`
`
`In the Matter of
`
`CERTAIN MOBILE DEVICES
`AND RELATED SOFTWARE
`
`
`
`
`UNITED STATES INTERNATIONAL TRADE COMMISSION
`WASHINGTON, D.C.
`
`Before the Honorable Theodore R. Essex
`Administrative Law Judge
`
`
`
`
`
`
`Investigation No. 337-TA-750
`
`RESPONDENT MOTOROLA MOBILITY, INC.’S RESPONSES TO APPLE’S
`OBJECTIONS TO MOTOROLA’S REBUTTAL EXHIBITS
`
`Pursuant to Order No. 9, Respondent Motorola Mobility, Inc. (“Motorola”)
`
`hereby submits its responses to Complainant Apple, Inc.’s (“Apple”) objections to
`
`Motorola’s rebuttal trial exhibits (including witness statements), served on September 12,
`
`2011. Motorola’s responses to Apple’s objections to Motorola’s rebuttal exhibits are
`
`listed in Attachment A and include a column entitled “Motorola’s Response to Apple’s
`
`Objections.” Motorola’s responses to Apple’s objections to Motorola’s rebuttal witness
`
`statement are set forth below. These responses are based on the objections asserted by
`
`Apple. Motorola specifically reserves the right to amend these responses in the event
`
`that Apple clarifies its objections or raises new objections. Motorola also reserves the
`
`right to respond to any evidentiary objections that were raised in Apple’s motions in
`
`limine or otherwise.
`
`
`
`
`
`
`
`
`
`MOTOROLA’S RESPONSES TO APPLE INC.’S OBJECTIONS TO THE
`WITNESS STATEMENT [RX-1859C] OF DALE BENGTSON
`
`
`Question and
`Answer Number in
`Witness Statement
`
`Notes/Exhibits
`
`Objections
`
`Motorola’s Responses to Apple’s
`Objections
`
`Q. 1-142 (All)
`
`Q. 32, 52, 54, 63-
`64, 68-69
`
`Q. 35, 37, 51, 53
`
`Q. 42-47, 55-61,
`65-67, 71, 106, 108-
`110, 116, 124
`
`
`
`
`
`
`
`
`
`
`
`MIL
`
`FRE 701, FRE 702
`
`Vague, FRE 611,
`FRE 701, FRE 702
`
`FRE 602
`
`Q. 48, 62
`
`FRE 602, FRE 611,
`FRE 701, FRE 702
`
`
`
`
`
`
`
`2
`
`Motorola has responded separately
`to Apple’s motion in limine
`concerning Mr. Bengtson’s
`testimony pursuant to the Procedural
`Schedule.
`Not opinion testimony by a lay
`witness and not expert opinion
`testimony. The questions call for
`and the testimony offers facts based
`on Mr. Bengtson’s personal
`knowledge.
`The questions are sufficiently clear.
`
`The questions do not suggest an
`answer and are therefore not leading.
`
`Not opinion testimony by a lay
`witness and not expert opinion
`testimony. The questions call for
`and the testimony offers facts based
`on Mr. Bengtson’s personal
`knowledge.
`Foundation for Mr. Bengtson’s
`personal knowledge is provided in
`his earlier testimony. Further
`foundation, if needed, may be
`provided on re-direct.
`Foundation for Mr. Bengtson’s
`personal knowledge is provided in
`his earlier testimony. Further
`foundation, if needed, may be
`provided on re-direct.
`
`The questions do not suggest an
`answer and are therefore not leading.
`
`Not opinion testimony by a lay
`
`
`
`
`
`Question and
`Answer Number in
`Witness Statement
`
`Notes/Exhibits
`
`Objections
`
`Motorola’s Responses to Apple’s
`Objections
`
`witness and not expert opinion
`testimony. The questions call for
`and the testimony offers facts based
`on Mr. Bengtson’s personal
`knowledge.
`Motorola withdraws Questions 73-
`75 based on agreement with Apple
`that testimony concerning products
`no longer at issue will not be
`presented.
`
`Question 121 is relevant to non-
`infringement.
`
`Foundation for Mr. Bengtson’s
`personal knowledge is provided in
`his earlier testimony. Further
`foundation, if needed, may be
`provided on re-direct.
`Motorola withdraws questions 79-
`84, and 89-92 based on agreement
`with Apple that testimony
`concerning products no longer at
`issue will not be presented.
`
`Questions 85, 86, 87, 93 and 94 are
`relevant to non-infringement.
