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
3
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.
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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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