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

Filing 1020

Administrative Motion to File Under Seal Documents Under Seal Re Apples Opposition To Samsungs Motion For Summary Judgment filed by Apple Inc.. (Attachments: #1 Proposed Order, #2 Declaration Of Jason R. Bartlett In Support Of Apples Opposition To Samsungs Motion For Summary Judgment, #3 Bartlett Decl. Ex. 8, #4 Bartlett Decl. Ex. 9, #5 Bartlett Decl. Ex. 10, #6 Bartlett Decl. Ex. 11, #7 Bartlett Decl. Ex. 17, #8 Bartlett Decl. Ex. 18, #9 Bartlett Decl. Ex. 19, #10 Bartlett Decl. Ex. 23, #11 Bartlett Decl. Ex. 26, #12 Bartlett Decl. Ex. 30, #13 Bartlett Decl. Ex. 31, #14 Bartlett Decl. Ex. 32, #15 Bartlett Decl. Ex. 53, #16 Bartlett Decl. Ex. 54, #17 Bartlett Decl. Ex. 55, #18 Bartlett Decl. Ex. 57, #19 Bartlett Decl. Ex. 58, #20 Bartlett Decl. Ex. 59, #21 Bartlett Decl. Ex. 60, #22 Bartlett Decl. Ex. 61, #23 Bartlett Decl. Ex. 62, #24 Bartlett Decl. Ex. 64, #25 Bartlett Decl. Ex. 67, #26 Bartlett Decl. Ex. 80)(Jacobs, Michael) (Filed on 6/1/2012)

Exhibit 54
(Submitted Under Seal)

Confidential Attorneys' Eyes Only

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION
APPLE INC., a California
corporation,

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Plaintiff,
vs.
Case 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.
---------------------------------/

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CONFIDENTIAL
ATTORNEYS' EYES ONLY
OUTSIDE COUNSEL
VIDEOTAPED DEPOSITION OF ANDREW PLATZER
Redwood Shores, California
Tuesday, October 18, 2011

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Reported by:
LORRIE L. MARCHANT, CSR No. 10523, RPR, CRR, CCRR,
CLR
JOB NO. 42881

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TSG Reporting - Worldwide

(877)-702-9580

Confidential Attorneys' Eyes Only
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October 18, 2011
10:10 a.m.
Videotaped Deposition of ANDREW
PLATZER, held at the offices of Quinn
Emanuel Urqhart Oliver & Hedges, LLP,
555 Twin Dolphin Drive, Redwood
Shores, California, before Lorrie L.
Marchant, a Certified Shorthand
Reporter, Registered Professional
Reporter, Certified Realtime Reporter,
California Certified Realtime Reporter
and Certified LiveNote Reporter.

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A P P E A R A N C E S:
FOR THE PLAINTIFF APPLE INC.:
MORRISON & FOERSTER
BY: WESLEY OVERSON, ESQ.
425 Market Street
San Francisco, California 94105
FOR THE DEFENDANTS SAMSUNG:
QUINN EMANUEL URQUHART & SULLIVAN
BY: TODD BRIGGS, ESQ.
555 Twin Dolphin Drive
Redwood Shores, California 94065
ALSO PRESENT:
Alan Dias, Videographer
---oOo---

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THE VIDEOGRAPHER: Good morning. This is
the start of Disk No. 1 of the videotaped deposition
of Andrew Platzer in the matter of Apple Inc.,
versus Samsung, in the United States District Court,
Northern District of California, San Jose Division.
Case No. 1 -- 11-CV-01846.
We are located today at 555 Twin Dolphin Drive
in the City of Redwood Shores, California. Today is
October 18, 2011, and the time is 10:10 a.m. My name is
Alan Dias, from TSG Reporting.
Counsel, would you please identify yourself for
the record.
MR. BRIGGS: Todd Briggs from Quinn Emanuel
for Samsung.
MR. OLSON: Erik Olson from Morrison &
Foerster, for Apple and for the witness.
THE VIDEOGRAPHER: Will the court reporter
please swear in the witness.
THE REPORTER: Do you solemnly swear or
affirm under the penalties of perjury that the
testimony you are about to offer will be the truth,
the whole truth and nothing but the truth?
THE WITNESS: I do.
THE VIDEOGRAPHER: You may proceed.
///

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TSG Reporting - Worldwide

EXAMINATION BY MR. BRIGGS
BY MR. BRIGGS:
Q. Can you state your full name for the
record.
A. Andrew Platzer.
Q. How do you spell that?
A. A-N-D-R-E-W, P-L-A-T-Z-E-R.
Q. Where do you live?
A. In Santa Clara, California.
Q. How long have you lived in Santa Clara?
A. Fifteen years.
Q. Where do you work?
A. Apple Computer.
Q. And you work for Apple in Cupertino?
A. Yes.
Q. What's your home address?
A. 3224 El Sobrante Street, Santa Clara.
Q. How long have you worked for Apple?
A. A bit over 15 years.
Q. So you came to Apple in 1996?
A. Yes.
Q. Where were you before that?
A. I worked at a number of smaller companies
in Toronto, Canada.
Q. When did you graduate from college?