`Motorola withdraws questions 88
`and 95 based on agreement with
`Apple that testimony concerning
`products no longer at issue will not
`be presented..
`
`Not opinion testimony by a lay
`witness and not expert opinion
`testimony. The questions call for
`and the testimony offers facts based
`on Mr. Bengtson’s personal
`knowledge.
`Foundation for Mr. Bengtson’s
`
`FRE 402, FRE 602
`
`FRE 402
`
`FRE 402, FRE 701,
`FRE 702
`
`FRE 602, FRE 701,
`
`3
`
`
`
`
`
`
`
`
`
`Q. 73-75, 121
`
`Q. 79-87, 89-94,
`96-102
`
`Q. 88, 95
`
`Q. 107, 115, 120,
`
`
`
`
`
`
`
`Motorola’s Responses to Apple’s
`Objections
`
`personal knowledge is provided in
`his earlier testimony. Further
`foundation, if needed, may be
`provided on re-direct.
`
`Not opinion testimony by a lay
`witness and not expert opinion
`testimony. The questions call for
`and the testimony offers facts based
`on Mr. Bengtson’s personal
`knowledge.
`
`
`
`Notes/Exhibits
`
`Question and
`Answer Number in
`Witness Statement
`123, 128, 135-141
`
`Objections
`
`FRE 702
`
`
`
`
`4
`
`
`
`
`
`
`
`
`
`
`
`MOTOROLA’S RESPONSES TO APPLE INC.’S OBJECTIONS TO THE
`REBUTTAL WITNESS STATEMENT [RX-1860C] OF DAVID BOLDT
`
`
`Question and
`Answer
`Number in
`Witness
`Statement
`
`Notes/
`Exhibits Objections
`
`Motorola’s Responses to Apple’s Objections
`
`
`
`
`
`
`
`
`
`
`
`V, F
`
`V, F
`
`V, F
`
`V, F
`
`V, F
`
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`
`5
`
`7
`
`14
`
`16
`
`17
`
`18
`
`
`
`
`
`
`
`
`
`
`Question and
`Answer
`Number in
`Witness
`Statement
`
`19
`
`28
`
`29
`
`34
`
`V, F
`
`
`
`
`
`
`Notes/
`Exhibits Objections
`
`Motorola’s Responses to Apple’s Objections
`
`V, F
`
`V, F
`
`V, F, FRE
`602, FRE
`701, FCGR
`9.1
`
`
`
`
`
`
`
`
`
`redirect.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`
`Mr. Boldt has personal knowledge. See, e.g., Mr.
`Boldt’s testimony, Q/A 5-17.
`
`Not opinion testimony by lay witness and not
`expert opinion testimony. The question calls for facts
`and the testimony offers facts based on Mr.
`Boldt’s personal knowledge.
`
`This testimony sets forth factual material, not legal
`argument.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`
`6
`
`
`
`
`
`Question and
`Answer
`Number in
`Witness
`Statement
`
`35
`
`38
`
`39
`
`
`
`
`
`
`Notes/
`Exhibits Objections
`
`Motorola’s Responses to Apple’s Objections
`
`
`
`
`
`
`
`V, F
`
`V, F, FRE
`602, FRE
`701, FCGR
`9.1
`
`V, F, FRE
`602, FRE
`701, FCGR
`9.1
`
`further foundation, if needed, may be provided on
`redirect.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`
`Mr. Boldt has personal knowledge. See, e.g., Mr.
`Boldt’s testimony, Q/A 5-17.
`
`Not opinion testimony by lay witness and not
`expert opinion testimony. The question calls for facts
`and the testimony offers facts based on Mr.
`Boldt’s personal knowledge.
`
`This testimony sets forth factual material, not legal
`argument.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`
`Mr. Boldt has personal knowledge. See, e.g., Mr.
`Boldt’s testimony, Q/A 5-17.
`
`
`
`7
`
`
`
`
`
`Question and
`Answer
`Number in
`Witness
`Statement
`
`42
`
`43
`
`44
`
`
`
`
`
`
`Notes/
`Exhibits Objections
`
`Motorola’s Responses to Apple’s Objections
`
`Not opinion testimony by lay witness and not
`expert opinion testimony. The question calls for facts
`and the testimony offers facts based on Mr.
`Boldt’s personal knowledge.
`
`This testimony sets forth factual material, not legal
`argument.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`
`Mr. Boldt has personal knowledge. See, e.g., Mr.
`Boldt’s testimony, Q/A 5-17.
