Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`ESTTA330169
`ESTTA Tracking number:
`02/02/2010
`
`Filing date:
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`91172885
`Defendant
`Hindustan Lever Limited
`Robert Alpert
`BRYAN CAVE LLP
`1290 Avenue of the Americas
`New York, NY 10104
`UNITED STATES
`tcrodriguez@bryancave.com
`Other Motions/Papers
`Teresa C. Rodriguez
`tcrodriguez@bryancave.com
`/teresa c. rodriguez/
`02/02/2010
`Exhibit C to Declaration of R. Alpert-Opp.No. 91172885.pdf ( 214 pages
`)(11522563 bytes )
`
`Proceeding
`Party
`
`Correspondence
`Address
`
`Submission
`Filer's Name
`Filer's e-mail
`Signature
`Date
`Attachments
`
`
`ESTTA330169
`ESTTA Tracking number:
`02/02/2010
`
`Filing date:
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`91172885
`Defendant
`Hindustan Lever Limited
`Robert Alpert
`BRYAN CAVE LLP
`1290 Avenue of the Americas
`New York, NY 10104
`UNITED STATES
`tcrodriguez@bryancave.com
`Other Motions/Papers
`Teresa C. Rodriguez
`tcrodriguez@bryancave.com
`/teresa c. rodriguez/
`02/02/2010
`Exhibit C to Declaration of R. Alpert-Opp.No. 91172885.pdf ( 214 pages
`)(11522563 bytes )
`
`Proceeding
`Party
`
`Correspondence
`Address
`
`Submission
`Filer's Name
`Filer's e-mail
`Signature
`Date
`Attachments
`
`
`
`
`
`EXHIBIT C
`EXHIBIT C
`
`
`
`
`
`
`
`1 Certified Copy
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`AYUSH HERBS, INC,
`
`Opposer,
`
`vs.
`
`HINDUSTAN LEVER LTD. CO.,
`
`Applicant.
`
`Opposition No. 91,172,885
`Serial No. 76/602,470
`
`30(b)(6) DEPOSITION OF
`
`DR. SHAILINDER SODHI
`
`January 7, 2010
`9:25 a.m.
`
`Suite 4300, 161 North Clark Street
`Chicago, Illinois
`
`LISA SCHWAM, CSR No. 8404650
`Notary Public within and for the
`County of Cook, State of Illinois, and a
`Certified Shorthand Reporter
`
` Telephone:
`
`212.687.8010
`800.944.9454
`Toll Free:
`212.557.5972
`Facsimile:
`One Penn Plaza
`
`Suite 4715
`New Y0rk,N.Y.101 19
`
`
`
`
`
`
`
`
`1
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Opposition No. 91,172,885
`
`Serial No. 76/602,470
`
`) \
`
`./
`
`)
`
`)
`
`)
`
`AYUSH HERBS,
`
`I NC.,
`
`Opposer,
`
`Vs.
`
`HINDUSTAN LEVER LTD. CO.,
`
`Applicant.
`
`The 30(b)(6) depositio
`
`n of DR. SHAILINDER
`
`SODHI, called for examination,
`
`t
`
`aken pursuant to the
`
`Federal Rules of Civil Procedure
`
`f the United States
`
`District Court pertaining to the
`
`taking of depositions,
`
`taken before LISA SCHWAM, CSR No.
`
`840-4650, a Notary
`
`Public within and for the County
`
`of Cook, State of
`
`Illinois, and a Certified Shorthand Reporter of said
`
`state, at Bryan Cave, LLP, Suite 4300, 161 North Clark
`
`Street, Chicago, Illinois, commencing, on the 7th day of
`
`January, A.D. 2010, at 9:25 a.m.
`
`
`ESQUIRE
`
`an Alexander Gallo Company
`
`Toll Free: 800.944.9454
`Facsimile: 212.557.5972
`
`Suite 4715
`One Penn Haza
`New York, NY 10119
`www.esquiresoIutions.com
`
`
`
`Dr. Shailinder Sodhi
`
`January 7,
`
`2010
`
`U.)N
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`PRESENT:
`
`AMIN TALATI,
`
`(444 North Orleans Street, Fourth Floor,
`
`Chicago, Illinois
`
`60654,
`
`312—466—1033), by:
`
`MR. RYAN M. KAISER,
`
`ryan@amintalati.com, and
`
`MR. RAKESH M. AMIN,
`
`rakesh@amintalati.com,
`'I.C
`appeared on behaii of the Opposer;
`
`BRYAN CAVE, LLP,
`
`(1290 Avenue of the Americas,
`
`New York, New York
`
`10104-3300,
`
`212-541-1292), by:
`
`MR. ROBERT ALPERT,
`
`robert.a1pert@bryancave.com, and
`
`MR.
`
`JOSEPH VILLAPOL,
`
`joseph.villapol@bryancave.com,
`
`appeared on behalf of the Applicant.
`
`
`ESQUIRE
`
`an Alexander Gallo Cmnpany
`
`Toll Free: 800.944.9454
`Facsimile: 212.557.5972
`
`Suite 4715
`One Penn Maza
`New York, NY 10119
`www.esquireso|utions.com
`
`
`
`Dr. Shailinder Sodhi
`
`January 7,
`
`2010
`
`3
`
`(WflEREUPON,
`
`the witness was sworn.)
`
`SHAILINDER SODHI,
`
`called as a witness herein, having been first duly sworn,
`
`was examined and testified as follows;
`
`EXAMINATION
`
`BY MR. ALPERT:
`
`Q.
`
`Dr. Sodhi, would you please take a look at what
`
`was marked yesterday in connection with your deposition
`
`as president of Ayush Herbs at Exhibit No. 3, please.
`
`A
`
`Istmmtmesmm<me?
`
`20
`
`Yes.
`
`Have you seen this document before today?
`
`A.
`
`Yes.
`
`Q.
`
`A.
`
`When did you first see it?
`
`You know, it was sometime in December the guy
`
`came to my clinic.
