`Case 2:23-cv-00059-JRG Document 187-2 Filed 09/05/24 Page 1 of 3 PagelD #: 10198
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`EXHIBIT M
`EXHIBIT M
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`Case 2:23-cv-00059-JRG Document 187-2 Filed 09/05/24 Page 2 of 3 PageID #: 10199
`CONFIDENTIAL
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` IN THE UNITED STATES DISTRICT COURT
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` FOR THE EASTERN DISTRICT OF TEXAS
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` MARSHALL DIVISION
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` Lead Case No. 2:23-cv-00059-JRG
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` Member Case No. 2:23-cv-00062-JRG
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` ______________________________________________________
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` CONFIDENTIAL VIDEO-RECORDED VIDEOCONFERENCE DEPOSITION
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` OF: JOSHUA SEIDEN - June 4, 2024
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` ______________________________________________________
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` TOUCHSTREAM TECHNOLOGIES, INC.,
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` Plaintiff,
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` v.
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` CHARTER COMMUNICATIONS, INC., et al.,
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` Defendants.
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` ______________________________________________________
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` TOUCHSTREAM TECHNOLOGIES, INC.,
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` Plaintiff,
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` v.
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` COMCAST CABLE COMMUNICATIONS, LLC, D/B/A XFINITY, et
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` al.,
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` Defendants.
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` ______________________________________________________
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` PURSUANT TO NOTICE AND AGREEMENT, the
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` CONFIDENTIAL VIDEO-RECORDED VIDEOCONFERENCE DEPOSITION
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`21
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` OF JOSHUA SEIDEN was taken on behalf of the Plaintiff
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` via videoconference per stipulation of all parties, on
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`22
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` June 4, 2024, at 8:59 a.m., before Haley L. Bortz,
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` Registered Professional Reporter, Certified Realtime
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` Reporter, and Notary Public within Colorado.
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`Veritext Legal Solutions
`346-293-7000
`
`Page 1
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`
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`Case 2:23-cv-00059-JRG Document 187-2 Filed 09/05/24 Page 3 of 3 PageID #: 10200
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` needed, once they were functioning they had to do what
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` they do to deploy a product so we stepped out of the
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` way.
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` Q. That's what I'm trying to figure out. If we
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` are talking about even getting to
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` September -- August/September of 2010, what they did to
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` deploy the commercial product, that's not something
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` that you could testify about from your personal
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` knowledge; right?
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` A. Correct.
`
` Q. Thinking about this time frame, you know, you
`
` had the prototype, you're starting the -- the handoff,
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` do you recall what documents would have been passed off
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` to the product team; what sort of documentation did
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` your team provide the products team as part of the
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` handoff?
`
` A. Well, you can imagine. I mean, we provided
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` design, architecture, XML specs, the design of how to
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` make it work.
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` Q. How voluminous was that to the best of your
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` recollection?
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` A. I can't remember. That was a long time ago.
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` Q. Hundreds of pages, 20 pages, thousands of
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` pages?
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` A. It was absolutely not hundreds of pages. It
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`Veritext Legal Solutions
`346-293-7000
`
`Page 34
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