Apple Inc. v. Samsung Electronics Co. Ltd. et al

Filing 1002

Declaration of Sam Stake in Support of #1005 Samsung's Opposition to Apple's Motion for Summary Judgment filed by Samsung Electronics America, Inc.. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8, #9 Exhibit 9, #10 Exhibit 10, #11 Exhibit 11, #12 Exhibit 12, #13 Exhibit 13, #14 Exhibit 14)(Maroulis, Victoria) (Filed on 6/1/2012) Modified on 6/4/2012 linking entry to document #1005 and correcting filing date. counsel posted document on 6/1/2012 (dhm, COURT STAFF).

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EXHIBIT 2 Srivastava, Mani, Ph.D. (Apple expert) UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 --------------------------------x APPLE INC., a California ) corporation, ) ) Plaintiff, ) ) vs. )No. 11-CV-01846-LHK ) SAMSUNG ELECTRONICS CO., LTD, ) a Korean business entity; ) SAMSUNG ELECTRONICS AMERICA, ) INC., a New York corporation; ) SAMSUNG TELECOMMUNICATIONS ) AMERICA, LLC, a Delaware ) limited liability company, ) ) Defendants. ) ________________________________) VIDEOTAPED DEPOSITION OF MANI SRIVASTAVA 16 Los Angeles, California 17 Wednesday, April 25, 2012 18 19 20 21 22 23 24 25 HIGHLY CONFIDENTIAL Reported By: SUSAN A. SULLIVAN, CSR #3522, RPR, CRR JOB NO. 48799 Apple v. Samsung Page 1 Srivastava, Mani, Ph.D. (Apple expert) 1 originally being anticipatory; is that correct? A 2 I analyzed them and found them to be 3 anticipatory. 4 invalidity contentions. Q 5 I did have access to Apple's But, in other words, you didn't come up 6 with the Suso reference yourself, you were limited 7 to what Apple had disclosed under the local rules; 8 is that correct? A 9 10 I was told that I was limited to it, yes. THE VIDEOGRAPHER: 11 12 Right. We're getting pretty close to the end of the tape. 13 MR. STRETCH: Why don't we change the tape. 14 THE VIDEOGRAPHER: This marks the end of Disc 15 No. 1 in the continuing deposition. 16 11:18 a.m. and we are now off the record. 17 (Recess) 18 THE VIDEOGRAPHER: The time is This marks the beginning of 19 Disc No. 2 in the continuing deposition. 20 is 11:30 a.m. and we're back on the record. 21 BY MR. STRETCH: Q 22 The time Doctor, let me ask you to first before we 23 look at the actual references, ask you to look at 24 Exhibit, I think it is 2A. 25 '460 that's asserted. Apple v. Samsung It is the claim of the Page 75 Srivastava, Mani, Ph.D. (Apple expert) 1 A Uh-huh. 2 Q Do you have that in front of you? 3 A Yes. 4 Q Now I understand that you have various 5 opinions and arguments about that it is not 6 infringed, it is invalid, everything else. Can we agree that at the very least this 7 8 claim requires the three core functions that Dr. 9 Yang opined on? And by that I mean two separate 10 E-mail transmission modes, one for text only, one -- 11 a second one for sending E-mail that's entered 12 through a display sub-mode and the ability to 13 sequentially display other images stored in memory? 14 MS. WHELAN: 15 THE WITNESS: Objection. I do find the claim overall 16 confusing as to what method it is citing. 17 there are two E-mail sub-modes or not, the claim 18 language does use the first E-mail sub-mode and the 19 second E-mail sub-mode. 20 report, the specification is at variance with that. 21 But in terms of does it talk about sending an E-mail 22 text alone, an E-mail with text and image and 23 sequentially scrolling through the images, yes, the 24 claim does talk about these three things. 25 Apple v. Samsung Q Whether As I alluded to in my BY MR. STRETCH: Okay. Page 76 Srivastava, Mani, Ph.D. (Apple expert) 1 State of California ) ) 2 ss. County of Los Angeles ) 3 I, SUSAN A. SULLIVAN, CALIFORNIA CSR No. 4 5 3522, RPR, CRR, do hereby certify: That prior to being examined MANI 6 7 SRIVASTAVA, the witness named in the foregoing 8 deposition, was, before the commencement of the 9 deposition, duly administered an oath in accordance 10 with C.C.P. Section 2094; 11 That the said deposition was taken before 12 me at the time and place therein set forth, and was 13 taken down by me in shorthand and thereafter 14 transcribed into typewriting under my direction and 15 supervision; that the said deposition is a true and 16 correct record of the testimony given by the 17 witness; I further certify that I am neither counsel 18 19 for, nor in any way related to any party to said 20 action, nor in any way interested in the outcome 21 thereof. IN WITNESS WHEREOF, I have subscribed my 22 23 name on this 26th day of April, 2012. 24 ___________________________________ SUSAN A. SULLIVAN CSR No. 3522 25 Apple v. Samsung Page 209

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