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

Filing 1150

MOTION for Extension of Time and to Seal Documents re #1024 Administrative Motion to File Under Seal Documents Re Apples Opposition To Samsungs Motion For Summary Judgment, #1022 Administrative Motion to File Under Seal Documents Re Apples Opposition To Samsungs Motion For Summary Judgment, #1020 Administrative Motion to File Under Seal Documents Under Seal Re Apples Opposition To Samsungs Motion For Summary Judgment, #1023 Administrative Motion to File Under Seal Documents Re Apples Opposition To Samsungs Motion For Summary Judgment, #925 Administrative Motion to File Under Seal Apple's Motion for Summary Judgment of Non-Infringement of U.S. Patent Number 7,362,867 and Invalidity of U.S. Patent Numbers 7,456,893 and 7,577,460, #1013 Administrative Motion to File Under Seal Documents Under Seal Re Apples Opposition To Samsungs Motion For Summary Judgment filed by Samsung Electronics America, Inc.(a New York corporation), Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC(a Delaware limited liability company). Responses due by 7/2/2012. (Attachments: #1 Exhibit 1 to Samsung's Motion, #2 Declaration of Anthony P. Alden in Support of Samsung's Motion, #3 Exhibit 1 to the Alden Declaration, #4 Declaration of Hankil Kang in Support of Samsung's Motion, #5 Exhibit 1 to the Kang Declaration, #6 Exhibit 2 to the Kang Declaration, #7 Exhibit 3 to the Kang Declaration, #8 Exhibit 4 to the Kang Declaration, #9 Exhibit 5 to the Kang Declaration, #10 Exhibit 6 to the Kang Declaration, #11 Exhibit 7 to the Kang Declaration, #12 Exhibit 8 to the Kang Declaration, #13 Exhibit 9 to the Kang Declaration, #14 Exhibit 10 to the Kang Declaration, #15 Exhibit 11 to the Kang Declaration, #16 Exhibit 12 to the Kang Declaration, #17 Exhibit 13 to the Kang Declaration, #18 Exhibit 14 to the Kang Declaration, #19 Exhibit 15 to the Kang Declaration, #20 Exhibit 16 to the Kang Declaration, #21 Exhibit 17 to the Kang Declaration, #22 Exhibit 18 to the Kang Declaration Pt. 1 of 5, #23 Exhibit 18 to the Kang Declaration Pt. 2 of 5, #24 Exhibit 18 to the Kang Declaration Pt. 3 of 5, #25 Exhibit 18 to the Kang Declaration Pt. 4 of 5, #26 Exhibit 18 to the Kang Declaration Pt. 5 of 5, #27 Exhibit 19 to the Kang Declaration, #28 Exhibit 20 to the Kang Declaration, #29 Exhibit 21 to the Kang Declaration, #30 Exhibit 22 to the Kang Declaration, #31 Exhibit 23 to the Kang Declaration, #32 Exhibit 24 to the Kang Declaration, #33 Exhibit 25 to the Kang Declaration, #34 Exhibit 26 to the Kang Declaration, #35 Exhibit 27 to the Kang Declaration, #36 Exhibit 28 to the Kang Declaration, #37 Proposed Order Granting Samsung's Miscellaneous Administrative Request)(Maroulis, Victoria) (Filed on 6/28/2012)

KANG DECLARATION
EXHIBIT 11

Exhibit 30
(Submitted Under Seal)

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

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APPLE INC., a California
corporation,
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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H I G H L Y C O N F I D E N T I A L
A T T O R N E Y S' E Y E S O N L Y

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VIDEOTAPED DEPOSITION OF STEPHEN GRAY
Palo Alto, California
Friday, May, 4, 2012

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BY: HEIDI BELTON, CSR, RPR, CRR, CCRR
CSR LICENSE NO. 12885
JOB NO. 49273

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May, 5, 2012
8:57 a.m.

A P P E A R A N C E S:

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Videotaped deposition of STEPHEN GRAY, held
at the offices of Morrison & Foerster, LLP,
755 Page Mill Road, Palo Alto, California,
before Heidi Belton, CSR, RPR, CRR, CCRR.
CSR License No. 12885

FOR THE PLAINTIFF APPLE INC.:

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MORRISON & FOERSTER

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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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Mark E. Melahn, Esq.

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FOR DEFENDANT: SAMSUNG ELECTRONICS CO., LTD.

