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

Filing 1180

Declaration of Hankil Kang in Support of #1140 Administrative Motion to File Under Seal filed bySamsung Electronics Co. Ltd.. (Attachments: #1 Exhibit 1, #2 Exhibit 2)(Related document(s) #1140 ) (Maroulis, Victoria) (Filed on 7/3/2012)

Exhibit 14
(Submitted Under Seal)

CONFIDENTIAL BUSINESS INFORMATION
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UNITED STATES INTERNATIONAL TRADE COMMISSION

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WASHINGTON, D.C.

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_______________________________________

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In the Matter of:

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CERTAIN ELECTRONIC DIGITAL

Case No.:

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MEDIA DEVICES AND COMPONENTS

337-TA-796

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THEREOF

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_______________________________________

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*** CONFIDENTIAL BUSINESS INFORMATION ***

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VIDEOTAPED PERSONAL DEPOSITION OF:

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GI-YOUNG LEE, VOLUME 2

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February 17, 2012

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Kim & Chang

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Daewoo, South Korea

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9:38 a.m. to 1:43 p.m.

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American Realtime Court Reporters / Asia
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to stipulation of counsel, was examined and testified
through the interpreter as follows:
EXAMINATION
BY MR. ZHANG:
Q. Good morning, Miss Lee.
A. Good morning.
Q. Do you recall that before we started our
deposition yesterday, you took an oath to tell the
truth?
A. Yes.
Q. And do you understand that you are still
under that oath here today?
A. Yes.
MR. ZHANG: like to mark as the next
I'd
exhibit a set of CAD drawings Bates labeled
SAMNDCA-CAD000030.
(Exhibit 12 was marked for identification.)
VIDEOGRAPHER: we go off the record for
Can
one second? I've just got to change something. Stand
by. I'm going off the record. The time is 9:40.
(Recess taken from 9:40 a.m. to 9:41 a.m.)
VIDEOGRAPHER: time is 9:41. We're back
The
on the record.
Q. (By MR. ZHANG) Miss Lee, if you could
please review the CAD drawings quickly.

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Do you recognize the design that's depicted
in these drawings?
A. I can recognize what this design is of.
COURT REPORTER: sorry, "I can" or "I
I'm
can't"?
LEAD INTERPRETER A. KIM: can."
"I

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MR. ZHANG: like to mark as the next
I'd
exhibit a Samsung phone model produced under number 48,
(Exhibit 13 was marked for identification.)
Q. (By MR. ZHANG) Miss Lee, if you could
review the model and tell me if you recognize what it
is.
A. I don't quite recognize it.

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MR. ZHANG:
I'll mark as the next exhibit a
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Samsung phone model produced under number 45
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(Exhibit 14 was marked for identification.) 5
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Q. (By MR. ZHANG) Miss Lee, if you could
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please review the model and tell me if you recognize
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it.
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A. Yes, I do.
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Q.

Did you personally make this model?
MS. NEILL:
Objection, vague.
I did not personally make this.
(By MR. ZHANG) Do you know who made this

A.
Q.
model?
A. I don't exactly recall.
Q. Does the model's physical appearance appear
altered to you in any way?
MS. NEILL:
Objection, vague.
A. I'm not sure.
Q. (By MR. ZHANG) Do you see any changes in
the model here today that you don't recall seeing the
last time that you saw the model?

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MS. NEILL:
Objection, vague.
A. I'm not quite sure, because it has been
quite some time since I last saw it.
MR. ZHANG:
Okay. I'll mark as the next
exhibit a Samsung phone model produced under number 58.
(Exhibit 15 was marked for identification.)
Q. (By MR. ZHANG) Miss Lee, if you could
please review the model and tell me if you recognize
it.
A. This is a model that I've seen before.

Q.

