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`1
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` 1 UNITED STATES DISTRICT COURT
` DISTRICT OF CONNECTICUT
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` 2
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` 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. :
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` 9
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`10 ************************************************
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`11 ORAL DEPOSITION OF
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`12 JAMIE L. THOMPSON
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`13 DECEMBER 6, 2016
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`14 ************************************************
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`15
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`16 ORAL DEPOSITION OF JAMIE L. THOMPSON, produced
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`17 as a witness at the instance of the
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`18 Plaintiff/Counterclaim Defendant, and duly sworn, was
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`19 taken in the above-styled and numbered cause on the 6th
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`20 of December, 2016, from 10:05 a.m. to 1:09 p.m., before
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`21 Shelly M. Tucker, CSR in and for the State of Texas,
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`22 reported by machine shorthand at the offices of Jackson
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`23 Walker L.L.P., 100 Congress Avenue, Suite 1100, Austin,
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`24 Texas, pursuant to the Federal Rules of Civil Procedure
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`25 and/or the provisions stated on the record.
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`DepoTexas, Inc.
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`
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`Jamie L. Thompson
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`2
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` 1 APPEARANCES
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` 2
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` 3
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` FOR THE PLAINTIFF/COUNTERCLAIM DEFENDANT:
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` 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
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` 8
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` 9
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`10
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` FOR THE DEFENDANTS/COUNTERCLAIM PLAINTIFFS:
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` 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
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`15
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`16 ALSO PRESENT:
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`17 James Thompson
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`18
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`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.
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`
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`Jamie L. Thompson
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`3
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` 1 INDEX
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` 2 PAGE
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` 3 Appearances....................................... 2
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` 4 JAMIE L. THOMPSON
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` 5 Examination by Ms. Alquist.................... 4
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` 6 Changes and Corrections........................... 78
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` 7 Signature......................................... 79
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` 8 Reporter's Certificate............................ 80
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` 9
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`10 EXHIBITS
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`11 NUMBER DESCRIPTION PAGE
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`12 Exhibit 43........................................ 6
` Notice of Deposition of Jamie L. Thompson
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`13
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`14
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`15
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`16
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`17
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`18
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`19
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`20
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`21
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`25
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`DepoTexas, Inc.
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`
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`Jamie L. Thompson
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`4
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` 1 JAMIE L. THOMPSON,
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` 2 having been first duly sworn, testified as follows:
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` 3 EXAMINATION
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` 4 BY MS. ALQUIST:
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` 10:04:55 5 Q. Good morning, Ms. Thompson.
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` 6 A. Hi.
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` 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
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` 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?
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`11 A. Yes.
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`12 Q. How many times?
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`13 A. Once.
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`14 Q. When was that?
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` 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?
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`24 A. Yes.
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` 10:06:10 25 Q. Thank you.
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`DepoTexas, Inc.
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`
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`Jamie L. Thompson
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`22
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` 1 Q. Rubicon Communications LP ceased to exist at
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` 2 some point. Is that right?
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` 3 A. No. We -- no.
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` 4 Q. So is it your testimony that Rubicon
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` 10:35:14 5 Communications LP exists today as an entity?
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` 6 A. No. We converted it to an LLC.
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` 7 Q. When was that?
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` 8 A. I believe it was June of 2014.
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` 9 Q. So while operating as Rubicon Communications
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` 10:35:35 10 LP -- which is roughly 2004 to 2014. Is that right?
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`11 A. Yes.
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`12 Q. How many -- was there a time frame where
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`13 Rubicon Communications LP had its highest number of
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`14 employees?
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` 10:35:51 15 A. That would be the day we converted to an LLC,
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`16 yeah.
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`17 Q. And how many employees in June of 2014 did
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`18 Rubicon Communications LP have?
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`19 A. Oh, boy. I would be totally guessing. And as
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` 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?
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`24 A. Yes.
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` 10:36:44 25 Q. So what -- I know you're a co-owner, but what
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`DepoTexas, Inc.
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`