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

Filing 1287

EXHIBITS re #1189 Pretrial Conference Statement, Apple's Revised Deposition Designation List (Exhibit 3 to Joint Pretrial Conference Statement) filed byApple Inc.. (Related document(s) #1189 ) (Jacobs, Michael) (Filed on 7/23/2012)

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HAROLD J. MCELHINNY (CA SBN 66781)
[e-mail]
RACHEL KREVANS (CA SBN 116421)
[e-mail]
MICHAEL A. JACOBS (CA SBN 111664)
[e-mail]
JENNIFER LEE TAYLOR (CA SBN 161368)
[e-mail]
ALISON M. TUCHER (CA SBN 171363)
[e-mail]
RICHARD S.J. HUNG (CA SBN 197425)
[e-mail]
JASON R. BARTLETT (CA SBN 214530)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: [phone]

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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Attorneys for Plaintiff and
Counterclaim-Defendant APPLE INC.

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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.,

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Case No.

11-cv-01846 LHK (PSG)

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,

APPLE’S REVISED DEPOSITION
DESIGNATIONS LIST (EXHIBIT
3 TO JOINT PRETRIAL
CONFERENCE STATEMENT)
Place:
Judge:

Courtroom 4, 5th Floor
Hon. Lucy H. Koh

Defendants.

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02198.51855/4844969.1 APPLE’S REVISED EXHIBIT LIST
CASE NO. 11-cv-01846 LHK (PSG)
sf-3173959

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Pursuant to the July 19, 2012 Minute Order and Case Management Order (Docket No.
1267) Apple submits herewith as Exhibit 1 its revised witness list, previously submitted as
Exhibit 3 to the Joint Pretrial Conference Statement (Docket No. 1189-3).

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Dated: July 23, 2012
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MORRISON & FOERSTER LLP

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By:

/s/ Michael A. Jacobs
Michael A. Jacobs

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Attorneys for Plaintiff
APPLE INC.

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02198.51855/4844969.1 APPLE’S REVISED EXHIBIT LIST
CASE NO. 11-cv-01846 LHK (PSG)
sf-3173959

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Exhibit 1

Apple v. Samsung, No. 11-01846

EXHIBIT 3a
Apple’s Witness List

Name
Balakrishnan, Ravin

Blevins, Tony

Bressler, Peter

Chapman, Greg

sf-3165098

Witnesses Apple Expects to Present at Trial
Address
Substance of Testimony to Be Given
Previously provided
Dr. Balakrishnan is a Professor of Computer Science at the
University of Toronto. His fields of expertise include computer
science, human-computer interaction, and computer user
interfaces. Dr. Balakrishnan may testify regarding the contents
of and subjects disclosed in his expert reports, including the
technical background and state of the art relevant to the ’381
patent, Samsung’s infringement of that patent, the validity of
that patent, and the functionality and operation of Samsung’s
Accused Products.
Previously provided
Mr. Blevins is currently the Vice President of Procurement at
Apple. Mr. Blevins may testify regarding Apple’s history,
products, components, supply chain and procurement, supplier
relationships, and technology, and the sales and marketing of
Apple’s products.
Previously provided
Mr. Bressler, FIDSA, is an industrial designer and an adjunct
professor at the University of Pennsylvania. Mr. Bressler may
testify regarding the contents of and subjects disclosed in his
expert reports, including the industrial design, background, and
state of the art of the D’889, D’677, and D’087 patents,
Samsung’s infringement and Apple’s practice of those patents,
the validity and non-functionality of those patents, and the nonfunctionality of Apple’s asserted trade dress.
Previously provided
Mr. Chapman is currently an engineer at Apple and may testify
regarding the design, development, research, operation,
function, performance, features, and/or structure of the accused
Apple products.

Apple v. Samsung, No. 11-01846

EXHIBIT 3a
Apple’s Witness List

Name
Donaldson, Richard

Dourish, Paul

Forstall, Scott

sf-3165098

Witnesses Apple Expects to Present at Trial
Address
Substance of Testimony to Be Given
Previously provided
Mr. Donaldson was formerly a licensing executive at Texas
Instruments and has expertise in licensing and intellectual
property valuation, including with respect to declared-essential
patents. He may testify regarding the subjects disclosed in his
expert reports, including without limitation FRAND licensing;
whether Samsung’s licensing offers were consistent with
FRAND; the appropriate FRAND rate for Samsung's declaredessential UMTS patents; including the patents-in-suit, and the
Samsung-Intel license.
Previously provided
Dr. Dourish is a Professor of Informatics in the Donald Bren
School of Information and Computer Sciences at the University
of California, Irvine. His fields of expertise include computer
science, mobile computing systems, human-computer
interaction, embedded systems, and user interface design and
operation. Dr. Dourish may testify regarding the contents of
and subjects disclosed in his expert reports, including the
technical background and state of the art relevant to the asserted
claims of the ’893 patent, the interpretation of the asserted
claims of the ’893 patent, the invalidity of the ’893 patent, the
design and operation of Apple’s Accused Products as they relate
to the asserted claims of the ’893 patent, and Apple’s noninfringement of the asserted claims of the ’893 patent.
Previously provided
Mr. Forstall is the Senior Vice President of iOS software at
Apple and a named inventor of the ’163 patent. Mr. Forstall
may testify regarding the graphical user interfaces in Apple
products such as the iPhone and iPad, the design and
development process for these interfaces, and the inventions of
the ’381, 915, and ’163 utility patents and their significance.