Did you personally make this model?
MS. NEILL:
Objection, vague.
As to that, I'm not sure.
(By MR. ZHANG) Do you know who did make the

A.
Q.
model?
A. I'm not exactly sure.
Q. Does the physical appearance of the model
look different than when the last time you saw it?
MS. NEILL:
Objection, vague.
A. Likewise, I don't quite recall as to that,
given that it has been a long time now.
MR. ZHANG:
I'll mark as the next exhibit a

CONFIDENTIAL BUSINESS INFORMATION
99..102
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Q. What do you recognize it to be?
A. This is an article reflecting in-house
interview.
Q. Did you and Mr. Tae Joong Kim work together
on the Galaxy Nexus?
MS. NEILL:
Objection, vague, lacks
foundation.
A. In some area we did together.
Q. (By MR. ZHANG) What area did you guys -- do
you and Mr. Kim work together on the Nexus?
MS. NEILL:
Objection, vague.
A. Designs . . .
(Interpreters conferring.)
A. Design specification.
Q. (By MR. ZHANG) Is it true that you and
Mr. Kim prepared this blog post together?
MS. NEILL:
Objection, vague, lacks
foundation.
A. We did not prepare this article as
reflected.
CHECK INTERPRETER P. KIM:
"Ourselves."
Q. (By MR. ZHANG) Do you recall my asking you
this question yesterday during your Northern District
of California deposition?
A. Are you saying that you asked this same

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Q. Are there any detriments to having a curved
front face for a touchscreen cellular phone?
MS. NEILL:
Objection, vague.
A. I'm not sure about that.
Q. (By MR. ZHANG) You're not aware of any
increased cost associated with making the front surface
of the Galaxy Nexus curved?
MS. NEILL:
Objection, vague, lacks
foundation.
A. I would think there would be also an
increase in cost.
Q. (By MR. ZHANG) Aside from cost, any other
detriments that you're aware of for making the front
surface of a mobile phone curved?
MS. NEILL:
Objection, vague.
A. Not that I can come up with at this moment.
MR. ZHANG: like to show the witness
I'd
what was previously marked as Exhibit 19 at the JinSoo
Kim deposition. And that is a Galaxy Vibrant phone.
MS. NEILL:
Objection, mischaracterizes the
record.
MR. ZHANG: it not a Vibrant phone?
Is
MS. NEILL:
It's a Vibrant, it's just not
necessarily called Galaxy Vibrant. It's a Samsung
Vibrant.

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question whether we prepared this article ourselves
yesterday?
Q. I'll ask a different question.
Do you recall testifying yesterday that you
and Mr. Kim prepared this blog post?
MS. NEILL:
Objection, mischaracterizes
prior testimony.
A. We prepared it together, in part.
Q. (By MR. ZHANG) Is it true that the front
face of the Galaxy Nexus is curved?
MS. NEILL:
Objection, vague.
A. Yes.
Q. (By MR. ZHANG) What are the advantages of
having a front surface to a touchscreen cellular phone
that is curved rather than flat?
MS. NEILL:
Objection, vague, lacks
foundation.
A. Like I testified earlier on NDCAL case,
since human face is shaped curved, I remember
testifying that the advantage, therefore, based on
that, would be advantageous to have it curved.
Q. (By MR. ZHANG) Can you think of any other
advantages here today?
A. I don't quite recall anything else at the
moment.
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MR. ZHANG: it's a Samsung Vibrant,
Oh,
okay.
Q. (By MR. ZHANG) Miss Lee, if you could
please take the phone out of the box and hold it up so
that the camera can make a record of it.
A. (Deponent complies.)
MR. ZHANG: you have it? Okay. Good.
Do
Thank you.
Q. (By MR. ZHANG) Miss Lee, do you know of a
reason why the speaker slot on a touchscreen mobile
phone could not be located at the top of the front
surface immediately underneath the metal band that
surrounds the front surface?
CHECK INTERPRETER P. KIM:
(Speaking in
Korean.)
MS. NEILL:
Objection, vague,
mischaracterizes the record.
A. I'm not sure about that.
Q. (By MR. ZHANG) Does that mean you know of a
reason or you don't know of a reason?
MS. NEILL:
Same objections.
A. I'm saying that I don't know about that for
sure.
Q. (By MR. ZHANG) Were you involved with the
design of a phone previously at Samsung that had its