`
`Not opinion testimony by lay witness and not
`expert opinion testimony. The question calls for facts
`and the testimony offers facts based on Mr.
`Boldt’s personal knowledge.
`
`This testimony sets forth factual material, not legal
`argument.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`
`8
`
`V, F
`
`V, F, FRE
`602, FRE
`701, FCGR
`9.1
`
`V, F, FRE
`602, FRE
`701, FCGR
`9.1
`
`
`
`
`
`
`
`
`
`
`
`Question and
`Answer
`Number in
`Witness
`Statement
`
`45
`
`46
`
`
`
`
`
`
`Notes/
`Exhibits Objections
`
`Motorola’s Responses to Apple’s Objections
`
`redirect.
`
`Mr. Boldt has personal knowledge. See, e.g., Mr.
`Boldt’s testimony, Q/A 5-17.
`
`Not opinion testimony by lay witness and not
`expert opinion testimony. The question calls for facts
`and the testimony offers facts based on Mr.
`Boldt’s personal knowledge.
`
`This testimony sets forth factual material, not legal
`argument.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`
`Mr. Boldt has personal knowledge. See, e.g., Mr.
`Boldt’s testimony, Q/A 5-17.
`
`Not opinion testimony by lay witness and not
`expert opinion testimony. The question calls for facts
`and the testimony offers facts based on Mr.
`Boldt’s personal knowledge.
`
`This testimony sets forth factual material, not legal
`argument.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`
`
`
`9
`
`
`
`
`
`V, F, FRE
`602, FRE
`701, FCGR
`9.1
`
`V, F, FRE
`602, FRE
`701, FCGR
`9.1
`
`
`
`
`
`Question and
`Answer
`Number in
`Witness
`Statement
`
`47
`
`48
`
`
`
`
`
`
`Notes/
`Exhibits Objections
`
`Motorola’s Responses to Apple’s Objections
`
`Mr. Boldt has personal knowledge. See, e.g., Mr.
`Boldt’s testimony, Q/A 5-17.
`
`Not opinion testimony by lay witness and not
`expert opinion testimony. The question calls for facts
`and the testimony offers facts based on Mr.
`Boldt’s personal knowledge.
`
`This testimony sets forth factual material, not legal
`argument.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`
`Mr. Boldt has personal knowledge. See, e.g., Mr.
`Boldt’s testimony, Q/A 5-17.
`
`Not opinion testimony by lay witness and not
`expert opinion testimony. The question calls for facts
`and the testimony offers facts based on Mr.
`Boldt’s personal knowledge.
`
`This testimony sets forth factual material, not legal
`argument.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`
`Mr. Boldt has personal knowledge. See, e.g., Mr.
`Boldt’s testimony, Q/A 5-17.
`
`10
`
`
`
`
`
`V, F, FRE
`602, FRE
`701, FCGR
`9.1
`
`V, F, FRE
`602, FRE
`701, FCGR
`9.1
`
`
`
`
`
`Question and
`Answer
`Number in
`Witness
`Statement
`
`49
`
`50
`
`
`
`
`
`
`Notes/
`Exhibits Objections
`
`Motorola’s Responses to Apple’s Objections
`
`
`Not opinion testimony by lay witness and not
`expert opinion testimony. The question calls for facts
`and the testimony offers facts based on Mr.
`Boldt’s personal knowledge.
`
`This testimony sets forth factual material, not legal
`argument.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`
`Mr. Boldt has personal knowledge. See, e.g., Mr.
`Boldt’s testimony, Q/A 5-17.
`
`Not opinion testimony by lay witness and not
`expert opinion testimony. The question calls for facts
`and the testimony offers facts based on Mr.
`Boldt’s personal knowledge.
`
`This testimony sets forth factual material, not legal
`argument.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`
`Mr. Boldt has personal knowledge. See, e.g., Mr.
`Boldt’s testimony, Q/A 5-17.
`
`Not opinion testimony by lay witness and not
`
`11
`
`
`
`
`
`V, F, FRE
`602, FRE
`701, FCGR
`9.1
`
`V, F, FRE
`602, FRE
`701, FCGR
`9.1
`
`
`
`
`
`Question and
`Answer
`Number in
`Witness
`Statement
`
`51
`
`52
`
`
`
`
`
`
`Notes/
`Exhibits Objections
`
`Motorola’s Responses to Apple’s Objections
`
`
`
`
`
`V, F, FRE
`602, FRE
`701, FCGR
`9.1
`
`V, F, FRE
`602, FRE
`701, FCGR
`9.1
`
`expert opinion testimony. The question calls for facts
`and the testimony offers facts based on Mr.