Apple v. Samsung, No. 11-01846

EXHIBIT 3a
Apple’s Witness List

Name
Givargis, Tony

Hauser, John

Hedge, Alan

sf-3165098

Witnesses Apple Expects to Present at Trial
Address
Substance of Testimony to Be Given
Previously provided
Dr. Givargis is a Professor of Computer Science at the
University of California, Irvine. His fields of expertise include
computer science, computer architecture, and software design.
Dr. Givargis may testify regarding the contents of and subjects
disclosed in his expert reports, including the technical
background and state of the art relevant to the asserted claims of
the ’711 patent, the invalidity of the ’711 patent, the design and
operation of Apple’s Accused Products as they relate to the
asserted claims of the ’711 patent, and Apple’s noninfringement of the asserted claims of the ’711 patent.
Previously provided
Dr. Hauser is the Kirin Professor of Marketing at the MIT Sloan
School of Management. His field of expertise includes
marketing research, customer satisfaction, and consumer
decision-making. Dr. Hauser may testify regarding the contents
of and subjects disclosed in his expert report, including the
conjoint studies that he conducted to determine the price
premium Samsung consumers are willing to pay for the features
associated with the patents-in-suit.
Previously provided
Dr. Hedge is a Professor in the Department of Design and
Environmental Analysis at Cornell University and a Research
Professor in the Department of Mechanical and Aerospace
Engineering at Syracuse University. Dr. Hedge may testify
regarding the contents of and subjects disclosed in his expert
report, including the field of ergonomics and human factors, the
non-functionality of the D’889, D’677, D’087, and D’305
patents, and the non-functionality of Apple’s asserted trade
dress.

Apple v. Samsung, No. 11-01846

EXHIBIT 3a
Apple’s Witness List

Name
Kare, Susan

Kim, Emilie

Kim, Hyong

sf-3165098

Witnesses Apple Expects to Present at Trial
Address
Substance of Testimony to Be Given
Previously provided
Ms. Kare is an icon designer and user interface graphic
designer. Ms. Kare may testify regarding the contents of and
subjects disclosed in her expert reports, including icon and user
interface graphics design, the background of and state of the art
relevant to the D’305 patent, Samsung’s infringement and
Apple’s practice of that patent, the validity and nonfunctionality of that patent, and the non-functionality of Apple’s
asserted trade dress.
Previously provided
Ms. Kim is currently a software engineer at Apple on the Photos
and Camera apps team. Ms. Kim may testify regarding Apple
prior art and the design, development, research, operation,
function, performance, and features of the accused Apple
products.
Previously provided
Dr. Kim is a Professor of Electrical and Computer Engineering
at Carnegie Mellon University. Dr. Kim's fields of expertise
include wireless communication networks and the areas of
network management and control systems. Dr. Kim may testify
regarding the contents of and subjects disclosed in his expert
reports, including the technical background and state of the art
relevant to the asserted claims of the ’516, the claims of the
’516 patent, the invalidity of the asserted claims of the ’516
patent, the design and operation of Apple's Accused Products as
they relate to the asserted claims of the ’516 patent, and Apple's
non-infringement of the asserted claims of the ’516 patent. Dr.
Kim may also testify as to alternative technologies to the ’516
patent.

Apple v. Samsung, No. 11-01846

EXHIBIT 3a
Apple’s Witness List

Name
Knightly, Edward

Musika, Terry

sf-3165098

Witnesses Apple Expects to Present at Trial
Address
Substance of Testimony to Be Given
Previously provided
Dr. Knightly is a Professor of Electrical and Computer
Engineering at Rice University. His fields of expertise include
mobile and wireless communication networks and highperformance protocol design, analysis, and implementation, as
well as deployment of testbeds. Dr. Knightly may testify
regarding the contents of and subjects disclosed in his expert
reports, including the technical background and state of the art
relevant to the asserted claims of the ’941 patent, the asserted
claims of the ’941 patent, the invalidity of the ’941 patent, the
design and operation of Apple’s Accused Products as they relate
to the asserted claims of the ’941 patent, and Apple’s noninfringement of the asserted claims of the ’941 patent. Dr.
Knightly may also testify as to alternative technologies to the
’941 patent.
Previously provided
Mr. Musika is a CPA with over 37 years of experience and is a
managing director and co-founder of Invotex Group. His fields
of expertise include accounting, finance, valuation, business
planning, and economic damages analysis. Mr. Musika may
testify regarding the contents of and subjects disclosed in his
expert reports, including the damages that Apple has suffered
due to Samsung’s violation of Apple’s intellectual property and
a rebuttal of certain damages Samsung may seek in connection
with Samsung’s counterclaims. Mr. Musika may also testify in
rebuttal to Dr. O’Brien regarding the contents of and subjects
disclosed in his expert report concerning defects in the
methodology, assumptions, and data used by Dr. O’Brien in
calculating a reasonable royalty for the three Samsung feature
patents.

