`
`Exhibit 25
`Public Redacted
`Version
`
`
`
`Case 1:20-cv-00393-LMB-WEF Document 1462-24 Filed 04/05/23 Page 2 of 6 PageID# 39791
`
`1
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`2
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`3
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`UNITED STATES DISTRICT COURT
`
`EASTERN DISTRICT OF VIRGINIA
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`Page 1
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`4 RAI Strategic Holdings,
`
`Inc. , et al. ,
`
`Plaintiffs,
`
`-against-
`
`5
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`6
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`7
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`8
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`9
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`10 Altria Client Services LLC,
`
`11 et al . ,
`
`Civil Action
`
`No. 120 CV
`
`00393
`
`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
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`18
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`19
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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
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`25
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`Defendants.
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`VIDEO-RECORDED 30(b) (6)
`
`DEPOSITION OF EDWARD KIERNAN
`
`Zoom Recorded Videoconference
`
`04/16/2021
`
`1:21 p.m . CEST
`
`REPORTED BY: AMANDA GORRONO, CLR
`
`CLR NO. 052005-01
`
`JOB NO. 192651
`
`
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`Case 1:20-cv-00393-LMB-WEF Document 1462-24 Filed 04/05/23 Page 3 of 6 PageID# 39792
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`Page 23
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`1 E. Kiernan
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`2 question?
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`3 Q. Yes, is it.
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`4 A. I assume that -- I'll make an
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`5 assumption that it is. I don't know
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`6 because I'm not often on LinkedIn, but,
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`7 yes.
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`8 Q. Okay. It lists here as your
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`9 current employer Philip Morris
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`10 International, but we established -- you
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`11 said your current employer is actually
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`12 Philip Morris Products right now; is that
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`13 correct?
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`14 A. That's correct.
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`15 Q. Okay. And I understand from
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`16 this that you're currently the director of
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`17 IP management at -- is that Philip Morris
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`18 Products?
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`19 A. Correct. But I actually -- like
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`20 I said, I'm not on LinkedIn often. They
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`21 change the title, so I actually have a
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`22 different title, currently.
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`23 Q. Okay. And what's your current
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`24 title?
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`25 A. Global head of IP management.
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`
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`Case 1:20-cv-00393-LMB-WEF Document 1462-24 Filed 04/05/23 Page 4 of 6 PageID# 39793
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`Page 24
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`1 E. Kiernan
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`2 Q. And is that -- are you serving
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`3 in the same role with just a different
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`4 title, or is that a new --
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`5 A. Yes, no, same role, different
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`6 title.
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`7 Q. Okay. And so you've been in
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`8 this role for -- looks like a little more
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`9 than 3 years; is that correct?
`
`10 A. Correct.
`
`11 Q. And what are your
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`12 responsibilities as global head of IP
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`13 management?
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`14 A. To protect PMI's innovations and
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`15 set strategy with regard to the capture of
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`16 intellectual property.
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`17 Q. And does your role involve
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`18 protecting innovations and setting
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`19 strategy for both noncombustible and
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`20 combustible nicotine products?
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`21 A. Yes.
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`22 Q. And in this role as global head
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`23 of IP management, are you serving as a --
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`24 in a legal role?
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`25 A. No.
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`
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`Case 1:20-cv-00393-LMB-WEF Document 1462-24 Filed 04/05/23 Page 5 of 6 PageID# 39794
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`1
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`2
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`5
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`6
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`8
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`18
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`19
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`20
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`24
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`25
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`E . Kiernan
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`Page 37
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`MR. SOBOLSKI: Objection;
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`outside of the scope, vague, lack of
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`foundation.
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`A.
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`MR. SOBOLSKI: Objection;
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`outside the scope, asked and answered.
`
`A.
`
`A.
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`MR. SOBOLSKI: Sarne objections.
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`
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`Case 1:20-cv-00393-LMB-WEF Document 1462-24 Filed 04/05/23 Page 6 of 6 PageID# 39795
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`1
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`2
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`6
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`7
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`Q.
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`A.
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`E . Kiernan
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`Page 38
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`MR. SOBOLSKI: Sarne objections.
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`13
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`14
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`MR. SOBOLSKI: Sarne objections.
`I
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`A.
`
`
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