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QUINN EMANUEL URQUHART & SULLIVAN

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555 Twin Dolphin Drive

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Redwood Shores, California 94065

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By: Victoria F. Maroulis, Esq.

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and

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QUINN EMANUEL URQUHART & SULLIVAN

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51 Madison Avenue

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New York, New York 10010

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By: Guy Eddon, Esq.

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A P P E A R A N C E S C O N T ' D:
and
QUINN EMANUEL URQUHART & SULLIVAN
865 S. Figueroa Street
Los Angeles, California 90017
By: Patrick Schmidt, Esq.

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Also Present: Shawn Phillips, videographer

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TSG Reporting - Worldwide

PALO ALTO, CALIFORNIA
FRIDAY, MAY 4, 2012
8:57 a.m.
(Whereupon Exhibit 1 marked
for identification.)
THE VIDEOGRAPHER: This is the start of tape
labeled number 1 of the videotaped deposition of Steven
Gray. In the matter Apple, Incorporated versus Samsung
Electronics Company, Limited, et al., in the
United States District Court, Northern District of
08:56:57
California, San Jose Division. Number 12-CV-00630-LHK
[sic].
This deposition is being held at 755 Page Mill
Road, Palo Alto, California on May 4, 2012 at
approximately 8:57 a.m.
08:57:19
My name is Sean Phillips. I'm the legal video
specialist from TSG Reporting, Incorporated,
headquartered at 747 Third Avenue, New York, New York.
The court reporter is Heidi Belton, in association with
TSG Reporting.
08:57:38
Will counsel please introduce yourself.
MR. MONACH: Andrew Monach, representing
Apple.
MR. MELAHN: Mark Melahn, representing Apple.
MS. MAROULIS: Victoria Maroulis, counsel for 08:57:51

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separate structured electronic documents distinct from a 16:28:19
structured electronic document in which they're
contained?
MS. MAROULIS: Objection; vague. Please feel
free to refer to Exhibit 15.
16:28:30
THE WITNESS: Let me take a look.
So what I'm -- two things. I looked for -- in
the specification -- any evidence to suggest that the
boxes of content could not be a structured electronic
document. And I find nothing in here that suggests that 16:32:31
the boxes of content couldn't be structured electronic
documents on their own. But further, on column 19 -yeah. On column 19, line -- starting at line 17, it's a
discussion about a render tree, and about the nodes on
the render tree, and about the various kinds of nodes
16:33:05
that -- that the render tree could contain in it. The
render tree in the specification is used as a mechanism
for identifying the boxes of content and being able to
traverse to get to the boxes of content.
So let me put this into the record. "In some 16:33:26
embodiments, the structured electronic document has an
associated render tree with the plurality of nodes and
determining the first box at the location of the first
gesture comprises: Traversing down the render tree to
determine a first node in the plurality of nodes that
16:33:43

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corresponds to the detected location of the first
16:33:46
gesture, traversing up the render tree from the first
node to the closest parent node that contains a logical
grouping of content and identifying content
corresponding to the closest parent node as the first
16:34:00
box. In some embodiments, the logical grouping of
content comprises a paragraph, an image, a plug-in
object, or a table. In some embodiments the closest
parent node is replaced inline, a block, an inline block
or an inline table."
16:34:19
In those embodiments that we're talking about,
this logical grouping containing a paragraph, an image,
a plug-in, or a table, at least all of those could be -can be -- could clearly be structured electronic
documents. There's no preclusion about that.
16:34:35
Paragraphs have structure. Images can be
configured. A JPEG image, for example, has structure.
A plug-in object -- I'm not sure what they mean by a
"plug-in object," but certainly tables have structure.
So all -- in all of those instances, the render tree
16:34:55
nodes enable structured electronic documents to be part
of the -- the -- the system.
So to answer your question, there is support
for it and nothing to preclude it.
BY MR. MONACH:
16:35:09

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Q. In your Appendix 7, depo Exhibit 17, on page 4