Apple v. Samsung, No. 11-01846

EXHIBIT 3a
Apple’s Witness List

Name
Ordover, Janusz

Poret, Hal

Rossi, Peter

sf-3165098

Witnesses Apple Expects to Present at Trial
Address
Substance of Testimony to Be Given
Previously provided
Dr. Ordover is a Professor of Economics at New York
University. His fields of expertise include industrial
organization, antitrust and regulation economics. He may
testify regarding the contents of and subjects disclosed in his
expert reports, including without limitation relevant industry
background; standardization of IPR; FRAND licensing; the
definition of the relevant input technologies markets; the effect
of Samsung's conduct on those markets; Samsung’s market
power; and the effects of Samsung’s conduct on downstream
competition.
Previously provided
Mr. Poret is an expert in the design and execution of consumer
surveys. Mr. Poret may testify regarding the contents of and
subjects disclosed in his expert report, including the
methodology and results of his surveys to test consumer
recognition of the iPhone and iPad trade dresses.
Previously provided
Dr. Rossi is the James Collins Professor of Marketing,
Statistics, and Economics at the Anderson School of
Management at UCLA. His fields of expertise include
marketing, statistics, economics, and survey research. Dr. Rossi
may testify regarding the contents of and subjects disclosed in
his expert report, including defects in the methodology,
assumptions, and data of Dr. Sukumar, and the reasons why Dr.
Sukumar’s opinions concerning alleged use of the patented
features and the value of the feature patents are invalid and
unreliable and an improper basis for calculating damages, in
rebuttal to Dr. Sukumar and Dr. O’Brien.

Apple v. Samsung, No. 11-01846

EXHIBIT 3a
Apple’s Witness List

Name
Schiller, Phil

Singh, Karan

Sood, Sanjay

sf-3165098

Witnesses Apple Expects to Present at Trial
Address
Substance of Testimony to Be Given
Previously provided
Mr. Schiller is the Senior Vice President of Worldwide Product
Marketing at Apple. Mr. Schiller may testify regarding Apple’s
marketing for Apple mobile devices such as the iPhone and
iPad, including information on advertising strategy and
expenditures, sales figures, other publicity for these products,
internal market research, and the marketing, advertising, and
retail channels for both Apple’s and competitors’ products. Mr.
Schiller also may testify regarding drivers of demand for
devices such as Apple’s iPhone and iPad products and the
competitive market for mobile devices, such as smartphones and
tablets.
Previously provided
Dr. Singh’s fields of expertise include computer science,
human-computer interaction, and computer user interfaces. Dr.
Singh may testify regarding the contents of and subjects
disclosed in his expert reports and declarations, including the
technical background and state of the art relevant to the asserted
claims of the ’163 and ’915 patents, Samsung’s infringement of
those patents, the validity of those patents, and the functionality
and operation of Samsung’s Accused Products as they relate to
those patents.
Previously provided
Dr. Sood is an Associate Professor at the Anderson Graduate
School of Management of the University of California, Los
Angeles. Dr. Sood may testify regarding the contents of and
subjects disclosed in his expert report, including the importance
of design in consumer choice, Apple’s brand equity, and the
impact of Samsung’s accused products on Apple’s product
designs and overall brand.

Apple v. Samsung, No. 11-01846

EXHIBIT 3a
Apple’s Witness List

Name
Srivastava, Mani

Stringer, Chris

Teksler, Boris

sf-3165098

Witnesses Apple Expects to Present at Trial
Address
Substance of Testimony to Be Given
Previously provided
Dr. Srivastava’s fields of expertise include mobile computing
systems, embedded systems, low-power systems, wireless
sensing, and wireless networks. Dr. Srivastava may testify
regarding the contents of and subjects disclosed in his expert
reports, including the technical background and state of the art
relevant to the asserted claim of the ’460 patent, the invalidity of
the ’460 patent, the design and operation of Apple’s Accused
Products as they relate to the asserted claim of the ’460 patent,
and Apple’s non-infringement of the asserted claim of the ’460
patent.
Previously provided
Mr. Stringer is currently a Senior Director of Industrial Design
at Apple and is a co-inventor on the D’889, D’677, and D’087
patents. Mr. Stringer may testify regarding the industrial design
process at Apple, the background, conception, and reduction to
practice of those patents, other designs considered by Apple,
and the background, design, and success of Apple’s products.
Previously provided
Mr. Teksler is the Director of Patent Licensing and Strategy at
Apple. Mr. Teksler may testify regarding Apple’s practices and
policies with respect to licensing of its intellectual property and
Apple’s efforts to stop Samsung from violating Apple’s
intellectual property and proprietary technology. Mr. Teksler
may also testify concerning Apple's licensing negotiations with
Samsung, the costs incurred by Apple in defense of Samsung’s
assertion of declared-essential patents, FRAND licensing, and
Apple’s licenses relating to UMTS declared-essential patents.

Apple v. Samsung, No. 11-01846

EXHIBIT 3a
Apple’s Witness List

Name
Van Liere, Kent

Witnesses Apple Expects to Present at Trial
Address
Substance of Testimony to Be Given
Previously provided
Dr. Van Liere is an expert in statistics and survey research
methods. He may testify regarding the contents of and subjects
disclosed in his expert report, including the methodology and
results of his surveys, whether consumers associate Samsung
phones with Apple, and whether consumers confuse the source
of the Samsung Galaxy Tab 10.1 with Apple.

