Case 2:14-cv-00111-AJS Document 328 Filed 04/22/15 Page 1 of 6
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`Parrot’s
`Designations
`Page/Line
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`9:8-19 (from
`“Can you . . .)
`10:19-11:1
`11:6-19
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`12:10-21
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`13:23-14:2
`15:20-25
`16:22-17:6
`18:9-18
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`Drone
`Technologies,
`Inc.'s Counter-
`designations
`Page/Line
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`12:22-13:8
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`19:1-10
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`21:3-11
`21:22-22:4
`(from “When
`you started . . .)
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`22:19-23:7
`(From “Tell me
`...)
`23:19-22
`24:23-25 (from
`“How did ...)
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`Deposition of Diane Lee on September 12, 2015
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`Drone Technologies,
`Inc.'s Objections
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`Parrot’s Objections to Counter-
`designations and Response to DTI
`Objections
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`(Drone Technologies response to Parrot Objection)
`– Testimony is relevant to the completion of
`previous testimony regarding the marital
`relationship between Ms. Lee and Mr. Ding. Also
`relevant to provide context for testimony designated
`by Parrot at 86:2-13, 86:22-87:6.
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`Parrot Objection to counter designations:
`FRE401-403. Not relevant to any issue on
`damages.
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`{00029726 / 2 }
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`Case 2:14-cv-00111-AJS Document 328 Filed 04/22/15 Page 2 of 6
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`29:6-9
`39:9-11
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`26:10-23
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`39:24-40:15
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`40:19-41:1
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`41: 5-8
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`63:22-25 (from
`“Do you . . .”)
`64: 4-17
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`65:3-8
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`65:15-20
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`66:16-17
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`66:19-67:4
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`67:24-68:3
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`68:20-69:3
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`FRE 402, 403; Drone
`Technologies Motion in Limine 1 (Doc No. 236)
`FRE 402, 403; Drone
`Technologies Motion in Limine 1 (Doc No. 236)
`FRE 402, 403; Drone
`Technologies Motion in Limine 1 (Doc No. 236)
`FRE 402, 403; Drone
`Technologies Motion in Limine 1 (Doc No. 236)
`FRE 402, 403; Drone
`Technologies Motion in Limine 1 (Doc No. 236)
`FRE 402, 403; Drone
`Technologies Motion in Limine 1 (Doc No. 236)
`FRE 402, 403; Drone
`Technologies Motion in Limine 1 (Doc No. 236)
`FRE 402, 403; Drone
`Technologies Motion in Limine 1 (Doc No. 236)
` FRE 402, 403; Drone
`Technologies Motion in Limine 1 (Doc No. 236)
`FRE 402, 403; Drone
`Technologies Motion in Limine 1 (Doc No. 236)
`Ms. Lee’s testimony is not relevant to any issue
`remaining in this case (FRE 402) and if it were
`relevant, it should be excluded because its
`probative value is substantially outweighed by the
`danger of unfair prejudice, confusion of the issues
`or the potential to mislead the jury (FRE 403).
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`Drone Technologies Motion in Limine 1 (Doc No.
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`Parrot only seeks to admit if DT opens the
`door on the issue of inventorship.1
`Parrot only seeks to admit if DT opens the
`door on the issue of iventorship.
`Parrot only seeks to admit if DT opens the
`door on the issue of iventorship.
`Parrot only seeks to admit if DT opens the
`door on the issue of iventorship.
`Parrot only seeks to admit if DT opens the
`door on the issue of iventorship.
`Parrot only seeks to admit if DT opens the
`door on the issue of iventorship.
`Parrot only seeks to admit if DT opens the
`door on the issue of iventorship.
`Parrot only seeks to admit if DT opens the
`door on the issue of iventorship.
`Parrot only seeks to admit if DT opens the
`door on the issue of iventorship.
`Parrot only seeks to admit if DT opens the
`door on the issue of iventorship.
`Relevant to Georgia Pacific Factor 9 -
`(“The utility and advantages of the
`patented property over the old modes or
`devices, if any, that had been used for
`working out similar results”). Goes to the
`state of the art.
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`1 Highlighted sections will not be introduced without prior approval of the Court.
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`{00029726 / 2 }
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`Case 2:14-cv-00111-AJS Document 328 Filed 04/22/15 Page 3 of 6
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`69:15-19
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`236) was granted (Doc. No. 287 ¶ 1), precluding
`Parrot from presenting arguments as to the alleged
`deficiencies in Ms. Lee’s inventorship. That order
`(Doc. No. 287 ¶ 1) was the fourth time this Court
`has dealt with this issue, including this specific
`testimony by Ms. Lee (see Doc. No. 229, page 3).
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`Parrot asserts that Ms. Lee’s testimony is relevant
`to damages under Georgia Pacific Factor 11,
`however, there is nothing probative in this
`designated portion of Ms. Lee’s testimony relative
`to Parrot’s use of the invention, or evidence of the
`value of that use.
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`Ms. Lee’s testimony is not relevant to any issue
`remaining in this case (FRE 402) and if it were
`relevant, it should be excluded because its
`probative value is substantially outweighed by the
`danger of unfair prejudice, confusion of the issues
`or the potential to mislead the jury (FRE 403).
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`Drone Technologies Motion in Limine 1 (Doc No.
