throbber
Case 5:19-cv-00036-RWS Document 66-7 Filed 08/27/19 Page 1 of 7 PageID #: 2769
`Case 5:19-cv-00036—RWS Document 66-7 Filed 08/27/19 Page 1 of 7 PageID #: 2769
`PUBLIC VERSION
`
`EXHIBIT 6
`
`EXHIBIT 6
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`PUBLIC VERSION
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`

`

`Case 5:19-cv-00036-RWS Document 66-7 Filed 08/27/19 Page 2 of 7 PageID #: 2770
`
`Case 1:18-cv-00158-LY Document 55-6 Filed 02/15/19 Page 2 of 7
`Case 1:18—cv-00158—LY Document 55-6 Filed 02/15/19 Page 2 of 7
`
`In the Matter of:
`
`Uniloc USA, Inc., et al vs
`
`Apple Inc.
`
`COURTREPQRTiNG SULHTIUNS
`
`Bodie P. Nash
`
`January 09, 2019
`
`68 Commercial W/wnfo Boston, MA 02110
`888.825 3376 617.399. 01.30
`
`610652! Covemgc
`COtlf'tfié’IIOIflfig. 607%
`
`1%%
`3:3L19 E1
`an {1nn
`"'1‘; grflrg
`fm‘$11::
`
`PUBLIC VERSION
`
`

`

`Case 5:19-cv-00036-RWS Document 66-7 Filed 08/27/19 Page 3 of 7 PageID #: 2771
`
`Case 1:18-cv-00158-LY Document 55-6 Filed 02/15/19 Page 3 of 7
`Case 1:18-cv-00158-LY Document 55-6 Filed 02/15/19 Page 3 of 7
`
`Uniloc USA, Inc., et al vs
`Apple Inc.
`
`Attorneys Eyes Only
`
`Bodie P. Nash
`January 09, 2019
`
`PROCEEDINGS
`
`BODIE P. NASH,
`
`caiied as a witness, having been du1y sworn by a
`
`Notary Pubiic, was examined and testified as
`
`foIiows:
`
`BY MR. ERCOLINI:
`
`EXAMINATION
`
`Q.
`
`A.
`
`Morning, Mr. Nash.
`
`Morning.
`
`to be asking you some questions today about App1e's
`
`MR. BREVERMAN:
`
`Can we State
`
`appearances before we start?
`
`MR. ERCOLINI:
`
`Sure. Michaei
`
`ErcoIini, piaintiff Uniioc.
`
`Appie.
`
`MR. GUARAGNA:
`
`John Guaragna for
`
`MR. BREVERMAN: Marc Breverman,
`
`in—house counsei for Appie.
`
`BY MR. ERCOLINI:
`
`Q.
`
`Good morning again, Mr. Nash.
`
`Good morning.
`
`Q.
`
`My name is Mike Ercoiini.
`
`I'm an
`
`attorney for Uni10c in a number of cases in the
`
`Western District of Texas against Appie.
`
`I'm going
`
`O'Brien & Levine Court Reporting Solutions
`888.825.3376 - production@court-reporting.com
`
`Page 8
`
`PUBLIC VERSION
`
`

`

`Case 5:19-cv-00036-RWS Document 66-7 Filed 08/27/19 Page 4 of 7 PageID #: 2772
`
`Case 1:18-cv-00158-LY Document 55-6 Filed 02/15/19 Page 4 of 7
`Case 1:18-cv-00158-LY Document 55-6 Filed 02/15/19 Page 4 of 7
`
`Bodie P. Nash
`Attorneys Eyes Only
`Uniloc USA, Inc., et al vs
`
`Apple Inc. January 09, 2019
`
`Q.
`
`Okay.
`
`I'm sti11 trying to understand
`
`LOOOVGU'l-PUUNl—l
`
`exactiy what shared services is.
`
`A.
`
`I wouid think generaiiy ——
`
`MR. GUARAGNA: Objection, asked and
`
`answered.
`
`BY MR. ERCOLINI:
`
`Q.
`
`A.
`
`So if you couid c1arify.
`
`Generaiiy, a shared service is a service
`
`1ike human resources or 1ike finance,
`
`that mu1tip1e
`
`|—‘ O organizations use to support the operation of their
`
`'—| |_| business.
`
`H N
`
`Q.
`
`Okay.
`
`It says the job at the new campus
`
`wi11 inc1ude finance.
`
`H+4Akn Operation Center that —— strike the question.
`
`Is that at the Americas
`
`|_| U'l
`
`|—‘ \l
`
`Are finance functions performed at the
`
`H m Americas Operations Center in Austin?
`
`A.
`
`Are you referring to the Parmer Lane
`
`H 00 campus?
`
`
`
`NNl—ll—‘OO
`
`N W
`
`Q.
`
`A.
`
`Q.
`
`Right.
`
`Yes,
`
`they are.
`
`Can you teii me what finance functions
`
`N N are performed there?
`
`A.
`
`Very generaiiy,
`
`there are 10ts of
`
`N 4:. functions performed by the finance organization.
`
`O'Brien & Levine Court Reporting Solutions
`888.825.3376 — producti0n@court-reporting.com
`
`Page 59
`
`PUBLIC VERSION
`
`