Walker, Michael

Previously provided

Watrous, Bruce "BJ"

Previously provided

sf-3165098

Dr. Walker is the former Chair of the European
Telecommunications Standards Institute (“ETSI”) Board and
has expertise with respect to ETSI’s IPR policy as well as
disclosure and licensing of declared standards-essential patents.
He may testify regarding the contents of and subjects disclosed
in his expert report, including without limitation the ETSI IPR
policy, Samsung's failure timely to disclose the ’516 and ’941
patents, Samsung’s irrevocable commitments to ETSI under the
ETSI IPR policy to license those patents, and its breach of such
commitments by seeking injunctive relief in this case.
Mr. Watrous is the Vice President & Chief IP Counsel at Apple
and may testify concerning Apple’s licensing negotiations with
Samsung, the costs incurred by Apple in defense of Samsung’s
assertion of declared-essential patents, FRAND licensing, and
Apple’s licenses relating to UMTS declared-essential patents.

Apple v. Samsung, No. 11-01846

EXHIBIT 3a
Apple’s Witness List

Name
Winer, Russell

Name
Anzures, Freddy

Beyer, Tom

sf-3165098

Witnesses Apple Expects to Present at Trial
Address
Substance of Testimony to Be Given
Previously provided
Dr. Winer is the William Joyce Professor of Marketing and the
Chair of the Marketing Department at the Stern School of
Business, New York University. Dr. Winer may testify
regarding the content of and subjects disclosed in his expert
reports, including the strength of Apple’s brand, the relationship
between Apple’s product design and the strength of Apple’s
brand, the strength and fame of Apple’s asserted trade dress,
Samsung’s infringement and dilution of Apple’s asserted trade
dress, and the impact that Samsung’s accused products have on
Apple’s product designs and the overall Apple brand.

Witnesses Apple MAY CALL at Trial if the Need Arises
Address
Proposed Purpose of Testimony
Previously provided
Mr. Anzures is currently a Designer at Apple and is a coinventor on the D’305 patent. Mr. Anzures may testify
regarding the D’305 patent, including its background,
conception, and reduction to practice, the design process at
Apple, other designs considered by Apple, and the background,
design, and success of Apple’s products. Mr. Anzures also may
testify regarding the design and development of the iPhone user
interface unveiled at MacWorld 2007.
Morrison & Foerster LLP
Mr. Beyer is a legal assistant in the San Francisco office of
425 Market St.
Morrison & Foerster, counsel for Apple. Mr. Beyer may testify
San Francisco, CA
regarding the parties’ productions in this case, including the
94105
authenticity of documents and devices produced by Apple.

Apple v. Samsung, No. 11-01846

EXHIBIT 3a
Apple’s Witness List

Name
Brunner, Robert

Buckley, Mark

Christie, Greg

Denison, Justin

Hill, Arthur Lee IV

sf-3165098

Witnesses Apple MAY CALL at Trial if the Need Arises
Address
Proposed Purpose of Testimony
7 Broderick Street
Mr. Brunner is the former Senior Director of Industrial Design
San Francisco, CA 94117
for Apple. Mr. Brunner may testify concerning the “Brain Box”
concept, if introduced by Samsung despite the Court’s prior
rulings.
Previously provided
Mr. Buckley is a financial analyst at Apple, Inc. Mr. Buckley
may testify regarding information from Apple’s internal systems
relating to Apple’s financial results, Apple’s manufacturing
capacity, and the profitability of Apple’s products and services.
Previously provided
Mr. Christie is the Vice President of Human Interface at Apple
and a named inventor of the ’163 patent. Mr. Christie may
testify regarding the graphical user interfaces in Apple products
such as the iPhone and iPad, the design and development process
for these interfaces, and the inventions of the ’381, 915, and ’163
utility patents and their significance.
Address known to Samsung
Mr. Denison is STA’s Chief Strategy Officer. He may be called
to testify regarding the development, design, sales and marketing
of the accused Samsung products, Samsung’s awareness of and
consideration of Apple, its products, and its intellectual property,
competition between Apple and Samsung in the smartphone and
tablet markets, and the pricing and hardware and software design
of Samsung’s accused products.
Sony Mobile Communications
Mr. Hill is the General Counsel for Sony Mobile
USA, 3333 Piedmont Rd., Suite Communications (USA) Inc. He may be called to testify to the
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authenticity of sales records produced by Sony Mobile
Atlanta, GA
Communications (USA) Inc. and other Sony business records.
30305

Apple v. Samsung, No. 11-01846

EXHIBIT 3a
Apple’s Witness List

Name
Joswiak, Greg

Keeper of the Records

Witnesses Apple MAY CALL at Trial if the Need Arises
Address
Proposed Purpose of Testimony
Previously provided
Mr. Joswiak is the Vice President for iPod, iPhone, and iOS
Product Marketing at Apple. Mr. Joswiak may testify regarding
Apple’s marketing for Apple’s iOS devices such as the iPhone,
including Apple’s advertising strategy and expenditures, sales
figures, other publicity for these products, and internal market
research, and the marketing, advertising, and retail channels for
both Apple’s and competitors’ products. Mr. Joswiak also may
testify regarding the competitive market for mobile devices, such
as smartphones.
Sony Ericsson Mobile
The Keeper of the Records may be called to testify to the
Communications
authenticity of sales records produced by Sony Mobile
100 Redwood Shores Parkway,
Communications (USA) Inc. and other Sony business records.
Redwood City, CA

Lutton, Richard J.