16:35:10

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tiles to what's called a "zone view" of four tiles,
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right?
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A. That's correct.
16:35:35
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Q. Are you asserting that that change in the
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display is -- meets the enlarging, translating, and
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substantially centering a first-box limitation as
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recited in Claim 50 of the '163 patent?
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A. The -- with respect to claim 2B, there is a -- 16:36:04
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a first box which is selected from the world view that
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then is -- is enlarged and substantially centered. The
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world view is a collection of four boxes surrounding
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what they call the "blue dot."
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Q. Do you mean -- I'm sorry. Did you mean zone 16:36:28
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view?
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A. Sorry. Did I say -18
Q. You said "world view."
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A. Did I say "world view" too many times? The
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world view is the 6-by-6 matrix. The selection of one 16:36:37
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of the -- one of the boxes within a four-box matrix
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surrounding the blue dot in the world view creates a
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zone view. The zone view is -- what gets enlarged and
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substantially centered. So the -- this is a -- this is
a box within the world view which becomes centered and 16:37:01 25
you show the -- a transition from the world view of 36

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enlarged in the zone view.
16:37:05
Q. Does -- would you agree that Claim 50
requires -- I'm looking at the -- sort of the middle of
the claim near line 32 -- that what is required is
enlarging and translating the structured electronic
16:37:22
document so that the first box is substantially
centered?
MS. MAROULIS: Objection; vague. Calls for
legal conclusion.
THE WITNESS: I think you have -- with the
16:37:37
proviso there maybe alterations in the language. But I
think you've -- you've correctly read the limitation
starting at line 31.
MS. MAROULIS: We've been going for over an
hour.
16:37:53
THE WITNESS: Would you like to take a break
soon?
MR. MONACH: Let me just finish up with this.
MS. MAROULIS: Okay.
BY MR. MONACH:
16:37:57
Q. Is it your opinion that in the transition from
the world view to the zone view shown on page 4 of your
Appendix 7, that what has been enlarged and translated
is the same structured electronic document that is shown
in the world view?
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A. No. The document which is being shown in the 16:38:32
zone view on page 4 is a box of content from the
structured electronic document shown in the world view.
Q. Which is -- so the thing shown on the right is
a different structured electronic document than the
16:39:00
structured electronic document shown in the world view,
right?
MS. MAROULIS: Objection; vague.
THE WITNESS: I thought I said something
different, so let me try again.
16:39:16
The selection of -- of the box shown in -okay. In the world view on the left, there is
identified in red a first box. Selection of that box by
a first gesture enlarges and centers that box of content
in the zone view shown on the right.
16:39:38
BY MR. MONACH:
Q. But there is no enlarging and translating of
the structured electronic document shown on the left;
rather, the distinct -- in your view -- structured
electronic documents in those four tiles are enlarged
16:39:57
and centered?
MS. MAROULIS: Objection; vague. Assumes
facts.
BY MR. MONACH:
Q. Is that right?
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A. I believe that the enlarged and centered zone 16:40:11
view is a box of content found on the world view. It is
comprised of individual tiles or structured electronic
documents on their own. But it is from -- it is derived
or created from an enlargement of the world view
16:40:29
structured electronic document into the zone view.
BY MR. MONACH:
Q. So the world view electronic document, the
36-tile document is not enlarged as an entity and then
translated to center those four boxes, right?
16:40:48
MS. MAROULIS: Objection; vague.
THE WITNESS: I don't have any reason to
believe that -- well, let me say it slightly
differently. I'm not sure, sitting here today, exactly
what the -- the software performed with respect to
16:41:15
enlarging and centering. But given what the functions
are that are intended for LaunchTile, there is no reason
for me, sitting here today, to believe that the
structured electronic document that is -- that is the
world view is not enlarged and the portion of it that
16:41:34
was selected in that box of content simply enlarged and
translated into the zone view.
BY MR. MONACH:
Q. Let's look at the content from these four
boxes that are shown in the center of the world view and 16:41:46

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then are shown in -- on the right in the zone view.
16:41:53
On one -- for example, the upper right-hand
tile inside the red line you've drawn looks like an
e-mail icon. Do you see that?
A. In the -- yes. In -- in the first -- if
16:42:10
you're referring to the -- well, go ahead. Which one
are we pointing at?
Q. Right. So in the box that you've drawn in the
world view and labeled the first box, in the upper
right-hand corner, there is a tile that looks like it
16:42:26
has an e-mail icon. Do you see that?
A. I do.
Q. Right. And that is the -- that's a tile for
the e-mail application in LaunchTile, right?
A. I believe that -- yes, I believe that -- well, 16:42:44
it is a -- it is an icon derived from the e-mail
structured electronic document that underlies it. But
yes, it is a -Q. And then if you look on the right in the zone
view, you don't see a blowup or an enlargement of that 16:42:55
e-mail. What you see is a different level of detail.
You see a listing of individual e-mails within the
e-mail file. There's different content, correct?
MS. MAROULIS: Objection; misstates the
document.
16:43:15