`

`Case 5:19-cv-00036-RWS Document 66-7 Filed 08/27/19 Page 5 of 7 PageID #: 2773
`
`Case 1:18-cv-00158-LY Document 55-6 Filed 02/15/19 Page 5 of 7
`Case 1:18-cv-00158-LY Document 55-6 Filed 02/15/19 Page 5 of 7
`
`Uniloc USA, Inc., et al vs
`Apple Inc.
`
`Attorneys Eyes Only
`
`Bodie P. Nash
`January 09, 2019
`
`Q.
`
`Revenue reporting?
`
`LOOOVChU'l-D-UJNI—l
`
`A.
`
`I beiieve so, yes. Revenue recording,
`
`for sure.
`
`Q.
`
`Customer support,
`
`is that function
`
`performed at the Parmer Lane office?
`
`A.
`
`Q.
`
`A.
`
`Q.
`
`Yes.
`
`Capitai Ridge as weii?
`
`NO.
`
`Okay.
`
`For what products is customer
`
`[.4 0 support performed at the Parmer Lane office?
`
`MR. GUARAGNA: Objection,
`
`re1evance,
`
`I—‘ N outside the scope.
`
`Same objections.
`
`|_| |_|
`
`F‘F‘F‘U1ALN
`
`|_| Ch
`
`|—\ \I
`
`A.
`
`Most. Most ——
`
`BY MR. ERCOLINI:
`
`Q.
`
`A.
`
`Q.
`
`Most products?
`
`Most products, yes.
`
`Are there any products you can identify
`
`|—‘ 00 for which customer support is not done at Parmer
`
`5.x 0 Lane?
`
`N O
`
`N H
`
`MR. GUARAGNA:
`
`Not specificaiiy.
`
`22 BY MR. ERCOLINI:
`
`M W
`
`24 office?
`
`
`Is marketing done at the Parmer Lane
`
`
`
`O'Brien & Levine Court Reporting Solutions
`888.825.3376 - producti0n@court-reporting.com
`
`Page 60
`
`PUBLIC VERSION
`
`

`

`Case 5:19-cv-00036-RWS Document 66-7 Filed 08/27/19 Page 6 of 7 PageID #: 2774
`
`Case 1:18-cv-00158-LY Document 55-6 Filed 02/15/19 Page 6 of 7
`Case 1:18-cv-00158-LY Document 55-6 Filed 02/15/19 Page 6 of 7
`
`Uniloc USA, Inc., et al vs
`Bodie P. Nash
`Apple Inc.
`January 09, 2019
`
`
`Attorneys Eyes Only
`
`1 knowledge. Most generally in the Parmer Lane
`
`campus, AppleCare, which supports all products, all
`
`kDOOVOWLn-PUUN
`
`consumer products.
`
`Q.
`
`Can you elaborate on what the customer
`
`support functions are at that Parmer Lane campus?
`
`A.
`
`It's a very detailed functionality, but
`
`if you think through the —— if you had a problem
`
`with your device and wanted to contact somebody at
`
`Apple about your device, whether that be an iOS
`
`H0 device or a Mac device, you would call
`
`into
`
`H H AppleCare, a warranty protection program and speak
`
`H N to them about technical support.
`
`H W
`
`Q.
`
`Okay.
`
`So if I had a problem with my
`
`H.p. passcode on my iPhone and I wanted to direct that to
`
`H U'I AppleCare, would a representative at the Parmer Lane
`
`H 03 campus be available?
`
`FlPl00V speculation.
`
`MR. GUARAGNA: Objection, calls for
`
`H LO
`
`A.
`
`Could be, yes.
`
`BY MR. ERCOLINI:
`
`
`
`NNNNI—‘O technology that's identified in Exhibit 4, would
`
`Q.
`
`Okay. And with respect to AirDrop
`
`N W that also be something that I could direct to
`
`24 AppleCare?
`
`
`
`
`O'Brien & Levine Court Reporting Solutions
`888.825.3376 - production@court—reporting.com
`
`Page 101
`
`PUBLIC VERSION
`
`

`

`Case 5:19-cv-00036-RWS Document 66-7 Filed 08/27/19 Page 7 of 7 PageID #: 2775
`
`Case 1:18-cv-00158-LY Document 55-6 Filed 02/15/19 Page 7 of 7
`Case 1:18-cv-00158-LY Document 55-6 Filed 02/15/19 Page 7 of 7
`
`Uniloc USA, Inc., et al vs
`Apple Inc.
`
`Attorneys Eyes Only
`
`Bodie P. Nash
`January 09, 2019
`
`I be1ieve so, yes.
`
`LOOOVCBU'I-PUUNI—l
`
`H O
`
`FaceTime issues?
`
`I beiieve so.
`
`And iMessage?
`
`Yes.
`
`Q.
`
`Outside of the Parmer Lane campus and the
`
`Capitai Ridge campus,
`
`there's another campus that's
`
`currentiy being buiit,
`
`is that correct,
`
`in Austin?
`
`A.
`
`Q.
`
`Announced.
`
`Announced.
`
`Is there a name internaiiy
`
`|_| |_| for that campus?
`
`H N
`
`A.
`
`Specuiation, but —— probabiy, but not to
`
`[.4 UL) my knowiedge.
`
`I don't know what that name is.
`
`|_\ A
`
`Q.
`
`And approximateiy how many peopie are
`
`I—‘ U'l empioyed at Parmer Lane?
`
`H 01
`
`Hi4CON
`
`A.
`
`Q.
`
`A.
`
`Approximateiy 6,000.
`
`6,000. And at Capitai Ridge?
`
`I'm sorry,
`
`I misspoke.
`
`Probabiy within
`
`I—‘ k0 Austin and those two campuses, 6,000.
`
`So maybe 5400
`
`N .b
`
`and 600; 5400 Parmer Lane, 600 in Capitai Ridge.
`
`NNNNI—‘O are you aware of any other Appie offices that
`
`Q.
`
`Thank you. within the state of Texas,
`
`N W empioy, 1et's say, over 500 peopie?
`
`A.
`
`NO.
`
`O'Brien & Levine Court Reporting Solutions
`888.825.3376 - production@court-reporting.com
`
`Page 102
`
`PUBLIC VERSION
`
`

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