`Case 1:20-cv-00393-LO-TCB Document 1093-6 Filed 02/25/22 Page 1 of 3 PagelD# 29981
`
`
`
`EXHIBIT 6
`EXHIBIT 6
`
`
`
`
`
`
`Case 1:20-cv-00393-LO-TCB Document 1093-6 Filed 02/25/22 Page 2 of 3 PageID# 29982
`921
`
`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF VIRGINIA
`Alexandria Division
`
`-------------------------------:
`:
`TECSEC, INCORPORATED,
`:
`Plaintiff,
`
`::
`
`:
`
`-vs-
`
`Case No. 1:10-cv-115
`
`Volume 4 - P.M.
`
`::
`
`ADOBE INC., et al.,
`Defendants.
`-------------------------------:
`
`::
`
`:
`
`JURY TRIAL PROCEEDINGS
`
`December 13, 2018
`
`Before: Liam O'Grady, USDC Judge
`
`And a Jury
`
`Norman Linnell and Anneliese Thomson - EDVA-OCRs (703)549-4626
`
`
`
`R. Sullivan - Direct
`Case 1:20-cv-00393-LO-TCB Document 1093-6 Filed 02/25/22 Page 3 of 3 PageID# 29983
`1009
`
`be used without the multi-level encryption capability?
`A.
`Yes, I was.
`Q.
`And do you understand the concept of non-infringing
`alternatives?
`A.
`I do.
`Q.
`And how does the availability of non-infringing
`alternatives impact your damages analysis?
`A.
`Well, non-infringing alternatives place a limit on how
`much a licensee would be willing to pay for a technology. As
`Mr. Wagner and I both agree, the impact or cost of those
`non-infringing alternatives limits the amount of royalties that
`would be agreed upon, which is another way of saying that
`$4 million or more for the technology is well above the
`non-infringing alternatives that would be available, and thus,
`that's another reason as to why that would not be considered
`reasonable.
`Q.
`And do you understand what the cost of a non-infringing
`alternative would be for Adobe?
`A.
`My -- yes. I have heard testimony in that regard that it
`would cost between 120,000 and 200,000 dollars to, to remove
`the functionality.
`Q.
`And would you speak to the economic rationale of choosing
`a non-infringing alterative as opposed to a price higher than
`that?
`A.
`
`Well, certainly that places limitations on what the
`
`1 2 3 4 5 6 7 8 9
`
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`Norman Linnell and Anneliese Thomson - EDVA-OCRs (703)549-4626
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