`
`So I don't know the date, but
`
`I
`
`probably signed on that day,
`
`so I don't know which of the
`
`date.
`
`It was sometime 7th.
`
`I don't know.
`
`December 7th. You can probably tell.
`
`Q.
`
`A.
`
`And he handed you a copy of this, correct?
`
`Yes.
`
`Q.
`
`Now, you'll notice it's directed —— it's a
`
`subpoena.
`
`
`ESQUIRE
`
`an Alexander Gallo Company
`
`Toll Free: 800.944.9454
`Facsimile: 212.557.5972
`
`Suite 4715
`One Penn Waza
`New York, NY 10119
`www.esquiresoiutions.com
`
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`23
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`24
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`
`
`Dr.
`
`Shailinder Sodhi
`
`4
`
`January 7, 2010
`
`‘*7
`
`By the way, do you know what a subpoena is?
`
`A.
`
`No.
`
`I'm not an attorney.
`
`Q. Well, it‘s a court order.
`
`A.
`
`Q.
`
`Okay.
`
`And it‘s directed to Ayush Herbs, Inc., and it
`
`asks that Ayush Herbs, Inc.,
`
`testify on certain matters.
`
`"About the following matters, or those set forth in an
`
`attachment." And then it says,
`
`"See attached Exhibit A."
`
`Do you see where I am on that?
`
`A.
`
`Q.
`
`A.
`
`Q.
`
`This one?
`
`Yes.
`
`Yes.
`
`Go ahead.
`
`Okay.
`
`So can you see where it says,
`
`"See
`
`attached Exhibit A"?
`
`A.
`
`Q.
`
`Yes.
`
`Now, would you turn to Exhibit A, please.
`
`Is my understanding correct that you
`
`are here today to testify on behalf of Ayush
`
`Herbs regarding the subject matters set forth in
`
`Exhibit A?
`
`A.
`
`Yes.
`
`Q.
`
`And you are -— you have been designated as the
`
`sole person to testify on all of these subject matters
`
`set forth in
`
`Exhibit A, correct?
`
`l3
`
`l4
`
`l5
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`l6
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`1 7
`
`L8
`
`l9
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`20
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`Zl.
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`23
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`24
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`
`ESQUIRE
`
`“" ‘“°"‘"““‘”G““““"““""‘y
`
`Toll Free: 800.944.9454
`Facsimile: 212.557.5972
`
`Suite 4715
`One Penn Plaza
`New York, NY 10119
`www esquiresolutions com
`
`
`
`Dr. Shailinder Sodhi
`
`January 7, 2010
`
`|
`
`E
`E
`
`Yes.
`
`A
`In preparation for today's deposition, did you
`
`A.
`
`Q.
`
`speak with anyone?
`A.
`No.
`
`Q.
`
`A.
`
`You didn't speak with your attorneys?
`
`I spoke with my attorneys, but not --
`
`MR. KAISER:
`
`Just yes or no.
`
`BY MR . ALPERT:
`
`Q.
`
`You did speak with "our attorneys in
`
`preparation for deposition?
`A.
`No, not for deposition. But I spoke in
`
`i
`D
`
`I
`1
`
`general.
`
`Q.
`
`A.
`
`Don't mark the exhibit, please.
`
`I'll put it in my pocket.
`
`I have a habit of
`
`writing things.
`
`Q.
`
`So I just want to make sure I understand.
`
`So you did not speak with your attorneys in
`
`preparing for today's deposition?
`
`A.
`
`You have to elaborate when "preparing," what
`
`you mean by that.
`
`Q.
`
`Okay. Did you speak with anyone concerning ~—
`
`_
`
`look at Topic A,
`
`"The Ayush Herbs Mark and Opposer's
`
`Goods and Services."
`
`12
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`23
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`24
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`Toll Free: 800.944.9454
`Facsimile: 212.557.5972
`
`Suite 4715
`
`Did you discuss with anyone your possible
`
`
`ESOI JIRE
`,‘_
`
`“ “°’‘‘'‘“‘‘°’°’‘'‘‘‘°°°‘‘’‘’““’
`
`New York, NY 10119
`www esquiresoiutions com
`
`
`
`Dr.
`
`Shailinder Sodhi
`
`January 7, 2010
`
`testimony on this subject matter?
`
`[\J
`
`MR. KAISER:
`
`Just for the record,
`
`I'm
`
`6
`
`objecting to privilege.
`
`He can answer yes or no.
`
`Nothing to do with the substance.
`
`BY THE WITNESS:
`
`A.
`
`Yes.
`
`BY MR. ALPERT:
`
`Q. With whom did you speak?
`
`A.
`
`Q.
`
`A.
`
`To my attorneys.
`
`And when was that?
`
`That was, you know,
`
`last night discussing about
`
`12
`
`13
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`14
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`the services which came ——
`
`MR. KAISER: Dr. Sodhi, objection. There's
`
`nothing to be discussed about the subject matter
`
`or the topics that we discussed or anything.
`
`We're objecting to this Line of questioning on
`
`privilege. You've asked the question. You've got your
`
`answer. Let's move on.
`
`BY MR. AL?ERT:
`
`Q.
`
`Other than your attorneys, did you speak with
`
`anyone else about Topic A,
`
`"The Ayush Herbs Mark and
`
`Opposer's Goods and Services," in preparation for today's
`
` —3j
`
`23
`
`24
`
`deposition?
`
`A.
`
`No.
`
`
`ESQUIRE
`
`““ “°"““““°'““°°°“"’“’
`
`Toll Free: 800.944.9454
`Facsimile: 212.557.5972
`
`Suite 4715
`One Penn Piaza
`New York, NY 10119
`www esquiresolutions com
`
`
`
`Dr. Shailinder Sodhi
`
`January 7, 2010
`
`I
`i
`I
`
`I
`
`7
`
`"The origination, development,
`Topic 3,
`Q.
`1
`selection, and adoption by Opposer of the Ayush Herbs
`2|
`3E Mark for Opposer's Goods and Services,
`including the
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10!
