DEPOSITION TRANSCRIPT
Case: Clearwater Capital Management LP v. Sterling Digital Media LLC
Case No.: 6-23-cv-18689-SEM
Court: United States District Court
Witness: David Chen, Chief Technology Officer
Date: 2025-05-12
Examining Attorney: [Counsel for Sterling Digital Media LLC], Sidley Austin LLP
EXAMINATION BY COUNSEL:
Q: Please state your name and current title for the record.
A: My name is David Chen. I serve as Chief Technology Officer.
Q: How long have you been in that role?
A: Approximately 2 years.
Q: I want to direct your attention to the subject of IP ownership and assignment.
Were you personally involved in those matters?
A: Yes, I was directly involved.
Q: Please describe your involvement.
A: I oversaw the relevant process and was responsible for ensuring compliance
with all applicable agreements and obligations.
Q: Were you aware of the specific contractual provisions at issue?
A: Yes. I reviewed those provisions carefully before proceeding.
Q: Did you take any steps to comply with the notice requirements?
A: We followed our standard procedures, which I believed to be compliant.
Q: I'm showing you what has been marked as Exhibit A. Do you recognize this document?
A: Yes, I signed it. I understood it restricted certain activities.
Q: And you understood the geographic scope of that restriction?
A: Yes. I believe it covered the continental United States.
Q: At any point did you consult legal counsel regarding these obligations?
A: Yes, we engaged Sidley Austin LLP to advise us on compliance.
Q: Nothing further. Thank you.
[END OF EXAMINATION]
Certified by: _______________________________
Court Reporter
I, David Chen, certify that the foregoing transcript accurately reflects my testimony.
Signature: _______________________________
Date: 2025-05-12