Previously provided

Ording, Bas

Previously provided

Platzer, Andrew

Previously provided

sf-3165098

Mr. Lutton is the former Chief Patent Counsel at Apple. Mr.
Lutton may testify regarding Apple’s practices and policies with
respect to licensing of its intellectual property, Apple’s efforts to
stop Samsung from violating Apple’s intellectual property and
using Apple’s proprietary technology, and communications
between Apple and Samsung including licensing negotiations.
Mr. Ording is the named inventor of the ’381 patent and may
testify regarding its invention.
Mr. Platzer is a named inventor of the ’915 patent and may
testify regarding its invention.

Apple v. Samsung, No. 11-01846

EXHIBIT 3a
Apple’s Witness List

Name
Rosenbrock, Karl
Heinz

Samsung Custodian of
Records

Schroepfer, Peter

Shin, Jaegwan

Sittler, Ed

sf-3165098

Witnesses Apple MAY CALL at Trial if the Need Arises
Address
Proposed Purpose of Testimony
Previously provided
Mr. Rosenbrock is the former Director-General of ETSI and was
retained by Samsung as an expert witness in this and prior
litigation. Mr. Rosenstock may be called to testify concerning
the subjects of his deposition, including without limitation the
IPR policies of ETSI.
Address known to Samsung
Samsung’s Custodian of Records may be called to testify
regarding the authenticity of documents and devices produced by
Samsung Electronics Co., Ltd., Samsung Electronics America,
Inc., and Samsung Telecommunications America, LLC.
Morrison & Foerster LLP
Mr. Schroepfer is a Korean Language Translator and may testify
425 Market St.
regarding the parties’ Korean language interpretations.
San Francisco, CA
94105
Address known to Samsung
Mr. Shin is a Senior Director with Samsung’s Mobile
Communications Lab. Mr. Shin may testify regarding his work
at Samsung, including Samsung’s study and use of Apple
products in its own product design and Samsung’s infringement
of the asserted patents.
Morrison & Foerster LLP
Mr. Sittler is a legal assistant in the San Francisco office of
425 Market St.
Morrison & Foerster, counsel for Apple. Mr. Sittler may testify
San Francisco, CA
regarding the parties’ productions in this case, including the
94105
authenticity of documents and devices produced by Apple.

Apple v. Samsung, No. 11-01846

EXHIBIT 3a
Apple’s Witness List

Name
Sohn, Dale

Tchao, Michael

sf-3165098

Witnesses Apple MAY CALL at Trial if the Need Arises
Address
Proposed Purpose of Testimony
Address known to Samsung
Mr. Sohn is the CEO of STA and an officer at SEC. Mr. Sohn
may be called to testify regarding the accused Samsung
products, including their sale, marketing, and development, the
relationship between SEC and STA, Samsung’s analysis and
consideration of Apple’s products, designs, and technology, and
the direction and implementation of campaigns relating to
Apple.
Previously provided
Mr. Tchao is the Vice President of iPad Product Marketing at
Apple. Mr. Tchao may testify regarding Apple’s marketing for
Apple’s iPad devices, including the advertising strategy and
expenditures, sales figures, other publicity for these products,
and internal market research for these devices, and the
marketing, advertising, and retail channels for both Apple’s and
competitors’ products. Mr. Tchao may testify regarding the
competitive market for tablets.

Apple v. Samsung, No. 11-01846

EXHIBIT 3b
Deposition Designations

Witnesses
Ahn, Seung-Ho

Substance of Testimony To Be Given
1

Benner, Timothy

Chang, Dong Hoon1

Cheung, Benjamin

Cho, Joon-Young

Mr. Ahn is the head of the IP Center at Samsung. Apple may
present testimony from Mr. Ahn concerning the subjects of his
depositions, including without limitation Samsung’s licenses and
licensing practices.
Mr. Benner is STA’s Senior Manager of Consumer
Insights and Analytics. Apple may present testimony from Mr.
Benner concerning the subjects of his deposition, including without
limitation consumer surveys in Samsung’s possession relating to
the smartphone and tablet markets.
Mr. Chang is a Senior Vice President at Samsung and head of
SEC’s Mobile Design Group. Apple may present testimony from
Mr. Chang concerning the subjects of his depositions, including
without limitation the accused Samsung products, Samsung’s
design and development process and strategy, the availability of
alternative designs, Samsung’s awareness, consideration, analysis,
and emulation of Apple’s designs, technology, products, and/or
intellectual property, and customer confusion relating to tablet
designs.
Dr. Cheung is currently a lead system engineer at Alcatel Lucent.
Apple may present testimony from Dr. Cheung concerning the
subjects of his deposition, including without limitation the
interpretation of technical standards, the design, development,
research, operation, function, performance, features, structure,
and/or standards compliance of the radio network controller and
base station hardware used with the accused Apple products, and
communications with network operators concerning
implementation of particular features.
Mr. Cho is listed as a co-inventor on the ’516 patent and currently
works as a principal engineer at Samsung. Apple may present
testimony from Mr. Cho concerning the subjects of his deposition,
including without limitation the technical background and state of
the art relevant to the asserted claims of the ’516 patent, the delayed
disclosure of the ’516 patent to ETSI, the general patenting and IPR
disclosure process at Samsung, and Samsung’s incentives to patent
and/or contribute to technical standards.