`
`11
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`12
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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
`
`18
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`19
`
`20
`
`21
`
`meaning, connotation, commercial
`
`impression of the terms
`
`'ayush' and "ayush herbs.‘"
`
`Did you speak with anyone other than your
`
`attorneys about this topic in preparation for today's
`
`deposition?
`
`A.
`
`No.
`
`Q.
`
`Topic C, "Opposer's first use of the Ayush
`
`Herbs Mark in the United States in connection with each
`
`and every product specified in Opposer's Registration
`
`No. 2,493, 772."
`
`Did you speak with any person or persons other
`
`than your attorneys here today about
`
`the subject matter
`
`of this topic?
`
`A.
`
`No.
`
`Q.
`
`Topic D,
`
`"The manufacture and production of
`
`Opposer's Goods and Services."
`
`Did you speak with anyone about that topic --
`
`MR. KAISER: Objection to form.
`
`BY MR. ALPERT:
`
`Thank you.
`
`Q.
`
`—— in preparation for today's deposition?
`
`MR. KAISER:
`
`
`ES I
`
`““‘ ‘““"““’°’ G"“’° °°“"’“”’
`
`Toll Free: 800.944.9454
`Facsimile: 212.557.5972
`
`Suite 4715
`
`One Penn Plaza
`
`New York, NY 10119
`www . esq u i resol utions . com
`
`
`
`Dr. Shailinder Sodhi
`
`January 7,
`
`2010
`
`BY THE WITNESS:
`
`R.)
`
`A.
`
`No.
`
`BY MR
`
`. ALPERT:
`
`Q-
`
`E,
`
`"The rendering of Opposer‘s Goods and
`
`Services in the United States."
`
`MR. KAISER:
`
`Same objection.
`
`BY MR. ALBERT:
`
`Q.
`
`A.
`
`Q.
`
`In preparation for today's deposition.
`
`NO.
`
`E,
`
`"The rendering of Opposer’s Goods and
`
`Services in the United States."
`
`Did you speak to anyone concerning this subject
`
`matter in preparation for today's deposition?
`
`A.
`
`No.
`
`Q.
`
`F,
`
`"The distribution of Opposer‘s Goods and
`
`Services in the United States,
`
`including channels of
`
`trade."
`
`Did you speak with anyone in connection with
`
`your preparation for today's deposition?
`
`A.
`
`,:=.-
`D.
`
`No.
`
`V.-
`G.
`
`"The advertising, promotion and offering for
`
`sale of Opposer's Goods and Services in the United
`
`States."
`
`Did you speak with anyone in preparing
`
`2-0]?
`
`13
`
`14
`
`16
`
`L7
`
`23
`
`24
`
`
`ESQUIRE
`
`an Alexander Gallo Company
`
`Toll Free: 800.944.9454
`Facsimile: 212.557.5972
`
`SuWe4715
`One Penn Plaza
`New York, NY 10119
`www.esquireso|utions.com
`
`
`
`Dr. Shailinder Sodhi
`
`January 7,
`
`9
`
`today's deposition about this topic?
`
`A.
`
`No.
`
`Q.
`
`When you say "No," such as you just did, does
`
`that include your attorneys?
`
`A.
`
`Q.
`
`Okay. Rephrase it.
`
`When you say “No,” that you spoke to no one,
`
`are you including your attorneys in that no?
`
`A.
`
`Q.
`
`No, no.
`
`So you may have spoken to your attorne"s about
`
`that topic?
`
`A.
`
`Yes.
`
`Q.
`
`H, "Publicity (both solicited and unsolicited)
`
`in the United States concerning Opposer's Goods and
`
`Services,
`
`including press releases and articles of any
`
`kind."
`
`Did you speak with anyone regarding that topic
`
`in preparation for today's deposition?
`
`A.
`
`No.
`
`Q.
`
`I,
`
`"The sale of Opposer's Goods and Services in
`
`the United States,
`
`including classes of purchasers."
`
`And let me remind you that sale includes
`
`financial information.
`
`Did you speak with anyone about this topic in
`
`preparation for today's deposition?
`
`
`
`ESQIRE
`
`an Alexander Gallo Company
`
`
`
`Toll Free: 800.944.9454
`Facsimile: 212.557.5972
`
`Suite 4715
`One Penn Haza
`New York, NY 10119
`www.esquiresolutions.com
`
`12
`
`13
`
`14
`
`15
`
`16
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`17
`
`18
`
`19
`
`2O
`
`21
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`22
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`23
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`24
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`
`
`Dr. Shailinder Sodhi
`
`January 7,
`
`2010
`
`1 1 ! I
`
`A.
`
`No.
`
`10
`
`Q.
`
`J,
`
`"Any licenses, franchises, sublicenses,
`
`sub—franchises, distributorships, assignments and other
`
`such agreements concerning Opposer's Goods and Services."
`
`Did you speak to anyone concerning this topic
`
`in preparation for today's deposition?
`
`A.
`
`No.
`
`Q-
`
`K,
`
`"Opposer's compliance with federal and state
`
`regulatory authorities concerning the production, sale,
`
`promotion, or advertising of Opposer‘s Goods and
`
`Services."
`
`Did you speak with anyone in connection with
`
`this topic in preparing for today's deposition?
`
`I would
`
`remind you that that would include your attorneys.
`
`15
`
`16
`
`17
`
`18
`
`MR. KAISER:
`
`I'll object to form.
`
`I'm
`
`confused by the question.
`
`MR. ALPERT:
`
`It's not whether you're
`
`confused.
`
`It's whether the witness is
`
`confused.
`
`MR. KAISER: All right.
`
`BY THE WITNESS
`
`Yeah, you need to elaborate.
`
`MR. ALPERT:
`
`Now that your attorney has
`
`he's confused,
`
`I gather you're confused.
`
`said
`
`
`ESQUIRE
`
`an Alexander Gallo Company
`
`Toll Free: 800.944.9454
`Facsimile: 212.557.5972
`
`Suite 4715
`One Penn Piaza
`New Yerk, NY 10119
`www.esquireso|utions.com
`
`
`
`Dr.