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THE WITNESS: I don't -- I would not say that 16:43:20
it is different. Well, I'd say that both the upper
right -- upper right-hand corner of the zone view and
the upper right-hand corner of the first box are derived
from the same document. They're different
16:43:33
manifestations of the same document, but they are
derived from the same structured electronic document
which is the rendering of the e-mail system. It's
just -- based upon the screen real estate, it's a
different manifestation.
16:43:48
BY MR. MONACH:
Q. It's different content. It's not simply an
enlarging of the images that are shown in the tile in
the world view; it is a -- looking at different data and
displaying different data rather than displaying the
16:44:04
same thing in a larger font size or a larger image,
right?
MS. MAROULIS: Objection; argumentative.
Misstates the document.
THE WITNESS: Let me agree that it is not a
16:44:14
magnification of what's in the -- in the upper
right-hand corner of the first box of the world view.
It is not a magnification -- the upper right-hand corner
of the zone view is not a magnification of the original.
That's accurate.
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within the bounds of the -- of the 2-by-2 box. It is
17:04:34
enlarging and centering that in the -- in the LaunchTile
application view. It is an expansion of that box.
BY MR. MONACH:
Q. Okay. But -- and it is not an enlargement and 17:04:48
translation of a structured electronic document
consisting of these four squares of content, correct?
A. That is -- what it is doing -- yes. What it
is doing is enlarging and expanding the -- it happens to
be enlarging, but it's scrolling into position the upper 17:05:13
right-hand quadrant of the original first box, which is
the 2-by-2 matrix. It's not expanding the entire -entirety of the first box. This is -Q. Right.
A. -- the second box.
17:05:30
Q. And you cannot scroll or pan when you're in
the LaunchTile application view to see any of the
adjacent LaunchTile zone view boxes, right?
MS. MAROULIS: Objection; compound.
THE WITNESS: My best recollection of the way 17:05:54
that this operates is that -- is that -- let me think.
I don't -- sitting here right now, I don't remember
certainly whether or not there is the ability to slide
back to the other view. But I think not. I think -- so
let me -- sorry.
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I believe that from the selected second box, 17:06:34
which has been expanded and centered on page 5, is
labeled the "LaunchTile application view," that it is -from there, I don't know of a navigation path back to
the first box other than to go back up to the world view 17:06:51
and then select the zone again.
BY MR. MONACH:
Q. If you're working on a computer running
Windows and it has Microsoft Word and you double click
on the Microsoft Word icon so that the application is
17:07:17
launched and replaces whatever has been on the screen
previously, covers it up, would you consider that to be
enlarging and translating a structured electronic
document?
MS. MAROULIS: Objection; incomplete
17:07:34
hypothetical.
THE WITNESS: Would I consider it to be
enlarging and translating a structured electronic
document?
MR. MONACH: Mm-hmm.
17:07:46
THE WITNESS: I would not consider that -hadn't considered it before, but I would not, sitting
here right now, consider it enlarging and translating a
structured electronic document. What I think that is is
analogous to selecting one of these pieces of mail from 17:08:00

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the LaunchTile application view and opening that up.
17:08:05
The LaunchTile application view -- or the box labeled
"LaunchTile application view" is the second box that was
in the zone view and is derived from the same data and
was in the world view as well. So the expansion of the 17:08:20
world view -- of the 4-by-4 matrix to bring up -- so it
gets expanded and centered on the screen. And the
selection -- that's the first box. The gesture
selecting the second box then yields the expansion and
essentially centering to create the LaunchTile
17:08:41
application view.
If I were to now select one of those e-mail -one of those e-mails that's on that page and then go
into the e-mail reader, that then would be analogous to
selecting Microsoft Word which then is an application, 17:08:56
which now you're off on the races.
BY MR. MONACH:
Q. Does tapping on what you call the "second box"
launch the e-mail application in LaunchTile or not?
A. I think that the system, the way it's set up, 17:09:09
is that the e-mail application was opened at world view,
it's opened at zone view, and it's opened further at
LaunchTile application view.
MR. MONACH: Let's mark as the next exhibit -I believe it's Exhibit 18.
17:09:31