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reasons, but none that I can come up with at this time.
Q. Are you aware of any detriments to having
rounded corners on a touchscreen cellular phone?
MS. NEILL:
Objection, vague.
A. None that I can think of at this time.
Q. (By MR. ZHANG) Are you aware of a detriment
associated with rounded corners whereby space is taken
away from the interior of the phone for components?
Maybe I can ask that better.
Are you aware that rounded corners on a
cellular phone can take away interior space for
components?
MS. NEILL:
Objection, vague.
A. I think that may vary depending on the shape
of components.
Q. (By MR. ZHANG) So turning your attention to
page 2 of Exhibit 2 again, and comparing the Vibrant
phone that's in front of you to the photograph of the

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MS. NEILL:
Objection, vague. Also object
to comparing a photograph to an actual object that
she's holding in her hand.
A. So just to clarify, did you just ask me one

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looks different from the other?
Q. (By MR. ZHANG) Yes.
A. Yes.

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MS. NEILL:
Objection, vague.
A. I don't know about that.
Q. (By MR. ZHANG) So you have no information
either way; is that correct?
MS. NEILL:
Same objection.
A. I don't think I can state as to that solely
by looking at the front surface of a phone, because
that may vary depending on what level of comfort the
user might feel.
CHECK INTERPRETER P. KIM:
"Front shape."
LEAD INTERPRETER A. KIM:
"The front surface
shape," that is.

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phone where the active area is not centered on the
front face?
MS. NEILL:
Objection, vague.
A. I think it may not be centered right in the
mid-point of the front surface.
Q.

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A. I find it hard to make that distinction
solely by looking at this photograph.
Q. (By MR. ZHANG) So the photograph . . .
A.
because
looking at this photograph reflected on this page, I
don't know whether this is a photograph depicting a
mock-up phone or actually a phone that has been
commercially released.
Q. So I believe you had two concerns about the
question, one was that the photograph is of poor
quality, so if I were to ask you the same question, but
to just tell you that I'm only asking you to look at

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Q. (By MR. ZHANG) Miss Lee, do you know of a
reason why the active area on a touchscreen cellular
phone has to be centered on the front face of the
phone?
MS. NEILL:
Objection, vague.
A. I think that varies depending on the phone.
Q. (By MR. ZHANG) So in your opinion, it is
possible to have a functioning touchscreen cellular

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CONFIDENTIAL BUSINESS INFORMATION
131..132
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(Counsel representing this witness should arrange for
reading and signing and thereafter distribute copies of
the signed Errata sheet to opposing counsel without
involvement of the court reporter.)

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DAEWOO

)
)
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STYLE OF CASE:

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SOUTH KOREA

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I, Melanie L. Giamarco, Registered
Professional Reporter and Certified Realtime Reporter,
do hereby certify that the aforementioned witness was
first duly sworn by me pursuant to stipulation of
counsel to testify to the truth; that I was authorized
to and did report said deposition in stenotype; and
that the foregoing pages are a true and correct
transcription of my shorthand notes of said deposition.

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DEPOSITION OF:

GI-YOUNG LEE

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DATE TAKEN:

February 17, 2012

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E R R A T A
Page

Line Change

S H E E T

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Reason

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I further certify that said deposition was
taken at the time and place hereinabove set forth and
that the taking of said deposition was commenced and
completed as hereinabove set out.

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Page 132

Certain Electronic Digital Media
Devices and Components Thereof

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C E R T I F I C A T E

I hereby certify that I have read my deposition and
that it is true and correct subject to any changes in
form or substance entered here.
________________
_________________________
Date
GI-YOUNG LEE

I further certify that I am not attorney or
counsel of any of the parties, nor am I a relative or
employee of any attorney or counsel of any party
connected with the action, nor am I financially
interested in the action.
The foregoing certification of this
transcript does not apply to any reproduction of the
same by any means unless under the direct control
and/or direction of the certifying reporter.

IN WITNESS WHEREOF, I have hereunto set my
hand this 19th day of February, 2012.

____________________________
Melanie L. Giamarco
Certified Realtime Reporter
Registered Professional Reporter
Certified Shorthand Reporter

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