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

Filing 1206

Administrative Motion to File Under Seal filed by Apple Inc.. (Attachments: #1 [Public] Apple's Opposition to Samsung's Motions in Limine, #2 Declaration of Joseph Kanada, #3 Exhibit 8, #4 Exhibit 11, #5 Exhibit 13, #6 Exhibit 14, #7 Exhibit 15, #8 Errata 16, #9 Exhibit 17, #10 Exhibit 18, #11 Exhibit 19, #12 Exhibit 20, #13 Exhibit 21, #14 Exhibit 22, #15 Exhibit 23, #16 Exhibit 24, #17 Exhibit 25, #18 Exhibit 26, #19 Exhibit 27, #20 Exhibit 28, #21 Exhibit 29, #22 Exhibit 30, #23 Exhibit 31, #24 Exhibit 32, #25 Exhibit 33, #26 Exhibit 34, #27 Exhibit 35, #28 Exhibit 36, #29 Exhibit 37, #30 Exhibit 38, #31 Exhibit 39, #32 Exhibit 40)(Jacobs, Michael) (Filed on 7/10/2012)

Exhibit 40

Apple v. Samsung
Confidential – Attorneys’ Eyes Only

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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

EXPERT REPORT OF KARAN
SINGH, PH.D. REGARDING
INFRINGEMENT OF U.S.
PATENTS NOS. 7,864,163,
7,844,915 AND 7,853,891

Defendants.

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**CONFIDENTIAL – CONTAINS MATERIAL DESIGNATED AS HIGHLY
CONFIDENTIAL – ATTORNEYS’ EYES ONLY PURSUANT
TO A PROTECTIVE ORDER**

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EXPERT REPORT OF DR. KARAN SINGH REGARDING INFRINGEMENT OF THE ’163, ’915 AND ’891 PATENTS
Case No. 11-cv-01846-LHK
sf-3123376

Apple v. Samsung
Confidential – Attorneys’ Eyes Only

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various companies in the computer graphics and design industries. Since 2002, I have also been

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the Chief Scientist at Geometry Systems, which is a company which designs software for the

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reverse engineering of physical objects into usable digital models. I also co-founded Arcestra,

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Inc. in 2006, which is a software service for conceptualizing and visualizing architectural

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interiors.

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devices inspired by a sketching metaphor.

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My current research focus is on interaction techniques for pen and touch based

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I have previously testified by deposition as an expert in proceedings before the

International Trade Commission in the ITC Investigation In re Certain Electronic Digital Media

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Devices and Components Thereof, Inv. No. 337-TA-796 on behalf of complainant Apple.

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III.

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MATERIALS CONSIDERED
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In forming my opinions and views expressed in this Report, I reviewed the ’163

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patent and its file history, the ’915 patent and its file history, and the ’891 patent and its file

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history.

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I have also examined all of the following Samsung products, which are sometimes

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referred to in this Report as the “Samsung Accused Products”: Acclaim, Captivate, Continuum,

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Droid Charge, Epic 4G, Exhibit 4G, Fascinate, Galaxy Ace, Galaxy Prevail, Galaxy S (i9000),

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Galaxy S 4G, Galaxy S II (including the i9100, T-Mobile, AT&T, Epic 4G Touch and Skyrocket

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variants), Galaxy S Showcase (i500), Galaxy Tab 7.0, Galaxy Tab 10.1,1 Gem, Gravity Smart,

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Indulge, Infuse 4G, Intercept, Mesmerize, Nexus S, Nexus S 4G, Replenish, Sidekick, Transform,

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and Vibrant.

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In addition, I have reviewed portions of Samsung’s website regarding most of

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these products. I have also reviewed portions of the user manuals for these products. Attached as

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Exhibit 2 is a chart that lists the Bates numbers where true and correct copies of printouts from

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www.samsung.com of user guides and technical specifications for various Samsung Accused

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Products have been produced.

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Galaxy Tab 10.1 refers to both the WiFi and LTE versions.

EXPERT REPORT OF DR. KARAN SINGH REGARDING INFRINGEMENT OF THE ’163, ’915 AND ’891 PATENTS
Case No. 11-cv-01846-LHK
sf-3123376

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Apple v. Samsung
Confidential – Attorneys’ Eyes Only

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equivalent to the corresponding structures described in the ’891 patent for performing the

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functions in claim 74. Accordingly, these three Samsung Accused Products infringe claim 74.

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VIII. CONCLUSION

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593.

My opinions are subject to change based on additional opinions that Samsung’s

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experts may present and information I may receive in the future or additional work I may

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perform. I reserve the right to supplement this Report with new information and/or documents

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that may be discovered or produced in this case, or to address any new claim constructions

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offered by Samsung or ordered by the court. With this in mind, based on the analysis I have

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conducted and for the reasons set forth above, I have preliminarily reached the conclusions and

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opinions in this Report.
594.

In connection with my anticipated testimony in this action, I may use as exhibits

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various documents produced in this Action that refer or relate to the matters discussed in this

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Report. I have not yet selected the particular exhibits that might be used. In addition, I may

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create or assist in the creation of certain demonstrative exhibits to assist in the presentation of my

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testimony and opinions as described herein or to summarize the same or information cited in this

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Report. Again, those exhibits have not yet been created.

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Dated: March 22, 2012

/s/
Karan Singh

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EXPERT REPORT OF DR. KARAN SINGH REGARDING INFRINGEMENT OF THE ’163, ’915 AND ’891 PATENTS
Case No. 11-cv-01846-LHK
sf-3123376

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