Case 5:19-cv-00036-RWS Document 66-8 Filed 08/27/19 Page 1 of 7 PageID #: 2776
`Case 5:19-cv-00036—RWS Document 66-8 Filed 08/27/19 Page 1 of 7 PageID #: 2776
`PUBLIC VERSION
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`EXHIBIT 7
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`EXHIBIT 7
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`PUBLIC VERSION
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`Case 5:19-cv-00036—RWS Document 66-8 Filed 08/27/19 Page 1 of 7 PageID #: 2776
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`EXHIBIT 7
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`EXHIBIT 7
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`PUBLIC VERSION
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`Case 5:19-cv-00036-RWS Document 66-8 Filed 08/27/19 Page 2 of 7 PageID #: 2777
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`Case 1:18-cv-00158-LY Document 55-4 Filed 02/15/19 Page 2 of 7
`Case 1:18—cv-00158—LY Document 55-4 Filed 02/15/19 Page 2 of 7
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`In the Matter of:
`
`Um'loc USA, Inc., et al vs
`
`Apple Inc.
`
`Kayla Christie
`
`January 08, 2019
`
`{103%}?R “paints
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`Case 5:19-cv-00036-RWS Document 66-8 Filed 08/27/19 Page 3 of 7 PageID #: 2778
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`Case 1:18-cv-00158-LY Document 55-4 Filed 02/15/19 Page 3 of 7
`Case 1:18-cv-00158-LY Document 55-4 Filed 02/15/19 Page 3 of 7
`
`Uniloc USA, Inc., et al vs
`Apple Inc.
`
`Attorneys Eyes Only
`
`Kayla Christie
`January 08, 2019
`
`PROCEEDINGS
`
`LOOONGU‘I-P-UJNl—l
`
`|—‘ O
`
`MR. ERCOLINI: Michaei Ercoiini for
`
`the piaintiff Uni1oc.
`
`MR. GUARAGNA:
`
`John Guaragna for
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`App1e.
`
`MR. BREVERMAN: Marc Breverman,
`
`in—house counsei for App1e.
`
`THE WITNESS: Kay1a Christie for
`
`Appie.
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`KAYLA CHRISTI E ,
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`H H ca11ed as a witness, having been duiy sworn by a
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`[—1 N Notary Pubiic, was examined and testified as
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`to11ows:
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`+1P‘A(M
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`l—l LJ'I BY MR . ERCOLINI:
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`EXAMINATION
`
`Q.
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`l—‘|—‘\icn Mike Ercoiini.
`
`Morning. We'11 get to that. My name is
`
`I'm an attorney for Uniioc in these
`
`H m matters and I'm just here to ask you some questions
`
`H “3 about your —— about App1e's operations in and around
`
`N 0 Austin, Texas, and Texas genera11y.
`
`First of a11, can you state your fuii
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`N N name for me.
`
`
`
`N |--‘
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`N W
`
`N .b
`
`A.
`
`Q.
`
`Kayia Christie.
`
`Okay. Have you ever been deposed before,
`
`O'Brien & Levine Court Reporting Solutions
`888.825.3376 - production@court-reporting.com
`
`Page 8
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`PUBLIC VERSION
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`Case 5:19-cv-00036-RWS Document 66-8 Filed 08/27/19 Page 4 of 7 PageID #: 2779
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`Case 1:18-cv-00158-LY Document 55-4 Filed 02/15/19 Page 4 of 7
`Case 1:18-cv-00158-LY Document 55-4 Filed 02/15/19 Page 4 of 7
`
`Uniloc USA, Inc., et al vs
`Apple Inc.
`
`Attorneys Eyes Only
`
`
`Kayla Christie
`January 08, 2019
`
`A.
`
`Yeah.
`
`I have —— I include that, sorry,
`
`LOOOVCTAU'IAUUNH
`
`HO
`
`H N
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`in the Mac product line, with this team that I just
`
`mentioned.
`
`Q.
`
`Okay.
`
`So the Mac Pro is manufactured in
`
`Texas?
`
`A.
`
`We do have a vendor that does produce
`
`some manufacturing for our Mac.
`
`Q.
`
`Okay. what's the name of that vendor?
`
`Flextronics.
`
`Q.
`
`Flextronics. And how long has
`
`H H Flextronics been manufacturing Mac Pros in Texas?
`
`A.
`
`It would be a guess, but I would say less
`
`
`
`H UJ than four years.
`
`P‘ldw-b clarify,
`
`MR. GUARAGNA: Counsel,
`
`just to
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`I'm going to designate the transcript
`
`H 03 attorneys' eyes only, outside counsel.
`
`F4Flldtoc»-u
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`MR. ERCOLINI:
`
`Sure.
`
`BY MR. ERCOLINI:
`
`Q.
`
`Do you know approximately how large the
`
`N O Flextronics facility is in terms of employees?
`
`A.
`
`I do not know the answer to the
`
`NNmild Flextronics Apple Play account.
`
`N L»
`
`Q.
`
`Do you know approximately —— well, strike
`
`N .b the question.
`
`O'Brien & Levine Court Reporting Solutions
`888.825.3376 - production@court—reporting.com
`
`Page 30
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`PUBLIC VERSION
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`Case 5:19-cv-00036-RWS Document 66-8 Filed 08/27/19 Page 5 of 7 PageID #: 2780
`
`Case 1:18-cv-00158-LY Document 55-4 Filed 02/15/19 Page 5 of 7
`Case 1:18-cv-00158-LY Document 55-4 Filed 02/15/19 Page 5 of 7
`
`Uniloc USA, Inc., et al vs
`Apple Inc.