`
`Shailinder Sodhi
`
`January 7,
`
`11
`
`Would you read back the question, please.
`
`(Record read as requested.)
`
`MR. KAISER;
`
`I'm going to renew the same
`
`C
`objection, but i; you can answer.
`
`BY MR. ALPERT:
`
`Q.
`
`A.
`
`Q.
`
`A.
`
`Go ahead.
`
`Time frame. When?
`
`In preparation for today's deposition.
`
`Yes.
`
`Q. With whom did you speak?
`
`Dr. Sodhi,
`
`I believe it‘s been about a minute.
`
`A.
`
`I know. And I'm trying to —— because it's
`
`multi —— it's not a one thing.
`
`It has the production and
`
`sale and promotion.
`
`So many things.
`
`So I'm trying to see —— trying to cover which
`
`part I discussed. Not discussed,
`
`I talked.
`
`Q.
`
`The question does not call for you to identify
`
`the specific aspect of this subject matter K, but simply
`
`to identify those people with whom you spoke concerning
`
`any aspect of subject matter K.
`
`And please, your attorney can‘t answer the
`
`question for you.
`
`A.
`
`Yes.
`
`I did speak to my attorney.
`
`Q.
`Anyone else?
`
`
`ESQUIRE
`
`an Alexander Gallo Company
`
`Toll Free: 800.944.9454
`Facsimile: 212.557.5972
`
`Suite 4715
`One Penn Plaza
`New York, NY 10119
`www.esquiresolutions.com
`
`f. 4
`
`l5
`
`16
`
`22
`
`23
`
`24
`
`
`
`Dr. Shailinder Sodhi
`
`January 7, 2010
`
`A.
`
`No.
`
`l2
`
`Q.
`
`By your attorney, can you identify the attorney
`
`or attorneys.
`
`A.
`
`Q.
`
`A.
`
`Ryan and Rakesh.
`
`And I assume that was last evening?
`
`Yes.
`
`I
`
`I
`
`|.._..\
`
`K)
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
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`18
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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
`
`period of time during which Opposer has not used the
`-n__
`L
`k in connection with any of the goods
`
`"The reasons for, and circumstances of, any
`
`H
`
`Q.
`
`L,
`
`yush Herbs Ma
`
`specified in Opposer's Registration No. 2,493,772 since
`
`the date of first use claimed in such registration."
`
`Did you speak with anyone concerning this topic
`
`in preparation for today's deposition?
`
`A.
`
`No.
`
`Q.
`
`M,
`
`"The filing, prosecution and maintenance of
`
`Opposer's Registration No. 2,493,772 and any other
`
`federal or state trademark application or registration
`
`for the Ayush Herbs Mark,
`
`including the basis for all
`
`statements made in connection therewith."
`
`Did you speak with anyone concerning this topic
`
`in preparing for today's deposition?
`
`1 would remind you
`
`that that would include attorneys such as Mr. Hughes.
`
`A.
`
`No.
`
`Q.
`
`"N, Any third—party applications, registrations
`
`
`
`ES
`
`\—
`
`ill.
`.1-
`’"‘ “‘°”“‘““"” G’“‘° °°““’““’
`
`ToHFree:800.944.9454
`FacshnHe:212.557.5972
`
`Suite 4715
`
`One Penn Plaza
`
`Nem1York,NY 10119
`www.esquiresoI utions.com
`
`
`
`Dr. Shailinder Sodhi
`
`January 7, 2010
`
`and uses of the Ayush Herbs Mark in connection with goods
`
`E0
`
`or services identical or similar to Opposer's Goods and
`
`13
`
`Services."
`
`A.
`
`Q.
`
`No.
`
`Did you speak with anyone ~—
`
`-— concerning this topic in preparation for
`
`i
`
`today's deposition?
`
`A.
`
`The answer is no.
`
`Q.
`
`0,
`
`“Any litigation, arbitration or U.S. Patent
`
`and Trademark Office proceedings concerning the Ayush
`
`Herbs Mark or Opposer's ownership, title or rights in and
`
`to the Ayush Herbs Mark."
`
`Did you speak with anyone concerning this
`
`particular topic in preparing for today's deposition?
`
`A.
`
`No.
`
`Q.
`
`P, "Settlement agreements concerning Opposer*s
`
`Goods and Services or the Ayush Herbs Mark in the United
`
`States."
`
`Did you speak with anyone concerning this topic
`
`in preparing for today's deposition?
`
`A.
`
`No.
`
`Q.
`
`Q, "Opposer's knowledge of Applicant and
`
`Applicant‘s use of or intended use of the trademark Ayush
`
`in the United States."
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21 _
`
`22
`
`23
`
`24
`
`
`
`I
`ES |
`“‘ “‘”"‘“““’°“"“° °°"“’“y
`
`Toll Free: 800.944.9454
`Facsimiie: 212.557.5972
`
`Suite 4715
`One Penn Plaza
`New York, NY 10119
`www esquiresolutions com
`
`
`
`Dr. Shailinder Sodhi
`
`January 7, 2010
`
`14
`
`'
`
`i
`-
`
`1
`
`2
`
`3'
`4
`
`5
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`6
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`7
`
`8
`
`9
`
`10
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`11
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`15
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`16
`
`17
`
`18
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`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`Did you speak with anyone concerning this topic
`
`in preparing for today‘s deposition?
`
`1 would remind you
`
`that this includes counsel.
`A.
`Yes.
`
`Q.
`
`A.
`
`Q.
`
`A.
`
`Q.
`
`A.
`
`And with whom did you speak?
`
`To my attorneys.
`
`Your attorneys being whom?
`
`Mr. Rakesh Amin and Ryan.
`
`No one else?
`
`No.
`
`Q
`
`R, ”Opposer‘s knowledge of Applicant's
`
`application for, registration of, or use of the trademark
`
`Ayush."
`
`Did you speak with anyone concerning this topic
`
`in preparation for today‘s deposition?
`
`A.
`
`Yes.
`
`Q. With whom?
