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

Filing 1140

Administrative Motion to File Under Seal filed by Apple Inc.. (Attachments: #1 Wheeler Declaration in Support of Administrative Motion, #2 Proposed Order, #3 Declaration of Jason R. Bartlett, #4 Exhibit 1, #5 Exhibit 2, #6 Exhibit 3, #7 Exhibit 4, #8 Exhibit 5, #9 Exhibit 6, #10 Exhibit 7, #11 Exhibit 8, #12 Exhibit 9, #13 Exhibit 10, #14 Exhibit 11, #15 Exhibit 12, #16 Exhibit 13, #17 Exhibit 14, #18 Exhibit 15, #19 Exhibit 16, #20 Exhibit 17, #21 Exhibit 18, #22 Exhibit 19, #23 Exhibit 20, #24 Exhibit 21, #25 Exhibit 22, #26 Exhibit 23, #27 Exhibit 24, #28 Exhibit 25, #29 Exhibit 26, #30 Exhibit 27, #31 Public Declaration of Peter W. Bressler, #32 Exhibit 1, #33 Exhibit 2, #34 Exhibit 3, #35 Exhibit 4, #36 Exhibit 5, #37 Exhibit 6, #38 Exhibit 7, #39 Exhibit 8, #40 Exhibit 9, #41 Exhibit 10, #42 Exhibit 11, #43 Exhibit 12, #44 Exhibit 13, #45 Exhibit 14, #46 Exhibit 15, #47 Exhibit 16, #48 Exhibit 17, #49 Exhibit 18, #50 Exhibit 19, #51 Exhibit 20, #52 Exhibit 21, #53 Exhibit 22, #54 Exhibit 23, #55 Exhibit 24, #56 Exhibit 25, #57 Exhibit 26, #58 Exhibit 27, #59 Exhibit 28, #60 Exhibit 29, #61 Exhibit 30, #62 Exhibit 31, #63 Exhibit 32, #64 Exhibit 33, #65 Exhibit 34, #66 Exhibit 35, #67 Exhibit 36, #68 Exhibit 37, #69 Exhibit 38, #70 Exhibit 39, #71 Exhibit 40, #72 Exhibit 41, #73 Exhibit 42, #74 Exhibit 43, #75 Exhibit 44, #76 Exhibit 45, #77 Exhibit 46, #78 Exhibit 47, #79 Exhibit 48, #80 Exhibit 49, #81 Exhibit 50, #82 Exhibit 51, #83 Exhibit 52, #84 Exhibit 53, #85 Exhibit 54, #86 Exhibit 55, #87 Exhibit 56, #88 Exhibit 57, #89 Exhibit 58, #90 Exhibit 59, #91 Exhibit 60, #92 Exhibit 61, #93 Exhibit 62, #94 Exhibit 63, #95 Exhibit 64, #96 Exhibit 65, #97 Exhibit 66, #98 Exhibit 67, #99 Exhibit 68, #100 Exhibit 69, #101 Exhibit 70, #102 Exhibit 71, #103 Exhibit 72, #104 Exhibit 73, #105 Exhibit 74, #106 Exhibit 75, #107 Exhibit 76, #108 Exhibit 77)(Jacobs, Michael) (Filed on 6/26/2012) Modified on 6/27/2012 pursuant to General Order No. 62, attachment #1 sealed (dhm, COURT STAFF).

Exhibit 6

Highly Confidential - Outside Counsel's Eyes Only

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION

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APPLE INC., a California
corporation,

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Plaintiff,
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vs.

CASE NO.

11-cv-01846-LHK

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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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H I G H L Y
C O N F I D E N T I A L
O U T S I D E C O U N S E L O N L Y

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VIDEOTAPED DEPOSITION OF CHRISTOPHER STRINGER
REDWOOD SHORES, CALIFORNIA
FRIDAY, NOVEMBER 4, 2011

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BY: ANDREA M. IGNACIO HOWARD, CSR, RPR, CCRR, CLR
CSR LICENSE NO. 9830
TSG JOB NO. 43706
TSG Reporting - Worldwide

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FRIDAY, NOVEMBER 4, 2011
9:56 a m.

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VIDEOTAPED DEPOSITION OF CHRISTOPHER
STRINGER, taken at QUINN EMANUEL URQUHART & 7
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SULLIVAN, LLP, 555 Twin Dolphin Drive,
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Suite 560, Redwood Shores, California,
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Pursuant to Notice, before me,
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ANDREA M. IGNACIO HOWARD, CLR, CCRR, RPR,
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CSR License No. 9830.
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A P P E A R A N C E S:
FOR APPLE INC.:
MORRISON & FOERSTER
By: MICHAEL A. JACOBS, Esq.
425 Market Street
San Francisco, California 94105

FOR SAMSUNG ELECTRONICS CO. LTD:
QUINN EMANUEL URQUHART & SULLIVAN
By: MICHAEL T. ZELLER, Esq.
865 South Figueroa Street, 10th Floor
Los Angeles, California 90017

ALSO PRESENT: Benjamin Gerald, Videographer
Cyndi Wheeler, Apple, Inc.
---oOo---

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REDWOOD SHORES, CALIFORNIA
FRIDAY, NOVEMBER 4, 2011
9:56 a.m.