`Boldt’s personal knowledge.
`
`This testimony sets forth factual material, not legal
`argument.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`
`Mr. Boldt has personal knowledge. See, e.g., Mr.
`Boldt’s testimony, Q/A 5-17.
`
`Not opinion testimony by lay witness and not
`expert opinion testimony. The question calls for facts
`and the testimony offers facts based on Mr.
`Boldt’s personal knowledge.
`
`This testimony sets forth factual material, not legal
`argument.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`
`Mr. Boldt has personal knowledge. See, e.g., Mr.
`Boldt’s testimony, Q/A 5-17.
`
`Not opinion testimony by lay witness and not
`expert opinion testimony. The question calls for facts
`and the testimony offers facts based on Mr.
`
`12
`
`
`
`
`
`Question and
`Answer
`Number in
`Witness
`Statement
`
`53
`
`56
`
`60
`
`61
`
`
`
`
`
`
`Notes/
`Exhibits Objections
`
`Motorola’s Responses to Apple’s Objections
`
`Boldt’s personal knowledge.
`
`This testimony sets forth factual material, not legal
`argument.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`
`Mr. Boldt has personal knowledge. See, e.g., Mr.
`Boldt’s testimony, Q/A 5-17.
`
`Not opinion testimony by lay witness and not
`expert opinion testimony. The question calls for facts
`and the testimony offers facts based on Mr.
`Boldt’s personal knowledge.
`
`This testimony sets forth factual material, not legal
`argument.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`
`13
`
`V, F, FRE
`602, FRE
`701, FCGR
`9.1
`
`V, F
`
`V, F
`
`V, F
`
`
`
`
`
`
`
`
`
`
`
`
`
`Question and
`Answer
`Number in
`Witness
`Statement
`
`62
`
`63
`
`64
`
`65
`
`66
`
`
`
`
`
`
`Notes/
`Exhibits Objections
`
`Motorola’s Responses to Apple’s Objections
`
`
`
`
`
`
`
`
`
`
`
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`
`14
`
`V, F
`
`V, F
`
`V, F
`
`V, F
`
`V, F
`
`
`
`
`
`Question and
`Answer
`Number in
`Witness
`Statement
`
`71
`
`75
`
`76
`
`80
`
`81
`
`82
`
`
`
`
`
`
`Notes/
`Exhibits Objections
`
`Motorola’s Responses to Apple’s Objections
`
`
`
`
`
`
`
`
`
`
`
`
`
`further foundation, if needed, may be provided on
`redirect.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`Apple has not specified its basis for objecting to this
`
`15
`
`V, F
`
`V, F
`
`V, F
`
`V, F
`
`V, F
`
`V, F
`
`
`
`
`
`Question and
`Answer
`Number in
`Witness
`Statement
`
`89
`
`90
`
`91
`
`92
`
`93
`
`
`
`
`
`
`Notes/
`Exhibits Objections
`
`Motorola’s Responses to Apple’s Objections
`
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`
`
`16
`
`V, F
`
`V, F
`
`V, F
`
`V, F
`
`V, F
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Question and
`Answer
`Number in
`Witness
`Statement
`
`94
`
`95
`
`96
`
`97
`
`98
`
`
`
`
`
`
`Notes/
`Exhibits Objections
`
`Motorola’s Responses to Apple’s Objections
`
`
`
`
`
`
`
`
`
`
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`
`17
`
`V, F
`
`V, F
`
`V, F
`
`V, F
`
`V, F
`
`
`
`
`
`Question and
`Answer
`Number in
`Witness
`Statement
`
`111
`
`113
`
`114
`
`
`
`
`
`
`Notes/
`Exhibits Objections
`
`Motorola’s Responses to Apple’s Objections
`
`
`
`
`
`
`
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`
`Mr. Boldt has personal knowledge. See, e.g., Mr.
`Boldt’s testimony, Q/A 5-17.
`
`Not opinion testimony by lay witness and not
`expert opinion testimony. The question calls for facts
`and the testimony offers facts based on Mr.
`Boldt’s personal knowledge.
`
`This testimony sets forth factual material, not legal
`argument.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`
`Mr. Boldt has personal knowledge. See, e.g., Mr.
`Boldt’s testimony, Q/A 5-17.
`
`Not opinion testimony by lay witness and not
`expert opinion testimony. The question calls for facts
`and the testimony offers facts based on Mr.
`Boldt’s personal knowledge.