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THE VIDEOGRAPHER: Correct.
17:09:33
MR. MONACH: Appendix 8 from your invalidity
report.
(Whereupon Exhibit 18 marked
for identification.)
17:09:38
BY MR. MONACH:
Q. Mr. Gray, is the Robbins '349 patent one of
the pieces of prior art you've relied on in opining that
the -- at least some of the claims of the '163 patent
are invalid?
17:10:20
A. Yes. Robbins '349 is one of the pieces of
prior art that I believe invalidates some of the
asserted claims of the '163.
Q. Could you describe briefly how the Robbins
invention works.
17:10:46
MS. MAROULIS: Objection; vague. Calls for a
narrative.
THE WITNESS: The Robbins invention takes
large -- creates a -- allows for the display of a large
data set on a relatively small display surface and uses 17:11:01
a variety of techniques to segment that large
information space to allow for access to the -- to
details or to finer levels of detail regarding that
large information space.
BY MR. MONACH:
17:11:28

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Highly Confidential - Attorneys' Eyes Only
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the answer's yes. I think the description in 2B and 2C 17:34:53
in my -- in Exhibit 18 -- Deposition Exhibit 18 show a
selection of the first segment. And while that first
box is enlarged, selection of a second segment to -- I
mean, a second box which then will enlarge and center
17:35:24
that -- or, rather, center -- I shouldn't say -- or
zoom. Tap to zoom. So the first one is a tap to zoom.
The second gesture is a tap to scroll.
BY MR. MONACH:
Q. Please identify for me in your chart the first 17:35:41
box that's enlarged and substantially centered. Where
is that?
MS. MAROULIS: Objection; asked and answered.
THE WITNESS: In the description for 2B,
detecting a first gesture and determining the first box, 17:36:01
there's a -- an illustration there which the
illustration is labeled "340." And the text supports
the fact that the segment 6 has been enlarged and it's
substantially centered.
BY MR. MONACH:
17:36:18
Q. Where is the second box if you look at page
340 -- or Figure 340?
A. So in 2B, there isn't a second box shown.
When we go to 2C, which is a description of the ability
to enlarge and then show second boxes which are
17:36:32

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available as a second gesture, the illustration at 1420 17:36:39
shows an equal overlapping segmentation of adjoining
areas prior to the first gesture.
Q. Do you have anyplace where after a first
gesture that enlarges the first box, you can still see
17:36:57
the second box and then tap on the second box to
substantially center it?
MS. MAROULIS: Objection; asked and answered.
THE WITNESS: Well, I don't have an
illustration -- I don't have an illustration in the
17:37:12
claim chart that shows a first box with second boxes
which would -- which are available for a second gesture.
But I believe that the second describes -- describes the
method by which that second box with a second gesture
could be selected or preselected.
17:37:31
BY MR. MONACH:
Q. By pressing on a number key?
A. Well, one of the methods that -- that can be
used -- well, the input component, 230, can be any one
of a touch pad, key pad, pointing device, stylus,
17:37:47
joystick or D pad.
MS. MAROULIS: Okay. We're at seven hours, so
I think we're done with the deposition.
MR. MONACH: Okay. All right. Thank you.
MS. MAROULIS: I don't have any questions for 17:38:02

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the witness.
17:38:03
We'll reserve the right to review and sign. I
believe there was some discussion of code, so we'll put
it under protective order for now and we'll dedesignate
it as needed.
17:38:12
Thank you, everyone.
THE VIDEOGRAPHER: This marks the end of disk
4 of 4 and concludes today's deposition of Stephen Gray.
The time is 5:38 p.m. And we're off the record.
(The proceeding adjourned at 5:38 p.m.)

____________________
STEPHEN GRAY

Subscribed and sworn to before me
this day of
2012.
___________________________

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TSG Reporting - Worldwide

CERTIFICATE
STATE OF CALIFORNIA )
) ss.:
COUNTY OF CONTRA COSTA )
I, Heidi Belton, 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 STEPHEN GRAY, the witness whose
deposition is herein before set forth, was
duly sworn 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 5th day of May, 20112.
_________________________________
HEIDI BELTON, CSR, RPR, CRR, CCRR
Certified Shorthand Reporter No. 12885

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