`
`Attorneys Eyes Only
`
`Kayla Christie
`January 08, 2019
`
`A.
`
`It's part of what App1e wou1d consider
`
`“DOOVONU'I-D-UJNH
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`its Austin campuses.
`
`Q.
`
`Its Austin campuses, which inc1ude how
`
`many 1ocations?
`
`A.
`
`Sorry. There are —— there's the Parmer
`
`Lane campus area,
`
`there's this one that is 1ooked
`
`upon as a connection to the Parmer Lane campus and
`
`then there's Capita1 Ridge, which is 30 minutes
`
`away.
`
`H O
`
`Q.
`
`Is it named —— informa11y within App1e,
`
`'—| H has a name been assigned to this campus yet?
`
`|—||—|WM
`
`A.
`
`Q.
`
`NO.
`
`It says in the third paragraph, "Jobs
`
`|—‘ .5 created at the new campus wi11 inc1ude a broad range
`
`[.4 U1 of functions inc1uding engineering, R&D, operations,
`
`[—1 Ch finance, sa1es and customer support.”
`
`|_| V
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`l-‘I—‘L000
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`A.
`
`Q.
`
`DO you see that?
`
`Yes.
`
`Okay.
`
`Can you te11 me of these broad ——
`
`N O of this range of functions, which functions are
`
`N [—1 current1y performed at one or more 1ocations ——
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`N N App1e 1ocations within Austin a1ready.
`
`NN-I>UU
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`A.
`
`Q.
`
`A11 of them.
`
`A11 of them?
`
`O'Brien & Levine Court Reporting Solutions
`888.825.3376 - production@court-reporting.com
`
`Page 131
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`PUBLIC VERSION
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`Case 5:19-cv-00036-RWS Document 66-8 Filed 08/27/19 Page 6 of 7 PageID #: 2781
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`Case 1:18-cv-00158-LY Document 55-4 Filed 02/15/19 Page 6 of 7
`Case 1:18—cv-00158—LY Document 55-4 Filed 02/15/19 Page 6 of 7
`
`Uniloc USA, Inc., et al vs
`Apple Inc.
`
`Attorneys Eyes Only
`
`Kayla Christie
`January 08, 2019
`
`1 BY MR. ERCOLINI:
`
`Q.
`
`Okay.
`
`So engineering and R&D,
`
`they
`
`shouidn't be distinct in this?
`
`A.
`
`R&D is an umbreiia to 1abe1 software,
`
`hardware, hardware technoiogies, et cetera.
`
`So I
`
`think they were just minimizing the number of areas
`
`that they needed to expiain ——
`
`Q.
`
`A.
`
`Okay.
`
`—— that to the externai wor1d that isn't
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`LDOOVONLn-PUJN
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`I—‘ O necessary.
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`
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`H H
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`l—‘ N
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`H L»
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`I—‘ U'I
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`H m
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`|-‘ \l
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`I—‘l—lL000
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`N O
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`N |_|
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`N N
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`NN#UJ
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`Q.
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`Operations, what does that refer to?
`
`Logistics.
`
`Q.
`
`And which iocations is iogistics
`
`H A functions performed?
`
`In Texas, it's in Austin.
`
`which campus?
`
`Parmer Lane.
`
`Parmer Lane.
`
`Finance?
`
`Parmer Lane.
`
`Parmer Lane. And can you te11 me what
`
`finance are performed at Parmer Lane?
`
`Shared service center.
`
`Shared service center.
`
`Yeah.
`
`O'Brien & Levine Court Reporting Solutions
`888.825.3376 - production@couIt-reporting.com
`
`Page 133
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`PUBLIC VERSION
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`Case 5:19-cv-00036-RWS Document 66-8 Filed 08/27/19 Page 7 of 7 PageID #: 2782
`
`Case 1:18-cv-00158-LY Document 55-4 Filed 02/15/19 Page 7 of 7
`Case 1:18-cv-00158-LY Document 55-4 Filed 02/15/19 Page 7 of 7
`
`Uniloc USA, Inc., et al vs
`Apple Inc.
`
`Attorneys Eyes Only
`
`Kayla Christie
`January 08, 2019
`
`Q.
`
`what is that?
`
`LDOONOWU'l-P-UUNI—l
`
`|-‘ W
`
`l—‘ U'I
`
`A.
`
`And that inciudes revenue reporting,
`
`coiiections, accounts payabie,
`
`treasury; we have
`
`payroii, compensation services, accounting,
`
`royaities.
`
`Q.
`
`And royaities?
`
`Uh—huh.
`
`Q.
`
`So revenue,
`
`is that for any particuiar
`
`segment within Appie or ——
`
`A.
`
`Q.
`
`l—‘I—‘I—lNl—‘O to?
`
`It's for aii of Appie.
`
`A11 of Appie. And then royaities refers
`
`A.
`
`Royaities refers to our reiationships
`
`H 4} with our app deveiopers, our —— the movie houses,
`
`iTunes, whomever we need to pay royaities to.
`
`So
`
`I--‘ 03 it's in the accounts payabie department, but it's
`
`|—‘ \I kind of separate. And actuaiiy,
`
`travei is here as
`
`
`
`weii and it's under finance.
`
`Q.
`
`A11 right. And then royaities, does that
`
`N O inciude royaities for 1icensed technoiogies?
`
`NO.
`
`No. where wou1d that be covered?
`
`I actuaiiy don't know.
`
`Okay.
`
`Do you —— I mean, do you know
`
`A.
`
`Q A
`
`.
`
`Q
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`O'Brien & Levine Court Reporting Solutions
`888.825.3376 - production@court-reporting.com
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`Page 134
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`HHLooo
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`N 4s
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