1
sf-3166400

Apple v. Samsung, No. 11-01846

EXHIBIT 3b
Deposition Designations

Witnesses

Substance of Testimony To Be Given

Cho, Nara

Mr. Cho is a member of Samsung’s Smartphone Planning Group.
Apple may present testimony from Mr. Cho concerning the subjects
of his deposition, including without limitation the Galaxy Tab 10.1,
Samsung’s design and development of the Galaxy Tab 10.1, the
reasons for customer returns of the Galaxy Tab 10.1, and
Samsung’s awareness, consideration, analysis, and emulation of
Apple’s designs, technology, products, and/or intellectual property.

Choi, Sung Ho1

Mr. Choi is a standards engineer at Samsung. Apple may present
testimony from Mr. Choi concerning the subjects of his depositions,
including without limitation Samsung’s standards-setting policies
and procedures, Samsung’s policies and procedures about the
decisions to seek patents on standardized technology, and the facts
relating to Samsung’s participation in 3GPPP.

Choi, Gee-sung

Mr. Choi is the head of Samsung Group’s corporate strategy and
recently served as CEO and Vice Chairman of Samsung
Electronics. Apple may present testimony from Mr. Choi regarding
the subjects of his deposition, including without limitation the
accused Samsung products, Samsung’s design and development
process and strategy, its awareness, consideration, analysis, and
emulation of Apple’s designs, technology, products, and/or
intellectual property, Samsung’s corporate strategy and structure,
and Samsung’s practices and actions concerning the retention and
preservation of documents.
Mr. Chung is a member of the IP Center at Samsung. Apple may
present testimony from Mr. Chung concerning the subjects of his
depositions, including without limitation Samsung licenses and
licensing practices.

Chung, Minhyung1

Conley, Cira

Denison, Justin1

Ms. Conley is a corporate representative for Gravity Tank. Apple
may present testimony from Ms. Conley concerning the subjects of
her deposition, including without limitation Gravity Tank’s
relationship with and work for Samsung.
Mr. Denison is STA’s Chief Strategy Officer. Apple may
present testimony from Mr. Denison concerning the subjects of his
depositions or trial testimony, including without limitation the
accused Samsung products, Samsung’s sales and marketing of the
accused products, Samsung’s design and development process and
strategy, competition between Apple and Samsung, the overall U.S.
smartphone and tablet markets, and Samsung’s awareness,
consideration, analysis, and emulation of Apple’s designs,
technology, products, and intellectual property.

2
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Apple v. Samsung, No. 11-01846

EXHIBIT 3b
Deposition Designations

Witnesses

Substance of Testimony To Be Given

Eun, Sung-Ho

Mr. Sung-ho Eun is an engineer at Samsung. Apple may present
testimony from Mr. Eun concerning the subjects of his deposition,
including without limitation the design, development, conception,
reduction to practice, and/or prosecution of the ’893 patent.

Hong, Wong Pyo

Mr. Hong is an Executive Vice President and the head of SEC’s
global product strategy. Apple may present testimony from
Mr. Hong concerning the subjects of his deposition, including
without limitation the accused Samsung products, Samsung’s
design and development process and strategy, the availability of
alternative designs, Samsung’s consideration, analysis and
emulation of Apple’s designs, technology, products, and/or
intellectual property, Samsung’s corporate strategy and structure,
and the availability of alternative designs.
Mr. Jeong is a Senior Engineer at Samsung. Apple may present
testimony from Mr. Jeong concerning the subjects of his deposition,
including without limitation the design, development, conception,
reduction to practice, and/or prosecution of the ’711 patent, the
scope and content of the prior art, and Samsung products that
purportedly practice the ’711 patent.

Jeong, Moon-Sang

Kho, Wookyun

Kim, Seongwoo1

Kim, Soeng-Hun

Mr. Kho is an engineer in SEC’s Advanced Development Software
Group 1. Apple may present testimony from Mr. Kho concerning
the subjects of his deposition, including without limitation
Samsung’s implementation of the bounce feature in its products,
Samsung’s design and development process and strategy, its
awareness, consideration, analysis, and emulation of Apple’s
designs, technology, products, and/or intellectual property, and the
authenticity of certain documents.
Mr. Kim is the director of IP licensing at Samsung. Apple may
present testimony from Mr. Kim concerning the subjects of his
depositions and the topics for which he was designated as a
corporate representative, including without limitation Samsung’s
licenses and licensing practices.
Mr. Kim is listed as a co-inventor on the ’941 patent and a senior
engineer at Samsung. Apple may present testimony from Mr. Kim
concerning the subjects of his deposition, including without
limitation the technical background and state of the art relevant to
the asserted claims of the ’941 patent, the ’941 patent and the
asserted claims of the ’941 patent, the delayed disclosure of the
’941 patent to ETSI, the general patenting and IPR disclosure
process at Samsung, and Samsung’s incentives to patent and/or
contribute to technical standards.
3

