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

Filing 1186

Administrative Motion to File Under Seal Apples Opening Supplemental Claim Construction Brief filed by Apple Inc.. (Attachments: #1 [Proposed] Order Granting Apple Inc.s Administrative Motion To File Documents Under Seal, #2 Apples Opening Supplemental Claim Construction Brief, #3 Declaration Of Ravin Balakrishnan, Ph.D., In Support Of Apples Opening Supplemental Claim Construction Brief, #4 Declaration Of Deok Keun Matthew Ahn In Support Of, #5 Exhibit 1, #6 Exhibit 2, #7 Exhibit 3, #8 Exhibit 4, #9 Exhibit 5, #10 Exhibit 6, #11 Exhibit 7)(Jacobs, Michael) (Filed on 7/5/2012)

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HAROLD J. MCELHINNY (CA SBN 66781)
[e-mail]
MICHAEL A. JACOBS (CA SBN 111664)
[e-mail]
RICHARD S.J. HUNG (CA SBN 197425)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff and
Counterclaim-Defendant APPLE INC

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WILLIAM F. LEE
[e-mail]
WILMER CUTLER PICKERING
HALE AND DORR LLP
60 State Street
Boston, MA 02109
Telephone: [phone]
Facsimile: [phone]
MARK D. SELWYN (SBN 244180)
[e-mail]
WILMER CUTLER PICKERING
HALE AND DORR LLP
950 Page Mill Road
Palo Alto, California 94304
Telephone: [phone]
Facsimile: [phone]

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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APPLE INC., a California corporation,

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Plaintiff,
v.
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,

Case No. 11-cv-01846-LHK (PSG)
DECLARATION OF DEOK KEUN
MATTHEW AHN IN SUPPORT OF
APPLE’S OPENING
SUPPLEMENTAL CLAIM
CONSTRUCTION BRIEF

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Defendants.
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DECLARATION OF DEOK KEUN MATTHEW AHN ISO APPLE’S OPENING SUPP. CLAIM CONSTRUCTION BRIEF
CASE NO. 11-cv-01846-LHK (PSG)
sf-3166912

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I, Deok Keun Matthew Ahn, declare as follows:

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I am an associate in the law firm of Morrison & Foerster LLP, counsel for Apple Inc.

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(“Apple”) in this action. I am licensed to practice law in the State of California and admitted to

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practice before this Court. I submit this declaration in support of Apple’s Opening Supplemental

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Claim Construction Brief.

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1.

Unless otherwise indicated, I have personal knowledge of the matters stated

herein. If called as a witness, I would testify to the facts set forth below.
2.

Attached hereto as Exhibit 1 is a true and correct copy of an excerpt from the

transcript of the 6/21/12 motions hearing before the Court.
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Attached hereto as Exhibit 2 is a true and correct copy of an excerpt from the

Internet and Technology Law Desk Reference (6th Ed.) (2004).
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Attached hereto as Exhibit 3 is a true and correct copy of an excerpt from the IBM

Dictionary of Computing (1994).
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Attached hereto as Exhibit 4 is a true and correct copy of an excerpt from the

Wiley Electrical and Electronics Engineering Dictionary (2004).
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Attached hereto as Exhibit 5 is a true and correct copy of an excerpt from Barron’s

Dictionary of Computer and Internet Terms (9th Ed.) (2006).
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Attached hereto as Exhibit 6 is a true and correct copy of an excerpt from the

5/2/12 transcript of the deposition of Andries Van Dam.
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Attached hereto as Exhibit 7 is a true and correct copy of a certified copy of U.S.

Patent No. 7,864,163.

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I declare under penalty of perjury that the foregoing is true and correct. Executed this 5th
day of July, 2012, at San Francisco, California.
/s/ Deok Keun Matthew Ahn
Deok Keun Matthew Ahn

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DECLARATION OF DEOK KEUN MATTHEW AHN ISO APPLE’S OPENING SUPP. CLAIM CONSTRUCTION BRIEF
CASE NO. 11-cv-01846-LHK (PSG)
sf-3166912

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ATTESTATION OF E-FILED SIGNATURE

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I, Michael A. Jacobs, am the ECF User whose ID and password are being used to file this

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Reply Declaration. In compliance with General Order 45, X.B., I hereby attest that Jason R.

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Bartlett has concurred in this filing.

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Dated: July 5, 2012

/s/ Michael A. Jacobs
Michael A. Jacobs

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DECLARATION OF DEOK KEUN MATTHEW AHN ISO APPLE’S OPENING SUPP. CLAIM CONSTRUCTION BRIEF
CASE NO. 11-cv-01846-LHK (PSG)
sf-3166912

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