`236) was granted (Doc. No. 287 ¶ 1), precluding
`Parrot from presenting arguments as to the alleged
`deficiencies in Ms. Lee’s inventorship. That order
`(Doc. No. 287 ¶ 1) was the fourth time this Court
`has dealt with this issue, including this specific
`testimony by Ms. Lee (see Doc. No. 229, page 3).
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`Parrot asserts that Ms. Lee’s testimony is relevant
`to damages under Georgia Pacific Factor 10,
`however, there is nothing probative in this
`testimony relative to the nature of the invention;
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`{00029726 / 2 }
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`Relevant to Georgia Pacific Factor 10 -
`(“The nature of the patented invention,
`the character of the commercial
`embodiment of it as owned and produced
`by the licensor…”).
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`Case 2:14-cv-00111-AJS Document 328 Filed 04/22/15 Page 4 of 6
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`69:23-24
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`70:7-8 (From
`“You’re not ...)
`70:12-16
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`71:2-14
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`71: 16-20
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`71:22-23
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`72:18-19
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`72:21-73:8
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`73:14-15
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`73:17-75:1
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`75:7-9 (From
`“Would it be
`...)
`75:11-12 and
`15-17
`75:19-25
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`evidence of the benefits to those who have used the
`invention; and there is no “commercial embodiment”
`owned or produced by the licensor. Accordingly,
`this testimony is wholly irrelevant to GPF 10.
`Same objection as above for 69:15-19
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`Same objection as above for 69:15-19
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`Same objection as above for 69:15-19
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`Same objection as above for 69:15-19
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`Same objection as above for 69:15-19
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`Same objection as above for 69:15-19
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`Same objection as above for 69:15-19
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`Same objection as above for 69:15-19
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`Same objection as above for 69:15-19
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`Same objection as above for 69:15-19
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`Same objection as above for 69:15-19
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`Relevant to Georgia Pacific factor 10-
`(“The nature of the patented invention,
`the character of the commercial
`embodiment of it as owned and produced
`by the licensor…”).
`Relevant to Georgia Pacific factor 10
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`Relevant to Georgia Pacific Factor 10 –
`(See above)
`Relevant to Georgia Pacific Factor 10–
`(See above)
`Relevant to Georgia Pacific Factor 10–
`(See above)
`Relevant to Georgia Pacific Factor 10–
`(See above)
`Relevant to Georgia Pacific Factor 10– (See
`above)
`Relevant to Georgia Pacific Factor 10– (See
`above)
`Relevant to Georgia Pacific Factor 10– (See
`above)
`Relevant to Georgia Pacific Factor 10– (See
`above)
`Relevant to Georgia Pacific Factor 10– (See
`above)
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`Same objection as above for 69:15-19
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`Same objection as above for 69:15-19
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`Relevant to Georgia Pacific Factor 10– (See
`above)
`Relevant to Georgia Pacific Factor 10– (See
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`{00029726 / 2 }
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`Case 2:14-cv-00111-AJS Document 328 Filed 04/22/15 Page 5 of 6
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`76:8-10
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`76:12-13
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`78:5-17
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`79:1-4
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`85:18-20 and
`85:24-86:1
`86:2-13
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`86:22-87:6
`87:22-88:2
`88:19-89:2
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`90:2-4
`90:16-24
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`91:18-92:2
`(from “So it
`was ...”)
`92:11-12
`92:14
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`104:10-19
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`Same objection as above for 69:15-19
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`Same objection as above for 69:15-19
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`FRE 402, 403; Drone
`Technologies Motion in Limine 1 (Doc No. 236)
`FRE 402, 403; Drone
`Technologies Motion in Limine 1 (Doc No. 236)
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`FRE 402, 403; Drone
`Technologies Motion in Limine 1 (Doc No. 236)
`FRE 402, 403; Drone
`Technologies Motion in
`Limine 1 (Doc No. 236) as to 85:24-86:1
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`89:3-5, 89:9
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`91:3-10
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`above)
`Relevant to Georgia Pacific Factor 10– (See
`above)
`Relevant to Georgia Pacific Factor 10– (See
`above)
`Parrot only seeks to admit if DT opens the
`door on the issue of inventorship.
`Parrot only seeks to admit if DT opens the
`door on the issue of inventorship.
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`Parrot only seeks to admit if DT opens the
`door on the issue of inventorship.
`Relevant to Georgia Pacific Factor 1 –
`(“The royalties received by the patentee for
`the licensing of the patent-in-suit, proving
`or tending to prove an established
`royalty.”)
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`105:20-106:14, 16, (Drone Technologies response to Parrot Objection) Parrot Objection to counter designations:
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`{00029726 / 2 }
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`Case 2:14-cv-00111-AJS Document 328 Filed 04/22/15 Page 6 of 6
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`19-24
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`– Testimony is relevant to Ms. Lee’s absence from
`the damages trial and explains why her testimony is
`being offered by video deposition and not as a live
`witness.
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`107:6-10 (from "do
`those illnesses . . .")
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`Counter-counter
`designation of
`107:11-17
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` 127:20-22
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`FRE401-403. Not relevant to any issue on
`damages. (Rely to DT response: DT is not
`offering her testimony, Parrot is. Parrot
`has to because she is a non-party not
`subject to the Court’s subpoena power.)
`Parrot Objection to counter designations:
`FRE401-403. Not relevant to any issue on
`damages.
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`{00029726 / 2 }
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