`
`A.
`
`Q.
`
`A.
`
`Q
`
`A.
`
`To my attorneys.
`
`The same attorneys you previously identified?
`
`Yes.
`
`Speak with anyone else?
`
`NO.
`
`Q.
`
`S,
`
`"Evidence of actual confusion between
`
`Opposer's Goods and Services and Applicant's services
`
`
`ES ‘
`x
`
`—
`“‘ "‘“’“““‘°’”’““°°°‘“"“”’
`
`TOH Free: 800.944.9454
`Facsimile: 212.557.5972
`
`Suite 4715
`
`One Penn Plaza
`
`New York, NY 10119
`www esquiresolutions com
`
`
`
`Dr. Shailinder Sodhi
`
`January 7, 2010
`
`l5
`
`which are marketed under the trademark Ayush."
`
`Did you speak with anyone concerning this topic
`
`in preparation for today's deposition?
`
`I
`
`!
`
`A.
`
`Q.
`
`A.
`
`Yes.
`
`Who?
`
`To my attorneys.
`
`1
`
`2'
`
`3'
`
`4
`
`5
`
`6
`
`Q.
`
`R,
`
`"The allegations set forth in the Notice of
`
`8' Opposition and in any other pleadings served in this
`
`7
`
`9
`
`opposition “
`
`10
`
`11
`
`12
`
`l3
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`MR. KAISER: Objection to form. Where are
`
`we? You said R.
`
`MR. ALPERT:
`
`I'm sorry.
`
`T.
`
`BY MR. ALPERT:
`
`Q.
`
`T.
`
`I'm sorry.
`
`"The allegations set forth in the Notice of
`
`Opposition and any other pleadings served in this
`
`opposition."
`
`Did you speak with anyone concerning this topic
`
`in preparation for today‘s deposition?
`
`A.
`
`Yes.
`
`21 _
`
`O. With whom?
`
`22
`
`23
`
`24
`
`A
`
`O.
`
`A
`
`My attorneys.
`
`Anyone else?
`
`NO.
`
`
`‘
`
`"“ "‘“""““°’°"“‘° °°"""’“”
`
`Toll Free: 800.944.9454
`Facsimile: 212.557.5972
`
`Suite 4715
`
`One Penn Plaza
`
`New York, NY 10119
`www.esquiresolutions.com
`
`
`
`Dr. Shailinder Sodhi
`
`January 7, 2010
`
`16
`
`Q.
`
`U, "Opposer's collection and production,
`
`including supplementation, of documents responsive to
`
`Applicant's First Set of interrogatories and First
`
`Request for the Production of Documents."
`
`Did you speak with anyone concerning this topic
`
`in preparation for today's deposition?
`
`A.
`
`Yes.
`
`Q. With whom?
`
`A.
`
`Q.
`
`A.
`
`My attorneys.
`
`Anyone else?
`
`No.
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`Q.
`
`By "my attorneys," you're referring to the same
`
`attorneys?
`
`A.
`
`Q.
`
`Exactly.
`
`V, "Opposer's document retention policy.”
`
`Did you speak with anyone concerning this topic
`
`in preparation
`
`for today‘s deposition?
`
`A.
`
`Yes.
`
`Q. With whom?
`
`A.
`
`Q.
`
`My attorneys.
`
`The same attorneys to whom you've been
`
`referring?
`
`A.
`
`Yes.
`
`Q.
`
`Anyone else?
`
`
`ESQIRE
`
`an Alexander Gallo Company
`
`Toll Free: 800.944.9454
`Facsimiie: 212.557.5972
`
`Suite 4715
`One Penn Maza
`New York, NY 10119
`www.esquiresoEutions.com
`
`
`
`Dr.
`
`Shailinder Sodhi
`
`January 7,
`
`20lO
`
`A.
`
`No.
`
`l7
`
`[\)
`
`Q.
`
`Other than speaking with your attorneys, what
`
`did you do in order to prepare yourself for today‘s
`
`deposition?
`
`A.
`
`A lot of thinking in my head about this
`
`deposition.
`
`Q.
`
`A.
`
`Q.
`
`A.
`
`Q.
`
`A.
`
`A lot of thinking.
`
`On your own?
`
`On my own.
`
`Did you review any documents?
`
`On my own?
`
`Yes.
`
`I did not have enough time to review all of the
`
`documents on my own.
`
`Q.
`
`Did you review any other documents —— did you
`
`review any documents?
`
`A.
`
`No,
`
`I didn't have time to review any
`
`document.
`
`Q.
`
`So you are here testifying not having reviewed
`
`any documents in preparation for today's deposition;
`
`is
`
`that correct?
`
`A.
`
`When you're asking me,
`
`I'm thinking last
`
`24 hours.
`
`Q.
`
`Leaving aside the documents that you were
`
`presented as marked exhibits yesterday, have you done any
`
`l5
`
`l6
`
`l7
`
`l8
`
`l9
`
`23
`
`24
`
`
`ESQUIRE
`
`an Alexander Gallo Company
`
`Toll Free: 800.944.9454
`FacsHnHe:212.557.5972
`
`SuRe4715
`One Penn Naza
`NemYork,NY 10119
`www.esquiresolutions.com
`
`
`
`Dr.
`
`Shailinder Sodhi
`
`January 7,
`
`2010
`
`other preparation —- have you reviewed any documents in
`
`18
`
`"_mmmm'i
`
`preparation for today's deposition?
`
`A.
`
`Yes.
`
`Q. What documents did you look
`
`at?
`
`MR. KAISER:
`
`I'll object just on the basis
`
`that to the extent you're calling for privileged
`
`information, any particular documents that we, as
`
`his attorneys, may have identified,
`
`I believe
`
`that's work product. And I don't believe that he
`
`needs to identify what we've identified with
`
`him.
`
`MR. ALPERT:
`
`I'm entitled —- if this witness
`
`has refreshed his recollection by looking at
`
`documents,
`
`I'm entitled to know what he's used to
`
`refresh his recollection.
