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

Filing 1043

Declaration of Nathan Sabri in Support of #1042 Opposition/Response to Motion, #1041 Administrative Motion to File Under Seal Apple Inc.'s Opposition to Samsung's Motion to Enforce April 12, 2012 Order filed byApple 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, #15 Exhibit 15, #16 Exhibit 16, #17 Exhibit 17, #18 Exhibit 18, #19 Exhibit 19, #20 Exhibit 20, #21 Exhibit 21, #22 Exhibit 22, #23 Exhibit 23, #24 Exhibit 24, #25 Exhibit 25, #26 Exhibit 26, #27 Exhibit 27)(Related document(s) #1042 , #1041 ) (Jacobs, Michael) (Filed on 6/5/2012)

DECLARATION OF NATHAN SABRI IN
SUPPORT OF APPLE’S OPPOSITIONS TO
SAMSUNG’S MOTION FOR SANCTIONS AND
MOTION TO ENFORCE

EXHIBIT 23

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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APPLE, INC.,

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Plaintiff,

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vs.

) NO. 11-CV-01846-LHK

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SAMSUNG ELECTRONICS, LTD.,

)

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et al.,

)

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Defendants.

)

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***

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ATTORNEYS' EYES ONLY

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PURSUANT TO THE PROTECTIVE ORDER

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***

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VIDEOTAPED DEPOSITION OF WEI CHEN, Ph.D.

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PALO ALTO, CALIFORNIA

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THURSDAY, MARCH 1, 2012

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Reported By:

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Yvonne Fennelly, CCRR, CSR No. 5495

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JOB NO. 46969
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MARCH 1, 2012

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9:06 A.M.

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Videotaped deposition of WEI CHEN, Ph.D.,

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held at the offices of Quinn Emanuel, 555 Twin

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Dolphin Drive, Redwood Shores, California,

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pursuant to Notice, before Yvonne Fennelly,

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CCRR, CSR 5495.

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A P P E A R A N C E S

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MORRISON & FOERSTER LLP

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Attorneys for Plaintiff

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425 Market Street

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San Francisco, California 94105

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BY:

ANDREW E. MONACH, Esq.

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[phone]

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[e-mail]

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QUINN EMANUEL URQUHART & SULLIVAN, LLP

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Attorneys for Defendant

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555 Twin Dolphin Drive

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Suite 560

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Redwood Shores, California 94065

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BY:

ANNA T. NEILL, Ph.D.

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[phone]

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[e-mail]

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VIDEOGRAPHER:
Aric Kerhoulas

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Redwood Shores, California

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Thursday, March 1, 2012

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- - -

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THE VIDEOGRAPHER:

Good morning.

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This marks the beginning of Disk 1 of the

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videotaped deposition of Wei Chen in the matter

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Apple, Incorporated versus Samsung Electronics,

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et al., in the United States District Court for

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the Northern District of California, San Jose

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09:06AM

Division, case No. 11-CV-01846 LHK.

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09:06AM

This deposition is being held at the

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office of Quinn Emanuel at 555 Twin Dolphin

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Drive in Redwood Shores, California.

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The date today is March 1, 2012.

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time is approximately 9:06 a.m.

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Kerhoulas of TSG Reporting, Incorporated.

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court reporter today is Yvonne Fennelly in

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The

association with TSG.

My name is Aric

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yourselves starting with the questioning

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Our

Will counsel please introduce

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09:06AM

attorney.

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MS. NEILL:

09:07AM

Anna Neill of Quinn

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Emmanuel Urquhart & Sullivan on behalf of

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Samsung.

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MR. MONACH:

Andrew Monach from

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09:07AM

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Morrison & Foerster representing Apple and the

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witness.

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THE VIDEOGRAPHER:

If the court

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reporter will please swear in the witness we can

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proceed.

09:07AM

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WEI CHEN, Ph.D.,

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having been first duly sworn was

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examined and testified as follows:

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- - -

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THE VIDEOGRAPHER:

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You may proceed.

09:07AM

EXAMINATION
BY MS. NEILL:

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Q.

Good morning, Mr. Chen.

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A.

Good morning.

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Q.

Would you please state your full name

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09:07AM

for the record?

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A.

Wei Chen.

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Q.

And can you please spell that?

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A.

W-E-I, C-H-E-N.

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Q.

Okay.

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And would you please state

09:07AM

your home address and your business address?
A.

Home address is 2898 Ramona Street,

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Palo Alto, California 94306.

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is 1 Infinite Loop, Cupertino, California.

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95014, I think.

Business address

09:07AM

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Page 32
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(Recess taken.)

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(Document marked Exhibit 1950

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for identification.)

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THE VIDEOGRAPHER:

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record, the time is 10:19 a.m.

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We're on the

BY MS. NEILL:

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Q.

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e-mail?

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A.

10:19AM

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Dr. Chen, do you recognize this

I see my name is on it, but I

actually don't recall seeing this e-mail.
Q.

10:19AM

On the second page of this chain of

e-mails, page ending 489.

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A.

Sorry?

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Q.

The page ending 489.

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A.

Okay.

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Q.

There appears to be an e-mail from

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10:20AM

Tang Yew Tan?

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A.

Correct.

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Q.

Do you know Tang Tan?

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A.

Yes.

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Q.

And who is Tang Tan?

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A.

He -- Tang is the manager of product

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10:20AM

design team for iPhone.
Q.

And at the bottom of this page, there

is a list of action items that starts with

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No. 1, Provide a cost comparison of the

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following Grapes, followed by the name Priya.

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Do you know who Priya is?

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A.

Priya is the manager of the display

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and touch panel procurement team, what we call

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global supply manager.

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Q.

A.

Grape is loosely referring to touch

panels, internally.

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And do you know what the term

"Grapes" refers to in this sentence?

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10:21AM

Q.

10:21AM

Under No. 1, the letter A, it says,

M68 full lam?

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What is M68?

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A.

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iPhone.

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Q.

And what does full lam, L-A-M, refer

A.

Full lam refers to the optical

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M68 is the code name for the original
10:22AM

to?

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bonding between the touch glass and the displays

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or between cover glass and the touch displays.

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Bonding.

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MR. MONACH:

10:22AM

Bonding, B-O-N-D-I-N-G.

Sorry.
THE WITNESS:

Thank you.

BY MS. NEILL:

10:22AM

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Page 55
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C E R T I F I C A T E

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STATE OF CALIFORNIA

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)
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COUNTY OF CONTRA COSTA

ss:

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I, YVONNE FENNELLY, CCRR, CSR 5495,

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within and for the State of California, do

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hereby certify:

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That WEI CHEN, Ph.D, the witness

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whose deposition is hereinbefore set forth, was

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duly sworn by me and that such deposition is a

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true record of the testimony given by such

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witness.

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I further certify that I am not

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related to any of the parties to this action by

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blood or marriage; and that I am in no way

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interested in the outcome of this matter.

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IN WITNESS WHEREOF, I have hereunto
set my hand this 1st day of March, 2012.

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___________________________________
YVONNE FENNELLY, CCRR, CSR NO. 5495

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