Apple Inc. v. Samsung Electronics Co. Ltd. et al
Filing
1044
Administrative Motion to File Under Seal Samsung's Reply In Support of Motion For Clarification of May 4, 2012 Order filed by Samsung Electronics America, Inc.(a New York corporation), Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC(a Delaware limited liability company). (Attachments: #1 Samsung's Reply In Support of Motion For Clarification of May 4, 2012 Order, #2 Declaration of Dr. Jeffrey Johnson, #3 Exhibit 1 to Johnson Declaration, #4 Declaration of Mark Tung, #5 Exhibit 1, #6 Exhibit 2, #7 Exhibit 3)(Maroulis, Victoria) (Filed on 6/5/2012)
1 QUINN EMANUEL URQUHART & SULLIVAN, LLP
Charles K. Verhoeven (Bar No. 170151)
charlesverhoeven@quinnemanuel.com
50 California Street, 22nd Floor
San Francisco, California 94111
Telephone: (415) 875-6600
Facsimile: (415) 875-6700
Kevin P.B. Johnson (Bar No. 177129
kevinjohnson@quinnemanuel.com
Victoria F. Maroulis (Bar No. 202603)
victoriamaroulis@quinnemanuel.com
th
555 Twin Dolphin Drive, 5 Floor
Redwood Shores, California 94065-2139
(650) 801-5000
Telephone:
Facsimile:
(650) 801-5100
Michael T. Zeller (Bar No. 196417)
michaelzeller@quinnemanuel.com
865 S. Figueroa St., 10th Floor
Los Angeles, California 90017
Telephone: (213) 443-3000
Facsimile: (213) 443-3100
Attorneys for SAMSUNG ELECTRONICS CO.,
LTD., SAMSUNG ELECTRONICS AMERICA,
INC. and SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION
APPLE INC., a California corporation,
CASE NO. 11-cv-01846-LHK
DECLARATION OF JEFFREY
JOHNSON, PH.D., IN SUPPORT OF
SAMSUNG'S REPLY IN SUPPORT OF
SAMSUNG'S MOTION FOR
CLARIFICATION
Plaintiff,
vs.
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,
Defendant.
Date: June 19, 2012
Time: 10:00 a.m.
Place: Courtroom 5, 4th Floor
Judge: Hon. Paul S. Grewal
FILED UNDER SEAL
02198.51855/4789156.1
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Case No. 11-cv-01846-LHK
DECLARATION OF JEFFREY JOHNSON
1
I, Jeffrey Johnson, declare as follows:
1.
I am currently the President and Principal Consultant at UI Wizards, Inc., where I
manage the company, perform product usability design, evaluation, testing, and training for
clients. I have more than 32 years of experience in the computer industry designing,
implementing, evaluating, and testing user interfaces, including touch-screen based user interfaces.
2.
I earned a B.A. in psychology from Yale University and a Ph.D. in psychology
with additional studies in computer science from Stanford University.
3.
Attached as Exhibit 1 is my Curriculum Vitae which summarizes my background,
credentials, and includes a list of my publications.
4.
I submit this declaration in support of Samsung's Reply ISO Samsung's Motion for
Clarification Regarding the Court's May 4, 2012 Order. I have personal knowledge of the facts set
forth in this declaration and, if called upon as a witness, I could and would testify to such facts
under oath.
5.
As I explained in my expert report titled “EXPERT REPORT OF JEFFREY
JOHNSON, PH.D. REGARDING NON-INFRINGEMENT OF U.S. PATENT NO. 7,469,381”
dated April 16, 2012, I have examined the “blue glow” feature on various Samsung devices and
my opinion is that the blue glow feature does not infringe the ’381 Patent.
6.
In a device/application with blue glow, when a user attempts to scroll a document
past the edge, the user encounters a hard stop, i.e. the document stops when it reaches the edge and
does not scroll past the edge. In addition, a visual indication, typically but not always a blue (but
the color is immaterial) glow is overlaid near the edge. Because no area beyond the edge is
displayed in an application with blue glow, the application does not infringe the claims of the ’381
Patent. Furthermore, because the document never translates in a second direction (i.e. “bounces”),
this is a second reason why blue glow feature does not infringe the claims of the ’381 Patent.
7.
I have been asked by counsel for Samsung Electronics Co., Ltd.; Samsung
Electronics America, Inc.; and Samsung Telecommunications America, LLC (collectively
"Samsung") to conduct a detailed review of its December 30, 2011 production of source code. I
also compared this source code to the generic version of blue glow source code produced on
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Case No. 11-cv-01846-LHK
DECLARATION OF JEFFREY JOHNSON
1 January 23, 2012 – which I understand is not tied to a particular product, but consists of the base
2 version which was implemented into the accused products.
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I also compared the above mentioned source code with the blue glow functionality
24 to the generic version of blue glow source code produced on January 23, 2012 – which I
25 understand is not tied to a particular product, but consists of the base version which was
26 implemented into the accused products. As a result of this review, I confirmed that the blue glow
27 source code is present in the versions of source code produced on December 30, 2011 for at least
28 the Galaxy S II, Exhibit 4G, Epic 4G, and Galaxy Tab 10.1.
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Case No. 11-cv-01846-LHK
DECLARATION OF JEFFREY JOHNSON
1
14.
The blue glow source code present on these four devices is substantially identical to
2 the generic version of source code produced by Samsung on January 23, 2012.
3
15.
The blue glow function is implemented by relatively a few lines of code which is
4 uncomplicated and straightforward. Someone who is experienced in reviewing source code would
5 not need to invest significant time and effort to understand the blue glow source code that exists in
6 the four products identified above.
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I declare under penalty of perjury under the laws of the United States that the foregoing is
9 true and correct. Executed on the 4th of June 2012, in Las Vegas, Nevada.
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______
13
_________
Jeffrey Johnson
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Case No. 11-cv-01846-LHK
DECLARATION OF JEFFREY JOHNSON
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