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

Filing 1204

Declaration of Deok Keun Matthew Ahn in Support of #1203 Claim Construction Statement filed byApple Inc.. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6)(Related document(s) #1203 ) (Jacobs, Michael) (Filed on 7/10/2012)

Exhibit 3

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

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APPLE, INC., a California Corporation

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vs.

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SAMSUNG ELECTRONICS COMPANY,

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LTD, a Korean business entity; SAMSUNG

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ELECTRONICS AMERICA, INC., a New

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York Corporation; SAMSUNG

CN:11-CV-01846-LHK

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TELECOMMUNICATIONS AMERICA, LLC,

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a Delaware Limited Liability Company.

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___________________________________/

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The videorecorded deposition of RAVIN

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BALAKRISHNAN, PH.D., was held on Friday, April 20,

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2012, commencing at 9:07 A.M., at the Law Offices of

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Quinn Emanuel, 1299 Pennsylvania Avenue, N.W., Suite

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825, Washington, D.C., before Ronda J. Thomas, a

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Notary Public.

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REPORTED BY:

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Ronda J. Thomas, RPR, CLR

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JOB NO. 48807
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Morrison and Foerster on behalf of the plaintiff,

09:08

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Apple.

09:08

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MR. AHN:

Forester on behalf of Apple.

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Matthew Ahn of Morrison and

MR. BUSEY:

09:08

And, also, I'm representing the

witness.

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09:08

09:08
09:08

THE VIDEOGRAPHER:

Will the court reporter

09:08

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please swear the witness.

09:08

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Whereupon,

09:08

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RAVIN BALAKRISHNAN, PH.D.,

09:08

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called as a witness, having been first duly sworn to tell 09:08

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the truth, the whole truth, and nothing but the truth, was09:08

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examined and testified as follows:

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09:08

EXAMINATION BY MR. JOHNSON:

09:08

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Q

Good morning, Dr. Balakrishnan.

09:08

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A

Good morning.

09:09

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Q

How many times have you been deposed now?

09:09

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A

I don't have a precise count.

09:09

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somewhere between half a dozen and ten.

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(Brief pause.)
Q

09:09

Sorry about that.

09:09
09:09

Apple?

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09:09

Is the bulk of your consulting work now for

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I would say

09:09
MR. BUSEY:

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Objection just to form.

The current litigation consulting I'm doing

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09:09
09:09

Page 186
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Q

Well, does the array of tiles move back in

the opposite direction after the user lifts her finger?

03:46
03:46

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A

In which image are you talking about?

03:46

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Q

I'm just talking about in the operation of

03:46

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LaunchTile.

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A

03:46
It may or may not, depending on where the

03:46

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finger is and where the, that blue, blue widget or blue

03:46

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circle is relative to where you lift the finger up.

03:46

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MR. JOHNSON:

Let's go ahead and take a

break.

03:46

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THE WITNESS:

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THE VIDEOGRAPHER:

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4.

Thank you.

03:46

This is the end of tape

We're off the record at 15:46.

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THE VIDEOGRAPHER:

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tape 5.

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03:57
This is the beginning of

BY MR. JOHNSON:

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We're back on the record at 15:58.

Q

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What's your definition of electronic

MR. BUSEY:

Objection to the extent it

calls for a legal conclusion.

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03:58
03:58
03:58

document as it's used in the '381 patent today?

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03:46
03:46

(Off the record.)

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03:46

03:58
03:58
03:58
03:58

(Witness reading.)
A

03:58

I believe the term is understood in this

04:00

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case to be the plain and ordinary meaning of electronic

04:00

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document.

04:00

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DISTRICT OF COLUMBIA, to wit:
I, RONDA J. THOMAS, a Notary Public of the

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District of Columbia, do hereby certify that the

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within-named witness personally appeared before me

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at the time and place herein set out, and after

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having been duly sworn by me, according to law, was

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examined by counsel.

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I further certify that the examination was
recorded stenographically by me and this transcript
is a true record of the proceedings.
I further certify that I am not of counsel to

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any of the parties, nor in any way interested in the

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outcome of this action.

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As witness my hand and notarial seal this
21st day of April, 2012.

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_____________________
RONDA J. THOMAS

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Notary Public

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My Commission Expires:

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August 31, 2013
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