`
`If the documents themselves in the contents of
`
`privilege, that's another issue we can deal with. But I
`
`am entitled to know what the documents themselves are.
`
`BY MR. ALPERT:
`
`Q.
`
`So what documents did you review other than the
`
`marked enhibits from yesterdav's testimonv?
`
`A.
`
`I did not have any document as a paper in front
`
`of me to review,
`
`but, you know,
`
`after yesterday's
`
`discussion, you know,
`L...
`
`
`ESQUIRE
`
`an Alexander Gallo Company
`
`I did think of the services and the
`
`Toll Free: 800.944.9454
`Facsimile: 212.557.5972
`
`Suite 4715
`One Penn Piaza
`New York, NY 10119
`www.esquireso|utions.com
`
`
`
`Dr.
`
`Shailinder Sodhi
`
`January 7,
`
`2010
`
`I
`
`I
`
`19
`
`So that's what
`
`I was thinking in my head after
`
`sales.
`
`reviewing.
`
`Q.
`
`Dr. Sodhi,
`
`:‘m not asking what you were
`
`thinking in your head at the moment, at least.
`
`A.
`
`Q.
`
`Right. Okay.
`
`What I'm asking is did you review any specific
`
`documents? Can you identify any specific documents that
`
`you reviewed?
`
`A.
`
`Q.
`
`No.
`
`I did not review any documents.
`
`So you're testifying today having reviewed no
`
`documents in preparation for today's examination,
`
`correct?
`
`A.
`
`Q.
`
`Yes,
`
`that‘s correct.
`
`Did your attorneys advise you of your
`
`obligation to familiarize yourself and place yourself in
`
`a position such that you could speak on behalf of the
`
`corporation on each and every one of the topics that we
`
`have just identified in Exhibit A?
`
`MR. KAISER:
`
`I'll put my objection on the
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21.
`
`record that I believe you're asking for
`
`22
`
`23
`
`24
`
`attorney/client privilege.
`
`He can answer it yes
`
`or no, but we're not going to get into the
`
`substance of what was advised and what was
`
`L..
`
`
`
`ESQIRE
`
`an Alexander Gallo Company
`
`Toll Free: 800.944.9454
`Facsimile: 212.557.5972
`
`SuRe47l5
`One Penn Maza
`New York, NY 10119
`www.esquiresoIu’cions.com
`
`
`
`Dr.
`
`Shailinder Sodhi
`
`January 7, 2010
`
`i._\
`
`discussed.
`
`2O
`
`MR. ALPERT: Reread the question, please.
`
`(Record read as requested.)
`
`THE WITNESS: One more time.
`
`(Record read as requested.)
`
`BY THE WITNESS:
`
`A.
`
`No.
`
`MR. ALPERT:
`
`If the reporter would please
`
`mark as Ayush Herbs 1, it shows the words "Lever
`
`Ayush."
`
`(WHEREUPON, a certain document was marked
`
`Ayush Herbs 1, for identification, as
`
`of January 7, 2010.)
`
`BY MR. ALPERT:
`
`Q.
`
`Dr. Sodhi, have you seen prior to today what's
`
`shown in Ayush Herbs Exhibit 1?
`
`A.
`
`Q.
`
`Ayush Herbs?
`
`Have you seen the mark "Lever Ayush" in Ayush
`
`Herbs Exhibit 1 before today?
`
`10
`
`|—| "h E .J. :3 9 5 rr 0) '3
`
`the mark as shown in Ayush Herbs Exhibit 1 for the
`
`identical services now covered by its Ayush application,
`
`.
`
`would you oppose that application?
`
`
`ESQIRE
`
`an Alexander Gallo Company
`
`Toll Free: 800.944.9454
`Facsimile: 212.557.5972
`
`Suite 4715
`One Penn Plaza
`New York, NY 10119
`www.esquireso|utions.com
`
`
`
`Dr.
`
`Shailinder Sodhi
`
`January 7,
`
`2010
`
`1
`
`A.
`
`Yes.
`
`21
`
`7
`
`KO
`
`[.4 C)
`
`|....\
`
`l,....\
`
`13
`
`14
`
`15
`
`L9
`
`20
`
`21
`
`22
`
`23
`
`24
`
`MR. KAISER: Object to the form. First,
`
`before the answer,
`
`I object to the form. And I
`
`also object to the extent that it calls for a
`
`legal conclusion.
`
`But
`
`I believe he‘s already answered yes.
`
`BY MR. ALPERT:
`
`Q.
`
`If Hindustan Lever were to begin using the mark
`
`shown in this same exhibit in the United States for those
`
`,\,.-a—
`sane services, would you Objcub to that use?
`
`MR. KAISER:
`
`BY THE WITNESS:
`
`A.
`
`Yes.
`
`BY MR. AL?ERT:
`
`Q.
`
`And if they refused or continued to use --
`
`let
`
`me put it this way:
`
`If they continued to use this, would
`
`you sue them?
`
`A.
`
`Yes.
`
`Q.
`
`A.
`
`And you would sue -— why would you sue them?
`
`It will create a confusion between Ayush Herbs
`
`trademark and Ayush name of Hindustan Lever.
`
`It‘s the
`
`same trade name.
`
`Q.
`
`And it would be your view that they would be
`
`infringing your rights?
`
`1
`
`
`
`ESQIRE
`
`an Alexander Gallo Company
`
`Toll Free: 800.944.9454
`Facshnflez 212.557.5972
`
`Sufie471S
`One Penn Haza
`New York, NY 10119
`www.esquireso|utions.com
`
`
`
`Dr. Shailinder Sodhi
`
`January 7,
`
`2010
`
`O\U’!
`
`‘.1 C)
`
`i...) ‘_l
`
`l3
`
`l4
`
`l5
`
`22
`
`MR. KAISER: Objection,
`
`form. Objection,
`
`legal conclusion, but you can answer.
`
`BY THE WITNESS:
`
`A.
`
`Yes.
`
`BY MR. ALPERT:
`
`Q.