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UIKit? Does that code always interpret a single
input point as a scroll operation?
MR. OLSON: Objection. Vague as to time.
Lack of foundation.
THE WITNESS: Again, I do not understand -a UIKit is a very large system.
BY MR. BRIGGS:
Q. Can you think of any instances in UIKit
where multiple input points are identified as a
scroll operation?
MR. OLSON: Objection. Vague as to time.
THE WITNESS: Could you be more specific as
to a time?
BY MR. BRIGGS:
Q. Any time.
A. So I'm not a lawyer. You know, I cannot
speak to "interpreted" as far as the patent is
concerned.

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Q. And does that code ever interpret multiple
inputs as a scroll operation?
A. I do not know without referring to other
materials.

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Q. What other materials would you refer to?
A. The source code.
Q. Any other materials?
A. Perhaps the documentation.
Q. What -- what documentations?
A. It would be public documentation.
Q. Is there a name for this public
documentation?
A. This would be the API reference.
Q. So there might be something in the API
reference that describes whether multiple input -input could be interpreted as a scroll operation?
A. I don't know.
Q. Did you write any of the APIs or -- let me
rephrase that.
Did you write any of the API documentation?
A. No.
Q. But sitting here today, you don't recall
whether any of the code or any of the API
documentation describes multiple input points being
interpreted as a scroll operation?
A. I don't understand. Could you break the
question down?
Q. Well, sitting here today, you -- you can't
recall any code that interprets multiple input

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points as a scroll operation; is that correct?
A. I don't recall.
Q. And sitting here today, you don't recall
any documentation that describes multiple input
points being interpreted as a scroll operation; is
that right?
A. Yes. I don't recall.
Q. Do you know if the UIKit code distinguishes
between a single input point and multiple input
points to determine whether a scroll or gesture
operation is invoked?
MR. OLSON: Objection. Asked and answered.
THE WITNESS: With regards to the patent,
I'm not comfortable in defining "invoked."

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TSG Reporting - Worldwide

BY MR. BRIGGS:
Q. Okay. Let's move to the next limitation.
It states, Issuing at least one scroll or
gesture call based on invoking the scroll or gesture
operation.
What is a scroll call?
MR. OLSON: Objection. Calls for a legal
conclusion. Lack of foundation.

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CERTIFICATE
STATE OF CALIFORNIA )
): ss
COUNTY OF SONOMA )
I, Lorrie L. Marchant, a Certified Shorthand
Reporter, a Registered Professional Reporter, a
Certified Realtime Reporter, and a Certified
Realtime Professional within and for the State of
California, do hereby certify:
That ANDREW PLATZER, the witness whose
deposition is herein set forth, was duly
sworn/affirmed by me and that such deposition is a
true record of the testimony given by such witness.
I further certify that I am not related to any
of the parties to this action by blood or marriage
and that I am in no way interested in the outcome of
this matter.
In witness whereof, I have hereunto set my hand
this 18th day of October, 2011.

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--------------------------------------------22
LORRIE L. MARCHANT, CSR, RPR, CRR, CLR, CCRR 23
CSR No. 10523
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INDEX
INDEX OF EXAMINATION
PAGE
MR. BRIGGS
5
---oOo--INDEX OF EXHIBITS
DESCRIPTION
PAGE
Exhibit 632 Declaration for Utility or
57
Design Patent Application
(Production Nos. APLPROS0000006260
- APLPROS0000006261)
---oOo--QUESTIONS INSTRUCTED NOT TO ANSWER
Page Line
9 5
31 17
33 3
33 8
61 10
---oOo---

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NAME OF CASE: Apple v. Samsung
DATE OF DEPOSITION: 10/18/2011
NAME OF WITNESS: Andrew Platzer
Reason Codes:
1. To clarify the record.
2. To conform to the facts.
3. To correct transcription errors.
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__________________________
ANDREW PLATZER

TSG Reporting - Worldwide

(877)-702-9580

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