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 14
Exhibit 43
(Submitted Under Seal)
Highly Confidential - Attorneys' Eyes Only
Page 1
1
2
3
4
5
6
7
8
9
10
11
12
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION
APPLE INC., a California
)
corporation,
)
)
Plaintiff,
)
)
vs.
) 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.
)
________________________________)
13
14
**HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY**
15
16
17
18
DEPOSITION OF BO-RA KIM
San Francisco, California
Wednesday, January 11, 2012
19
20
21
22
23
24
25
Reported By:
LINDA VACCAREZZA, RPR, CLR, CRP, CSR. NO. 10201
JOB NO. 45307
TSG Reporting - Worldwide
877-702-9580
Highly Confidential - Attorneys' Eyes Only
Page 5
1
and with me is Corey Cho.
2
MS. CARUSO:
Margaret Caruso Quinn
3
Emanuel, Urquhart & Sullivan for
4
Defendant Samsung.
5
THE VIDEOGRAPHER:
Would the
6
reporter please swear the witness and
7
09:18
interpreters?
8
BO-RA KIM
9
Having been duly sworn by the
10
Certified Shorthand Reporter, through the
11
Korean Interpretes, was examined and
12
testified as follows:
13
14
THE VIDEOGRAPHER:
Thank you.
Please proceed.
15
16
09:19
EXAMINATION
09:19
BY MR. ZHANG:
17
Q.
Good morning, Mr. Kim.
18
A.
Good morning.
19
Q.
You understand that you're
20
testifying under oath here today?
09:19
21
A.
Yes, I do.
22
Q.
And at times your attorney will
23
object; however, unless she instructs you not to
24
answer a question, you should answer my questions
25
fully and truthfully.
TSG Reporting - Worldwide
09:19
877-702-9580
Highly Confidential - Attorneys' Eyes Only
Page 88
1
know.
2
Q.
Do you have any idea why a picture
3
of this design is included in a document that is
4
titled "Dempsey" but doesn't relate to the
5
infusion 4G?
6
7
MS. CARUSO:
10
Objection.
Vague.
Mischaracterizes the record.
8
9
03:34
THE WITNESS:
I would not really
know the reason why because this is not a
document that I prepared.
11
MR. ZHANG:
03:34
I would like to mark
12
as Exhibit 1227 a document bearing the
13
Bates label SAMNDCA 000508091.
14
15
16
17
18
(Exhibit 1227 was marked for
identification.)
03:35
BY MR. ZHANG:
Q.
Mr. Kim, do you recognize this
document?
19
A.
Yes.
20
Q.
Did you write this document?
21
A.
No.
22
Q.
On the page that ends 91, the
I know about this.
23
front page, is the drawing under "Dempsey"
24
referring to the components that make up the
25
bezel of the Dempsey phone?
03:35
TSG Reporting - Worldwide
03:36
877-702-9580
Highly Confidential - Attorneys' Eyes Only
Page 89
1
MS. CARUSO:
2
Vague as to time.
3
THE WITNESS:
Objection.
Vague.
It is correct that
4
this portion is indicating the section
5
that's on the side of the window of
6
Dempsey.
7
Q.
03:37
Does this figure on the right-hand
8
side of the document represent final design of
9
the Dempsey phone?
10
MS. CARUSO:
Objection.
Vague.
11
Obviously this is only a portion of the
12
03:37
Dempsey, not the complete design.
13
THE WITNESS:
It would be
14
difficult for me to say that this would
15
be a finalized drawing just by looking at
16
a portion of this section, not the
17
entirety.
18
that this is not the final version.
19
Q.
03:39
And basically I would think
03:40
TSG Reporting - Worldwide
877-702-9580
Highly Confidential - Attorneys' Eyes Only
Page 90
1
2
(Discussion in Korean between
3
Interpreters.)
4
5
9
BY MR. ZHANG:
Q.
MS. CARUSO:
Objection.
10
ambiguous, and compound.
11
Vague,
THE WITNESS:
03:41
03:43
21
MS. CARUSO:
22
THE WITNESS:
Objection.
Vague.
03:46
TSG Reporting - Worldwide
877-702-9580
Highly Confidential - Attorneys' Eyes Only
Page 116
1
2
C E R T I F I C A T E
STATE OF CALIFORNIA
)
3
)
4
COUNTY OF SAN FRANCISCO )
5
I, LINDA VACCAREZZA, a Certified
6
Shorthand Reporter for the State of
7
California, do hereby certify:
8
That BO-RA KIM, the witness whose
9
deposition is hereinbefore set forth, was
10
duly sworn by me and that such deposition
11
is a true record of the testimony given
12
by such witness.
13
I further certify that I am not
14
related to any of the parties to this
15
action by blood or marriage; and that I
16
am in no way interested in the outcome of
17
this matter.
18
IN WITNESS WHEREOF, I have hereunto
19
set my hand this 11th day of January,
20
2012.
21
22
________________________________
23
LINDA VACCAREZZA, CSR. NO. 10201
24
25
TSG Reporting - Worldwide
877-702-9580