`
`This testimony sets forth factual material, not legal
`argument.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`
`18
`
`V, F, FRE
`602, FRE
`701, FCGR
`9.1
`
`V, F, FRE
`602, FRE
`701, FCGR
`9.1
`
`V, F, FRE
`602, FRE
`
`
`
`
`
`Question and
`Answer
`Number in
`Witness
`Statement
`
`117
`
`118
`
`
`
`
`
`
`Notes/
`Exhibits Objections
`
`Motorola’s Responses to Apple’s Objections
`
`701, FCGR
`9.1
`
`
`
`
`
`V, F, FRE
`602, FRE
`701, FCGR
`9.1
`
`V, F, FRE
`602, FRE
`701, FCGR
`9.1
`
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`
`Mr. Boldt has personal knowledge. See, e.g., Mr.
`Boldt’s testimony, Q/A 5-17.
`
`Not opinion testimony by lay witness and not
`expert opinion testimony. The question calls for facts
`and the testimony offers facts based on Mr.
`Boldt’s personal knowledge.
`
`This testimony sets forth factual material, not legal
`argument.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`
`Mr. Boldt has personal knowledge. See, e.g., Mr.
`Boldt’s testimony, Q/A 5-17.
`
`Not opinion testimony by lay witness and not
`expert opinion testimony. The question calls for facts
`and the testimony offers facts based on Mr.
`Boldt’s personal knowledge.
`
`This testimony sets forth factual material, not legal
`argument.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`
`
`19
`
`
`
`
`
`Question and
`Answer
`Number in
`Witness
`Statement
`
`129
`
`131
`
`
`
`
`
`
`Notes/
`Exhibits Objections
`
`Motorola’s Responses to Apple’s Objections
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`
`Mr. Boldt has personal knowledge. See, e.g., Mr.
`Boldt’s testimony, Q/A 5-17.
`
`Not opinion testimony by lay witness and not
`expert opinion testimony. The question calls for facts
`and the testimony offers facts based on Mr.
`Boldt’s personal knowledge.
`
`This testimony sets forth factual material, not legal
`argument.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`
`Mr. Boldt has personal knowledge. See, e.g., Mr.
`Boldt’s testimony, Q/A 5-17.
`
`Not opinion testimony by lay witness and not
`expert opinion testimony. The question calls for facts
`and the testimony offers facts based on Mr.
`Boldt’s personal knowledge.
`
`This testimony sets forth factual material, not legal
`argument.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`
`20
`
`
`
`
`
`V, F, FRE
`602, FRE
`701, FCGR
`9.1
`
`V, F, FRE
`602, FRE
`701, FCGR
`9.1
`
`
`
`
`
`Question and
`Answer
`Number in
`Witness
`Statement
`
`132
`
`133
`
`
`
`
`
`
`Notes/
`Exhibits Objections
`
`Motorola’s Responses to Apple’s Objections
`
`redirect.
`
`Mr. Boldt has personal knowledge. See, e.g., Mr.
`Boldt’s testimony, Q/A 5-17.
`
`Not opinion testimony by lay witness and not
`expert opinion testimony. The question calls for facts
`and the testimony offers facts based on Mr.
`Boldt’s personal knowledge.
`
`This testimony sets forth factual material, not legal
`argument.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`
`Mr. Boldt has personal knowledge. See, e.g., Mr.
`Boldt’s testimony, Q/A 5-17.
`
`Not opinion testimony by lay witness and not
`expert opinion testimony. The question calls for facts
`and the testimony offers facts based on Mr.
`Boldt’s personal knowledge.
`
`This testimony sets forth factual material, not legal
`argument.
`Apple has not specified its basis for objecting to this
`question as vague; nonetheless, the question is not so
`uncertain, indefinite, or unclear as to be improper.
`
`There is adequate foundation for this testimony, and
`further foundation, if needed, may be provided on
`redirect.
`
`
`
`21
`
`
`
`
`
`V, F, FRE
`602, FRE
`701, FCGR
`9.1
`
`V, F, FRE
`602, FRE
`701, FCGR
`9.1
`
`
`
`
`
`Question and
`Answer
`Number in
`Witness
`Statement
`
`134
`
`135
`
`
`
`
`
`
`Notes/
`Exhibits Objections
`
`Motorola’s Responses to Apple’s Objections
`
`Mr. Boldt has personal knowledge. See, e.g., Mr.
`Boldt’s testimony, Q/A 5-17.
`
`Not opinion testimony by lay witness and not
`expert opinion testimony. The questio
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