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Apple v. Samsung, No. 11-01846

EXHIBIT 3b
Deposition Designations

Witnesses

Substance of Testimony To Be Given
1

Kim, Young-Bum

Mr. Kim is listed as a co-inventor on the ’516 patent and is a senior
engineer at Samsung. Apple may present testimony from Mr. Kim
concerning the subjects of his depositions, including without
limitation the technical background and state of the art relevant to
the asserted claims of the ’516 patent, the ’516 patent and the
asserted claims of the ’516 patent, the delayed disclosure of the
’516 patent to ETSI, the general patenting and IPR disclosure
process at Samsung, and Samsung’s incentives to patent and/or
contribute to technical standards.

Kwak, Yong-Jun1

Mr. Kwak is listed as a co-inventor on the ’516 patent and currently
works at Samsung. Apple may present testimony from Mr. Kwak
concerning the subjects of his depositions, including without
limitation the technical background and state of the art relevant to
the asserted claims of the ’516 patent, the ’516 patent and the
asserted claims of the ’516 patent, the delayed disclosure of the
’516 patent to ETSI, the general patenting and IPR disclosure
process at Samsung, and Samsung’s incentives to patent and/or
contribute to technical standards.
Mr. Lam is an engineer at Samsung. Apple may present testimony
from Mr. Lam concerning the subjects of his depositions, including
without limitation the accused Samsung products, the user interface
and functionality of the accused Samsung products, Samsung’s
awareness, consideration, analysis, and emulation of Apple’s
designs, technology, products, and/or intellectual property, and the
authenticity of certain documents.
Mr. Lee is listed as a co-inventor on the ’516 patent and is a
principal engineer at Samsung. Apple may present testimony from
Mr. Lee concerning the subjects of his depositions, including
without limitation the technical background and state of the art
relevant to the asserted claims of the ’516 patent, the ’516 patent
and the asserted claims of the ’516 patent, the delayed disclosure of
the ’516 patent to ETSI, the general patenting and IPR disclosure
process at Samsung, and Samsung’s incentives to patent and/or
contribute to technical standards.

Lam, Ioi1

Lee, JuHo1

4
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Apple v. Samsung, No. 11-01846

EXHIBIT 3b
Deposition Designations

Witnesses

Substance of Testimony To Be Given
1

Lee, JunWon

Lee, Kiwon1

Lee, MinHyouk1

Lee, Sanguen

Ling, Qi

Mr. Lee is SEC’s Director of Licensing. Apple may present
testimony from Mr. Lee concerning the subjects of his deposition or
for which he was designated as a corporate representative,
including without limitation Samsung’s awareness of Apple’s
patents, Samsung’s notice of Apple’s claims of patent infringement
and trade dress violations, and the lack of any Samsung licenses
comparable to the intellectual property at issue. Apple may also
present testimony from Mr. Lee concerning Samsung’s licenses and
licensing practices and Samsung’s policies and practices for
participating at ETSI and 3GPP.
Mr. Lee is a lead engineer at SEC. Apple may present testimony
from Mr. Lee concerning the subjects of his depositions or trial
testimony, including without limitation the accused Samsung
devices, Samsung’s devices’ interpretation of touch inputs,
scrolling and gestures, the source code for the Samsung devices,
Samsung’s competitive intelligence practices, Samsung’s
awareness, consideration, analysis, and emulation of Apple’s
designs, products, and/or technology, and the authenticity of certain
exhibits.
Mr. Lee is vice president of the Mobile Communications Division
Design Team at SEC. Apple may present testimony from Mr. Lee
concerning the subjects of his deposition or trial testimony,
including without limitation the accused Samsung products,
Samsung’s design and development process and strategy, its
awareness, consideration, analysis, and emulation of Apple’s
designs, technology, products, and/or intellectual property, and the
availability of alternative designs.
Mr. Lee is a Manager at Samsung. Apple may present testimony
from Mr. Lee concerning the subjects of his deposition, including
without limitation the accused Samsung products, Samsung’s
business and marketing strategy, Samsung’s awareness,
consideration, analysis, and emulation of Apple’s designs,
technology, products, and/or intellectual property, Samsung’s sales
to and communications with Best Buy, and Samsung’s customer
surveys.
Mr. Ling is an engineer at Samsung. Apple may present testimony
from Mr. Ling concerning the subjects of his deposition, including
without limitation the accused Samsung products, the user interface
and functionality of Samsung’s accused products, Samsung’s
awareness, consideration, analysis, and emulation of Apple’s
designs, technology, products, and/or intellectual property, and the
authenticity of certain documents.

5
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Apple v. Samsung, No. 11-01846

EXHIBIT 3b
Deposition Designations

Witnesses
Nam, Ki Hyung

Substance of Testimony To Be Given
1

Oh, Jeong Seok

Mr. Nam is a senior engineer at SEC. Apple may present testimony
from Mr. Nam concerning the subjects of his depositions or trial
testimony, including the authenticity of certain documents.
Mr. Oh is a senior engineer at Samsung. Apple may present
testimony from Mr. Oh concerning the subjects of his deposition,
including without limitation the design, development, conception,
reduction to practice, and/or prosecution of the ’460 patent, the
scope and content of the prior art, and Samsung products that
purportedly practice the ’460 patent.