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THE VIDEOGRAPHER: Good morning. This marks 7
the beginning of the disc labeled No. 1 of the
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videotaped deposition of Chris Stinger -9
MR. JACOBS: Stringer.
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THE VIDEOGRAPHER: -- Stringer. In the
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matter Apple, Incorporated versus Samsung Electronics
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Company Limited, et al.
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Held in the United States District Court for
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the Northern District of California, San Jose
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Division. Case number is 11-cv-01846-LHK.
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This deposition is being held at 555 Twin
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Dolphin Drive, in the city of Redwood Shores,
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California. Taken on November 4th, 2011, at
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approximately 9:56 a.m.
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My name is Benjamin Gerald from TSG
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Reporting, Incorporated, and I am the legal video
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specialist. The court reporter is Andrea Ignacio, in
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association with TSG Reporting.
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At this time, will counsel please identify
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TSG Reporting - Worldwide

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themselves for the record.
MR. ZELLER: Mike Zeller for Samsung.
MR. JACOBS: Michael Jacobs from Morrison &
Foerster for Apple. With me is Cyndi Wheeler from
Apple Legal.
THE VIDEOGRAPHER: Thank you.
Will the reporter please swear the witness.
CHRISTOPHER STRINGER,
having been sworn as a witness,
by the Certified Shorthand Reporter,
testified as follows:
THE VIDEOGRAPHER: Thank you.
Please proceed.
EXAMINATION BY MR. ZELLER
MR. ZELLER: Let's please mark as
Exhibit 1161 the Reply Declaration of Christopher
Stringer in Support of Apple's Motion for Preliminary
Injunction.
(Document marked Exhibit 1161
for identification.)
MR. ZELLER: Q. Please let me know when
you've reviewed 1161.

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Q Focusing your attention at the first page --

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Page 103

Page 105

So let's, for the record, please mark as the
version of 841 that now has Mr. Stringer's marking on
it on page '18791 as Exhibit 841A.
(Document marked Exhibit 841A
for identification.)
MR. ZELLER: If we can go back to
Exhibit 1170. And by the way, did you want to send
those mockups back?
MR. JACOBS: That would be great.
MR. ZELLER: Okay. So let's go off the
record.
THE VIDEOGRAPHER: The time is 2:42 p m., and
we are off the record.
(Recess taken.)
THE VIDEOGRAPHER: The time is 2:55 p m., and
we are back on the record.
MR. ZELLER: Direct your attention to the
'889 design patent, which was previously marked as
Exhibit 8.
MR. JACOBS: I'll just hand you my copy.
THE WITNESS: All right. Thank you.
MR. ZELLER: Q. Please take a look at
Figure 1.
A Yes.
Q You'll see on Figure 1 that at least as part

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TSG Reporting - Worldwide

of the -- at least along part of the -- generally what
we'll call the perimeter area of the front, there's a
darker, thicker line?
A Which figure are you looking at?
Q This is Figure 1.
A Figure 1.
Q Do you see where at least on part of the
perimeter, there is a line that is darker and thicker?
A Which would be the second line from the left
on the left side of the figure.
Q Right, on the left side.
And then on the bottom portion of Figure 1,
it appears to run -- to be the line that is -- that
the -- is the edge, at least from that perspective?
A It looks like the edge, yes.
Q Do you know what that thicker line depicts?
A It's -- on the lower edge, it's the -- it
looks like the edge of the housing.
Q Well, what about on the left side?
A It's the edge of the housing.
Q So on both the left side and the bottom side,
you construe that darker, thicker line to be where the
edge of the housing is?
A I do construe that. And it's -- my
assumption is confirmed by looking at Figure 3 that

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No. 3 of 3 and concludes today's deposition of Chris
Stringer.
The time is 3:23 p m., and we are off record.
(WHEREUPON, the deposition ended at
3:23 p.m.)
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JURAT

I, CHRISTOPHER STRINGER, do hereby certify
under penalty of perjury that I have read the
foregoing transcript of my deposition taken
on November 4, 2011; that I have made such
corrections as appear noted herein in ink,
initialed by me; that my testimony as
contained herein, as corrected, is true and
correct.

DATED this ____ day of _____________, 2011,
at _____________________________, California.

__________________________________
SIGNATURE OF WITNESS

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CERTIFICATE OF REPORTER

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I, ANDREA M. IGNACIO HOWARD, hereby certify
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that the witness in the foregoing deposition was by me
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duly sworn to tell the truth, the whole truth, and
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nothing but the truth in the within-entitled cause;
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That said deposition was taken in shorthand
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by me, a Certified Shorthand Reporter of the State of
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California, and was thereafter transcribed into
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typewriting, and that the foregoing transcript
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constitutes a full, true and correct report of said
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deposition and of the proceedings which took place;
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That I am a disinterested person to the said
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action.
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IN WITNESS WHEREOF, I have hereunto set my
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hand this 4th day of November 2011.
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_______________________________________
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ANDREA M. IGNACIO HOWARD, RPR, CCRR, CLR, CSR No. 983023
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TSG Reporting - Worldwide

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INDEX
DEPOSITION OF CHRISTOPHER STRINGER
EXAMINATION
PAGE
BY MR. ZELLER
BY MR. JACOBS

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EXHIBITS
EXHIBIT
PAGE
Exhibit 1161 Reply Declaration of Christopher 5
Stringer in support of Apple's
Motion for a Preliminary
injunction; 50 pgs.
Exhibit 1162 Colored Photograph Ad of iPad 26
Thinner and Lighter; 1 pg.
Exhibit 1163 U.S. Patent No. D627,777 S;
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7 pgs.
Exhibit 1164 U.S. Patent No. D637,596 S;
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7 pgs.
Exhibit 1165 U.S. Patent No. D621,825 S;
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14 pgs.
Exhibit 1166 Sketchbooks, Bates Nos.
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APLNDC0000037650 - '95; 46 pgs.

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