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
Attorneys' Eyes Only
Page 1
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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
TSG Reporting - Worldwide - 877-702-9580
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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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(415) 268-7265
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amonach@mofo.com
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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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(650) 801-5032
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annaniell@quinnemanuel.com
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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
TSG Reporting - Worldwide - 877-702-9580
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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(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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10:20AM
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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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TSG Reporting - Worldwide - 877-702-9580
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