`
`1
`
` 1 UNITED STATES DISTRICT COURT
` DISTRICT OF CONNECTICUT
`
` 2
`
` LEGO SYSTEMS A/S :
` 3 :
` Plaintiff/Counterclaim- :
` 4 Defendant, :
` :
` 5 v. : Civil Action No.
` : 3:15-CV-00823-VLB
` 6 RUBICON COMMUNICATIONS, LP :
` DBA SMALLWORKS AND :
` 7 SMALLWORKS, LLC :
` :
` 8 Defendant/Counterclaim- :
` Plaintiff. :
`
` 9
`
`10 ************************************************
`
`11 ORAL DEPOSITION OF
`
`12 JAMIE L. THOMPSON
`
`13 DECEMBER 6, 2016
`
`14 ************************************************
`
`15
`
`16 ORAL DEPOSITION OF JAMIE L. THOMPSON, produced
`
`17 as a witness at the instance of the
`
`18 Plaintiff/Counterclaim Defendant, and duly sworn, was
`
`19 taken in the above-styled and numbered cause on the 6th
`
`20 of December, 2016, from 10:05 a.m. to 1:09 p.m., before
`
`21 Shelly M. Tucker, CSR in and for the State of Texas,
`
`22 reported by machine shorthand at the offices of Jackson
`
`23 Walker L.L.P., 100 Congress Avenue, Suite 1100, Austin,
`
`24 Texas, pursuant to the Federal Rules of Civil Procedure
`
`25 and/or the provisions stated on the record.
`
`DepoTexas, Inc.
`
`
`
`Jamie L. Thompson
`
`2
`
` 1 APPEARANCES
`
` 2
`
` 3
`
` FOR THE PLAINTIFF/COUNTERCLAIM DEFENDANT:
`
` Elizabeth A. Alquist
` 4 Woo Sin Sean Park
` DAY PITNEY LLP
` 5 242 Trumbull Street
` Hartford, Connecticut 06103-1212
` 6 Telephone: 860-275-0100
` Fax: 860-275-0343
` 7 Email: eaalquist@daypitney.com
` wpark@daypitney.com
`
` 8
`
` 9
`
`10
`
` FOR THE DEFENDANTS/COUNTERCLAIM PLAINTIFFS:
`
` Ryan T. Beard
`11 MEYERTONS HOOD KIVLIN KOWERT & GOETZEL
` 1120 South Capital of Texas Highway
`12 Building 2, Suite 300
` Austin, Texas 78746
`13 Telephone: 512-853-8800
` Fax: 512-853-8801
`14 Email: rbeard@intprop.com
`
`15
`
`16 ALSO PRESENT:
`
`17 James Thompson
`
`18
`
`19
`
`20
`
`21
`
`22
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`23
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`24
`
`25
`
`DepoTexas, Inc.
`
`
`
`Jamie L. Thompson
`
`3
`
` 1 INDEX
`
` 2 PAGE
`
` 3 Appearances....................................... 2
`
` 4 JAMIE L. THOMPSON
`
` 5 Examination by Ms. Alquist.................... 4
`
` 6 Changes and Corrections........................... 78
`
` 7 Signature......................................... 79
`
` 8 Reporter's Certificate............................ 80
`
` 9
`
`10 EXHIBITS
`
`11 NUMBER DESCRIPTION PAGE
`
`12 Exhibit 43........................................ 6
` Notice of Deposition of Jamie L. Thompson
`
`13
`
`14
`
`15
`
`16
`
`17
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`18
`
`19
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`20
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`21
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`22
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`23
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`24
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`25
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`DepoTexas, Inc.
`
`
`
`Jamie L. Thompson
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`4
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` 1 JAMIE L. THOMPSON,
`
` 2 having been first duly sworn, testified as follows:
`
` 3 EXAMINATION
`
` 4 BY MS. ALQUIST:
`
` 10:04:55 5 Q. Good morning, Ms. Thompson.
`
` 6 A. Hi.
`
` 7 Q. My name is Beth Alquist. I represent LEGO in
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` 8 the lawsuit between your companies, and I'm going to
`
` 9 ask you a series of questions today. I'm going to
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` 10:05:08 10 start with one. Have you ever been deposed before?
`
`11 A. Yes.
`
`12 Q. How many times?
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`13 A. Once.
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`14 Q. When was that?
`
` 10:05:13 15 A. I don't recall at this time, but it was
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`16 probably within the last six years.
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`17 Q. What was the nature of the deposition?
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`18 A. It was a trademark dispute.
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`19 Q. Who was involved in the trademark dispute?
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` 10:05:48 20 A. Rubicon Communications and AT&T. Technically
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`21 I guess it was one of their holding companies.
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`22 Q. When you said "one of their holding
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`23 companies," you mean AT&T?
`
`24 A. Yes.
`
` 10:06:10 25 Q. Thank you.
`
`DepoTexas, Inc.
`
`
`
`Jamie L. Thompson
`
`22
`
` 1 Q. Rubicon Communications LP ceased to exist at
`
` 2 some point. Is that right?
`
` 3 A. No. We -- no.
`
` 4 Q. So is it your testimony that Rubicon
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` 10:35:14 5 Communications LP exists today as an entity?
`
` 6 A. No. We converted it to an LLC.
`
` 7 Q. When was that?
`
` 8 A. I believe it was June of 2014.
`
` 9 Q. So while operating as Rubicon Communications
`
` 10:35:35 10 LP -- which is roughly 2004 to 2014. Is that right?
`
`11 A. Yes.
`
`12 Q. How many -- was there a time frame where
`
`13 Rubicon Communications LP had its highest number of
`
`14 employees?
`
` 10:35:51 15 A. That would be the day we converted to an LLC,
`
`16 yeah.
`
`17 Q. And how many employees in June of 2014 did
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`18 Rubicon Communications LP have?
`
`19 A. Oh, boy. I would be totally guessing. And as
`
` 10:36:27 20 a complete guess, I would say somewhere between 20 and
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`21 25.
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`22 Q. And did all of those employees ultimately
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`23 report to you?
`
`24 A. Yes.
`
` 10:36:44 25 Q. So what -- I know you're a co-owner, but what
`
`DepoTexas, Inc.
`
`
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