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Case 1:17-cv-00770-JDW Document 245-24 Filed 10/19/23 Page 1 of 6 PageID #: 24791
`
`Exhibit X
`
`

`

`Case 1:17-cv-00770-JDW Document 245-24 Filed 10/19/23 Page 2 of 6 PageID #: 24792
`
`1/5/2018
`
`337-TA-1067
`Confidential Business Information - Subject to Protective Order
`
`James Domanus
`
`Page 1
` UNITED STATES INTERNATIONAL TRADE COMMISSION
` Washington, D.C.
`
`In the Matter of )
` )
`CERTAIN ROAD MILLING )Inv. No. 337-TA-1067
`MACHINES AND COMPONENTS )
`THEREOF. )
`_______________________________)
`
` VIDEOTAPED DEPOSITION OF JAMES D. DOMANUS
` Maple Grove, Minnesota
` January 5, 2018 - 8:59 a.m.
`
` CONFIDENTIAL BUSINESS INFORMATION SUBJECT TO THE
` PROTECTIVE ORDER
`
`Reported by: Lisa A. Blanks, RPR, CRR
`Certified Reporter No. 50803
` ____________________________________________________
` DIGITAL EVIDENCE GROUP
` 1730 M Street, NW, Suite 812
` Washington, D.C. 20036
` (202) 232-0646
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2018
`
`202-232-0646
`
`

`

`Case 1:17-cv-00770-JDW Document 245-24 Filed 10/19/23 Page 3 of 6 PageID #: 24793
`
`1/5/2018
`
`337-TA-1067
`Confidential Business Information - Subject to Protective Order
`
`James Domanus
`
`Page 56
`
`section, there are comments provided, right?
` A. That's correct.
` Q. Also under the make and model rows, it
`identifies the make and model of the cold planer machine
`that the surveyed customer owns, right?
` A. That's correct.
` Q. And then in the like and dislike column,
`there's sort of a binary decision made -- I guess by
`whoever put this together -- regarding whether or not
`the customer likes or dislikes the features of the
`machine listed under make and model, right?
` A. Yes, I see the like and dislike.
` Q. And what does the like and dislike mean there?
` A. I assume it's whether they like the feature or
`dislike the feature or --
` Q. Is it about liking the machine in general, or
`the feature specifically commented on in the comments
`column?
` MS. SAHLSTEN: Objection, vague.
` THE WITNESS: It appears to be what's in the
`comments.
` Q. BY MR. POWERS: Okay. Let's go down to cell
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`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2018
`
`202-232-0646
`
`

`

`Case 1:17-cv-00770-JDW Document 245-24 Filed 10/19/23 Page 4 of 6 PageID #: 24794
`
`1/5/2018
`
`337-TA-1067
`Confidential Business Information - Subject to Protective Order
`
`James Domanus
`
`Page 57
`
`H15. Tell me when you're there.
` A. I'm there.
` Q. That says, "Improve leveling system.
`Benchmark Level Pro on Wirtgen."
` And the customer there owned a Wirtgen machine
`and liked it; is that fair to say?
` A. I see a -- yes, I see the like. I do not see
`the Wirtgen model.
` Q. Me either.
` Let's go down to column -- let's go down to
`cell H42.
` A. Okay.
` Q. It says there, "Likes Wirtgen grade/slope
`control system."
` Do you see that?
` A. Yes.
` Q. And that was a Wirtgen W2000, right?
` A. I see that, yes.
` Q. Let's go down to H48.
` A. Okay.
` Q. It says, "Very much liked the new grade and
`slope control from Wirtgen. Easy to learn and operate.
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`www.DigitalEvidenceGroup.com
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`Digital Evidence Group C'rt 2018
`
`202-232-0646
`
`

`

`Case 1:17-cv-00770-JDW Document 245-24 Filed 10/19/23 Page 5 of 6 PageID #: 24795
`
`1/5/2018
`
`337-TA-1067
`Confidential Business Information - Subject to Protective Order
`
`James Domanus
`
`Page 58
`
`Well laid-out controls," correct?
` A. I see that, yes.
` Q. And that was a Wirtgen W210, right?
` A. That's the model listed, yes.
` Q. And the customer likes it, correct?
` A. Correct.
` Q. Let's go to H56.
` A. Okay.
` Q. It says, "Level Pro system is great with the
`three-window setup that indicates set and actual
`readings," correct?
` A. That's correct.
` Q. That's a Wirtgen machine, right?
` A. It's got a W2100 listed.
` Q. Next cell down says, "Level Pro system is very
`nice," right?
` A. Correct.
` Q. Is that a Wirtgen machine?
` A. W2200 is listed.
` Q. Is that a Wirtgen machine?
` A. Yes.
` Q. H59 -- I feel like we're playing Bingo.
`
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`www.DigitalEvidenceGroup.com
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`Digital Evidence Group C'rt 2018
`
`202-232-0646
`
`

`

`Case 1:17-cv-00770-JDW Document 245-24 Filed 10/19/23 Page 6 of 6 PageID #: 24796
`
`usl20rB
`
`337-TA-7067
`Confidential Business Information - Subject to Protective Order
`
`James Domanus
`
`Page 195
`
`1 STATE OF MINNESOTA )
`) ss.
`COUNTY OF HENNEPIN )
`BE IT KNOWN that the foregoing deposition was
`taken before me, Lisa A. Bl-anks, RPR, CRR, and by virtue
`thereof authorized to administer an oath; that the
`wltness before testifyinq was duly sworn by me
`that the questions
`to the whol-e truth;
`to testify
`propounded to the witness and the answers of the witness
`thereto were taken down by me in shorthand and
`reduced to print by computer-aided
`thereafter
`that pursuant to
`transcription under my direction;
`request, notification was provided that the deposition
`that the
`for review and signature;
`is available
`true and
`transcript consisting of 170 pages is a full,
`accurate transcript of all proceedi-ngs and testimony had
`and adduced upon the taking of said deposj-tion, all done
`to the best of my skill and abilitY.
`I FURTHER CERTIFY that I am in no way related
`to nor employed by any of the parties hereto nol am I in
`in the outcome hereof -
`any way interested
`DATED at MinneapoJ-is, Minnesota, January 7,
`
`B
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`A. Blatrks' RPR, ClìR
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`www.DigitalEvidenceGroup.com DigitalEvidenceGroupC'tt2018
`
`202-232-0646
`
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`

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