIDENTIAL
`_______________________________________________________
` Taken at: 10885 NE Fourth Street
` Bellevue, Washington
`
`DATE TAKEN: April 22, 2016
`REPORTED BY: ELIZABETH PATTERSON HARVEY, RPR, CCR 2731
`
`Depo International
`800-591-9722
`
`Corel Exhibit 2015
`Microsoft v. Corel
`IPR2016-01084
`
`
`
`Jim Ross
`Corel Software, LLC v. Microsoft Corporation
`
`Page 96
`Jensen Harris on February 15, 2008, "We patented galleries
`but not specifically Live Preview last release. WordPerfect
`actually had Live Preview functionality in an earlier" --
`excuse me -- "in earlier versions."
` Did I read that correctly?
` A After you corrected yourself, yes.
` Q Yes. Were you part of discussions with Aaron
`Butcher on whether to preview Live Preview?
` A I don't recall any.
` Q Do you know if anyone at Microsoft was part of
`discussions with Mr. Butcher on whether to preview -- excuse
`me -- patent Live Preview?
` A I'm not aware of any.
` Q Would it generally be Microsoft's policy not to
`try and patent something where a competitor has similar
`functionality in earlier versions?
` A Well, it varies.
` Q What does it vary depending on?
` A If we've made an improvement to the competitor's
`functionality, then that is something that could be
`patented.
` Q If you haven't made an improvement on the
`functionality, does that mean would you not seek patent
`protection on it?
` A If it's the same as something that was previously
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`Depo International
`800-591-9722
`
`
`
`Jim Ross
`Corel Software, LLC v. Microsoft Corporation
`
`Page 97
`shipped, then you wouldn't be able to get a patent on it.
` Q Mr. Hatfield notes in his email that he has a
`"predisclosure that I may want to list it as a related
`patent for, if so."
` Does Microsoft have a standard predisclosure form
`that employees fill out when they may want to patent a
`feature?
` A We have several different predisclosure forms.
` Q Are they used in different scenarios?
` A Yes. They are used in different scenarios.
` Q What are the different scenarios that they're used
`in?
` A Individual patent attorneys would vary the
`predisclosure forms to suit their business.
` Q So would the Office division have a specific
`predisclosure form?
` A It probably used one or two, or maybe three.
` Q Did those predisclosure forms ask for known prior
`art?
` A I believe there was usually a section that talked
`about the improvement over the prior art.
` Q Were employees asked to investigate prior art?
` A There's no policy on that.
` Q Were they discouraged from investigating prior
`art?
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`Depo International
`800-591-9722
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