`
`Do you —- where do you sell —— where does Ayush
`
`Herbs sell its Ayush Herbs products, geographically
`
`speaking?
`
`A.
`
`Q.
`
`That‘s an awkward question.
`
`I apologize.
`
`Geographic?
`
`Yeah.
`
`Do you sell in only Washington State,
`
`only in California? Where do you sell?
`
`A.
`
`All over U.S.A.
`
`Q.
`
`A.
`
`Q.
`
`Throughout the United States?
`
`Yes. All over U.S.A.
`
`So you sell in Illinois; is that correct?
`
`A. Well, Illinois is a part of U.S.A.
`
`Q.
`
`A.
`
`Q.
`
`A
`
`So the answer is yes, correct?
`
`Yes.
`
`You sell in Florida;
`
`is that correct?
`
`I think I have annwered already. "ll over
`
`U.S.A. And Florida does include U.S.A.
`
`Q.
`
`A.
`
`And you sell in New York also?
`
`Yes.
`
`
`ESQUIRE
`
`an Alexander Gallo Company
`
`Toll Free: 800.944.9454
`Facsimile: 212.557.5972
`
`Suite 4715
`One Penn Maze
`New York, NY 10119
`www.esquireso|utions.com
`
`
`
`Dr. Shailinder Sodhi
`
`January 7,
`
`2010
`
`I I
`
`23
`
`Q.
`
`Do you have distributors located throughout
`
`the
`
`United States?
`
`A.
`
`Q.
`
`A.
`
`Q.
`
`A.
`
`Q.
`
`We do have distributors.
`
`Throughout the United States?
`
`Throughout the United States.
`
`So again, you have distributors in Illinois?
`
`We have a distributor who serves Illinois.
`
`Who sells to Illinois, but is not located in
`
`Illinois?
`
`A.
`
`NO.
`
`Q.
`
`Do you have a distributor who sells to New
`
`York?
`
`A.
`
`The distributor which we have,
`
`I do not know
`
`the channels, where do they sell, but they do sell it.
`
`And we sell directly to New York as well
`
`too.
`
`Q.
`
`What is the approximate volume of sales that
`
`you sell to New York?
`
`A.
`
`I do not know.
`
`Q. What's the approximate volume that you sell to
`
`Illinois?
`
`A.
`
`Answer is the same.
`
`I do not know.
`
`Q. Well, who would know?
`
`A. Well, that's accounting question. We have to
`
`look into the system. Sales by the states.
`
`l
`
`Toll Free: 800.944.9454
`Facsimile: 212.557.5972
`
`SuKe4715
`One Penn Plaza
`New York, NY 10119
`www.esquiresolutions.com
`
`
`
`ESQUIRE
`
`an Alexander Gallo Company
`
`OWU!
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`
`
`Dr. Shailinder Sodhi
`
`January 7, 2010
`
`that?
`
`[
`
`'
`
`Q.
`
`And who at your company would be able to do
`
`24
`
`A
`
`Q
`
`A
`
`Office manager can pull up the sales.
`
`And the office manager‘s name is?
`
`Jagjit Dhillon.
`
`Q.
`
`I take it he is the person who is most
`
`knowledgeable about sales, financial information;
`
`is that
`
`correct?
`
`MR. KAISER:
`
`I object to the form of that.
`
`BY MR
`
`. ALPERT:
`
`Q.
`
`Who is the most knowledgeable at your company
`
`concerning financial information,
`
`sales in particular,
`
`l3
`
`l4
`
`l5
`
`16
`
`amount of sales?
`
`MR.
`
`KAISER:
`
`Same objection.
`
`MR. ALPERT:
`
`Okay.
`
`BY THE WITNESS:
`
`A.
`
`I am, but when we trying to pull up the sales
`
`by state,
`
`everything is electronic.
`
`So you know, we can
`
`pull that out,
`
`and office manager can pull that out,
`
`those types of sales.
`
`BY MR ALBERT;
`
`Q.
`
`Yesterday when you were testifying as president
`
`of the company,
`C
`
`I showed you a number of exhibits,
`
`speci
`
`ically Exhibits 10 through 15, which you identified
`
`
`UIRE
`ESQ
`
`an Alexander Gallo Company
`
`Toll Free: 800.944.9454
`Facsimile: 212.557.5972
`
`Suite 4715
`One Penn Haza
`New York, NY 10119
`www.esquiresolutions.com
`
`I
`
`I
`
`1
`
`
`
`Dr. Shailinder Sodhi
`
`January 7, 2010
`
`25
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`1
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`2|
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`as ledgers. And I believe your testimony was that there
`
`were terms within this ledger that you were not competent
`encompassed.
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`to testify as to; for example,
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`total income, what this
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`D
`
`I
`
`Who would be the person again who would be
`
`competent to testify on that?
`
`A.
`
`Q.
`
`Can you repeat the question again.
`
`Okay.
`
`In your ledgers, you show various
`
`figures. And I had asked you to explain to me what
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`“Total Ificone" referred to. And you testified that you
`
`couldn't speak to that.
`
`Who could speak to that issue?
`
`A.
`
`The total income —— I can say that the total
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`income is what you see, that's what it is. And that's
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`what
`
`I can support that. That's what it is. But the
`
`detail of total income is all definitely on the office
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`manager and accountant.
`
`Q.
`
`A.
`
`Q.
`
`A.
`
`Q.
`
`Okay.
`
`The office manager being?
`
`Jagjit.
`
`The same person you just identified?
`
`Right.
`
`So if you wanted to know what products were
`
`encompassed within total income,
`
`I would need to speak to
`
`him, correct?
`
`ES UIRE
`
`Toll Free: 800.944.9454
`Facsimile: 212.557.5972
`
`Suite 4715
`
`3“ “°’‘‘"‘“‘’°‘ 0”” °"“"’““’
`
`New York, NY 10119
`www.esquireso|utions.com
`
`
`
`Dr.
`
`Shailinder Sodhi
`
`January 7,
`
`2010
`
`26
`
`A.
`
`Q.
`
`It‘s a her.
