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

Filing 1177

REPLY (re #1089 Administrative Motion to File Under Seal ) Apples Reply Regarding Design Patent Claim Construction filed byApple Inc.. (Attachments: #1 Declaration Of Jason R. Bartlett In Support Of Apples Reply Regarding Design Patent Claim Construction, #2 Exhibit 1, #3 Exhibit 2)(Jacobs, Michael) (Filed on 7/3/2012)

Exhibit 1

Highly Confidential - Outside Counsels' 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 JONATHAN IVE
SAN FRANCISCO, CALIFORNIA
THURSDAY, DECEMBER 1, 2011

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BY: ANDREA M. IGNACIO HOWARD, CSR, RPR, CCRR, CLR
CSR LICENSE NO. 9830
JOB NO. 43920
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MR. ZHANG:
Foerster, for Apple.

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Patrick Zhang, Morrison &

THE VIDEOGRAPHER:

Will the court reporter

please swear in the witness.

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JONATHAN IVE,

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having been sworn as a witness

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by the Certified Shorthand Reporter,

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testified as follows:

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THE VIDEOGRAPHER:

You may proceed.

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EXAMINATION BY MR. ZELLER

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MR. ZELLER:

Q.

Good morning.

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A

Good morning.

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Q

I understand you've had the pleasure of being

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deposed at least a couple of times before, but one, if

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I understand correctly, and tell me if -- if you

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recall this, was a case called Apple versus Future

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Power?

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A

Yes, I do recall.

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Q

All right.

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And generally speaking, that was about the

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iMac?

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A

Yes.
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what you've described?

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MR. JACOBS:

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THE WITNESS:

Objection; asked and answered.
I think the drawings -- I think

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Figure 1, in conjunction with Figure 3, I can't see

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any other interpretation than the one that I've --

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I've given you.

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MR. ZELLER:

Q.

Directing your attention to

Figure 2 --

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A

Yes.

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Q

-- you'll see that there are those three sets

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of diagonal lines --

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A

Yes.

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Q

-- as shown on the back surface?

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A

Yes.

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Q

And then if you take a look at Figure 4,

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you'll see that this is another view of the back

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surface, but it doesn't have those diagonal lines; do

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you see that?

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A

Yes.

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Q

Do you have an understanding as to why?

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A

No.

My -- my thought as a designer

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interpreting this drawing would be that in Figure 2,

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those three sets of lines make it clear that the back

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surface is flat, and that that has been established

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and communicated.
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And then in Figure 4, it's showing that this

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is a continuous single piece with radii that become

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the vertical wall.

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unambiguous to me.

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Q

And again, those two figures seem

Please take a look at Figure 1.

You'll see

that it has diagonal lines on the front surface.

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A

Yes.

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Q

Do you have an understanding as to what those

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lines depict?
A

Well, my -- my sense would be as a designer

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and the way that I would interpret this would be that

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they suggest that that surface is flat.

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in the way that they cross the -- the dotted line of

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the display aperture, that that surface is clear.

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my interpretation as a designer would be that it is

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both flat and clear.

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Q

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And then also

So

All right.
Directing your attention to Figure 3, you'll

see that Figure 3, another viewpoint of that --

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A

Yes.

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Q

-- front surface, also has the diagonal

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lines?

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A

Yes.

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Q

Do you see that?

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And I take it if you -- if I asked you that
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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
action.

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IN WITNESS WHEREOF, I have hereunto set my
hand this 2nd day of December, 2011.

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_______________________________________
ANDREA M. IGNACIO HOWARD, RPR, CCRR, CLR, CSR No. 9830

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