`
`Her,
`
`I‘m sorry.
`
`I would need to speak to her, correct?
`
`A.
`
`Or you can speak to me, and I
`
`can tell whomever
`
`to pull up that information.
`
`I mean, she is the person
`
`who will be pulling out so
`
`Q.
`
`Right.
`
`So sitting here today, you can't tell
`
`me, correct?
`
`A.
`
`Right now,
`
`I do not have all the things in
`
`front of me so
`
`cannot, yes.
`
`Q.
`
`And you did not speak to her in preparation for
`
`today's deposition;
`
`is that correct?
`
`’.O?"’.°?’
`
`No, no.
`
`You did not?
`
`No,
`
`I did not.
`
`And I take it on that same Exhibit 10, you
`
`would need to speak with her as regards what falls within
`
`the category of advertising;
`
`is that correct?
`
`A.
`
`Q.
`
`Yes.
`
`And again, you didn't speak to her in preparing
`
`for today's deposition, did you?
`
`A.
`
`No.
`
`Q.
`
`Do you know the state to which you sell the
`
`most Ayush Herbs products percentagewise?
`
`L4
`
`15
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`16
`
`17
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`18
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`19
`
`
`ESQUIRE
`
`an Alexander Galla Company
`
`Toll Free: 800.944.9454
`Facsimile: 212.557.5972
`
`Suite 4715
`One Penn Haze
`New York, NY 10119
`www.esquiresolutions.com
`
`
`
`Dr.
`
`Shailinder Sodhi
`
`January 7,
`
`2010
`
`! I %
`
`I
`
`J
`
`27
`
`A.
`
`Q.
`
`No,
`
`But
`
`I don't.
`-r-
`1
`
`take it from your testimony that you do
`
`sell in all 50 states?
`
`A.
`
`I do sell all over 50 states.
`
`statistics.
`
`I don't have
`
`Q.
`
`A.
`
`Q.
`
`But those statistics could be arrived at?
`
`Pardon?
`
`Could those statistics be generated by your
`
`computer system?
`
`A.
`
`Yes.
`
`Q.
`
`A.
`
`Q.
`
`By the office manager?
`
`Right.
`
`Did you ever inform your current attorneys that
`
`you had never used Ayush Herbs in connection with
`
`homeopathic and pharmaceutical preparations?
`
`MR. KAISER: Objection to the extent that it
`
`seeks substance of communication with attorneys.
`
`It's privileged.
`
`BY MR. ALPERT:
`
`Q.
`
`A.
`
`Q.
`
`Just a yes or a no.
`
`No.
`
`You are not currently using Ayush Herbs on skin
`
`lotions, correct?
`
`A.
`
`Yes.
`
`
`ESQIRE
`
`3“ ‘“”““"“‘ G"“° °°"“"”"
`
`Toll Free: 800.944.9454
`FacsHnHe:212.5S7.5972
`
`Suke4715
`One Penn Haza
`New York, NY 10119
`www.esq uiresol utions.com
`
`(JO[\JE-*‘
`
`1-‘ CD
`
`1...: F"
`
`13
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`2l_
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`22
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`23
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`24
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`
`
`Dr. Shailinder Sodhi
`
`January 7,
`
`2010
`
`28
`
`Q.
`
`Did you ever inform your attorneys that you
`
`were not using Ayush Herbs on skin lotions?
`
`MR. KAISER:
`
`Same objection as before.
`
`Yes—or—no answer.
`
`BY THE WITNESS:
`
`A.
`
`No.
`
`BY MR. ALPERT:
`
`Q.
`
`Are you currently using Ayush Herbs on skin
`
`creams?
`
`A.
`
`Q.
`
`correct?
`
`No. We have a plan to.
`
`I see. But currently you're not using,
`
`13
`
`14
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`15
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`17
`
`18
`
`19
`
`A.
`
`Yes.
`
`Q.
`
`Did you ever inform your attorneys that you
`
`were not using on skin cream?
`
`MR. KAISER: Robert,
`
`I have to stop this
`
`line of questioning. You're dancing on the line
`
`of attorney privilege. You're just asking him
`
`about the substance of the communications and
`
`just asking him to answer yes or no whether he
`
`said X. Y or Z.
`
`I really think it's inappropriate, and I'm
`
`going to instruct.
`
`MR. AMIN: You're asking for attorney/client
`
`
`ESQUIRE
`
`an Alexander Gallo Company
`
`Toi! Free: 800.944.9454
`Facsimile: 212.557.5972
`
`Suite 4715
`One Penn Waza
`New York, NY 10119
`www.esquiresoiutions.com
`
`
`
`Dr.
`
`Shailinder Sodhi
`
`January 7,
`
`2010
`
`29
`
`communications.
`
`MR. KAISER: You can't say the communication
`
`that you want him to answer if he asked us or not
`
`and then just say, well, it's just a yes—or—no
`
`question.
`
`I‘m going to instruct him not to answer these
`
`questions around what he asked us. But you can ask him
`
`if he spoke with us about it, that's fine, but if you put
`
`the substance in his mouth and say,
`
`"Answer yes or no,
`
`did you discuss that specific topic with your attorneys?"
`
`DI
`
`!I
`
`I
`
`I don't think that's appropriate.
`
`MR. ALPERT: Let's break this down.
`
`I don't
`
`think there's a privilege anymore, frankly, but
`
`I'll ask it the way you want it, and we'll talk
`
`about whether the privilege exists anymore.
`
`That‘s fair. Good point.
`
`BY MR. ALPERT:
`
`Q.
`
`Have you --
`
`MR. ALPERT:
`
`Is this the question you wanted
`
`me to ask? And I want to make sure I ask the
`
`question.
`
`MR. KAISER:
`
`It's not my question.
`
`It's
`
`your question.
`
`MR. ALPERT: Well,
`
`there was a question that
`
`14
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`19
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`23
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`24
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`
`ESQUIRE
`
`“‘ ’“°""““‘" °““° °°"“"'“"
`
`Toll Free: 800.944.9454
`Facsimile: 212.
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