Paltian, Markus

Mr. Paltian is a senior specialist, firmware development at Intel
Mobile Communications. Apple may present testimony from Mr.
Paltian concerning the subjects of his deposition, including without
limitation the interpretation of technical standards and the design,
development, research, operation, function, performance, features,
structure, and/or standards compliance of the baseband processor
used in the accused Apple products.

Park, Hyoung Shin1

Ms. Park is a Senior Designer at Samsung. Apple may present
testimony from Mr. Lee concerning the subjects of her depositions
or trial testimony, including without limitation the accused
Samsung products, Samsung’s design and development process and
strategy, its awareness, consideration, analysis, and emulation of
Apple’s designs, technology, products, and/or intellectual property,
and the availability of alternative designs.
Mr. Park is a director of product planning at Samsung. Apple may
present testimony from Mr. Park concerning the subjects of his
deposition, including without limitation the accused Samsung
products, Samsung’s design and development process and strategy,
its awareness, consideration, analysis, and emulation of Apple’s
designs, technology, products, and/or intellectual property,
Samsung’s competitive intelligence practices, and the authenticity
of certain documents.
Mr. Park is a principal engineer at Samsung. Apple may present
testimony from Mr. Park concerning the subjects of his deposition,
including without limitation the design, development, conception,
reduction to practice, and/or prosecution of the ’460 patent, the
scope and content of the prior art, and Samsung products that
purportedly practice the ’460 patent.

Park, Junho

Park, Sang-Ryul

6
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Apple v. Samsung, No. 11-01846

EXHIBIT 3b
Deposition Designations

Witnesses

Substance of Testimony To Be Given

Park, Seunggun

Mr. Park is Senior Vice President of the IP Center at Samsung.
Apple may present testimony from Mr. Park concerning the
subjects of his deposition, including Samsung’s compliance with
and understanding of the ETSI IPR policy regarding FRAND
licensing, its patent disclosures and FRAND commitments, and its
licenses and licensing negotiations.

Pendleton, Todd1

Mr. Pendleton is STA’s Chief Marketing Officer. Apple may
present testimony from Mr. Pendleton concerning the subjects of
his depositions, including without limitation the accused Samsung
products, Samsung’s and Apple’s product designs, competition
between Apple and Samsung, Samsung’s marketing and advertising
with respect to the feature patents, Samsung’s business, and the
overall U.S. smartphone and tablet markets.
Mr. Roarty was the corporate designee of Bloomberg LP. Apple
may present testimony from Mr. Roarty concerning the subjects of
his deposition, including without limitation the design and
development of Bloomberg terminals, alleged functional
constraints, and the availability of alternative designs.
Mr. Rosenberg is STA’s Senior Vice President of Mobile
Phone and Tablet Sales. Apple may present testimony from Mr.
Rosenberg concerning the subjects of his deposition, including
without limitation information concerning sales, pricing, retail
channels, and carriers of Samsung’s accused products, competition
between Apple and Samsung, Samsung’s business, Samsung’s
business strategies, and the overall U.S. smartphone and tablet
markets.
Mr. Rosenbrock is an expert witness retained by Samsung in this
and prior litigation. He is the former Director-General of ETSI.
Apple may present testimony from Mr. Rosenbrock concerning the
subjects of his depositions, including without limitation the IPR
policies of ETSI.

Roarty, Sean

Rosenberg, Brian

Rosenbrock, Karl Heinz1

Ryu, DongSeok

Mr. Ryu is responsible for UX negotiations with carriers at SEC.
Apple may present testimony from Mr. Ryu concerning the subjects
of his deposition, including without limitation Samsung’s design
and development process and strategy, its awareness, consideration,
analysis, and emulation of Apple’s designs, technology, products,
and/or intellectual property, Samsung’s ability to alter user
interfaces, Samsung’s business strategies, and the visual appearance
of Samsung’s user interfaces in relation to Apple’s user interfaces.

7
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Apple v. Samsung, No. 11-01846

EXHIBIT 3b
Deposition Designations

Witnesses
Schin, MinCheol

Sheppard, Tim1

Shin, Jaegwan1

Sohn, Dale

Substance of Testimony To Be Given
Mr. Schin is an executive for SEC’s Android Development Group
1. Apple may present testimony from Mr. Schin concerning the
subjects of his deposition, including without limitation the accused
Samsung products, Samsung’s design and development process and
strategy, Samsung’s awareness, consideration, analysis, and
emulation of Apple’s designs, technology, products, and/or
intellectual property, the user interface and functionality of
Samsung’s accused products, and the authenticity of certain
documents.
Mr. Sheppard is STA’s Vice President of Finance and
Operations. Apple may present testimony from Mr. Sheppard
concerning the subjects of his depositions, including without
limitation the financial results and profitability of Samsung’s
accused products, Samsung’s productions of financial information
to Apple, Samsung’s tax relationship with the United States and
transfer/allocation of profits between the three named defendants,
the pricing and sales of Samsung’s accused products, and
Samsung’s relationships with wireless network carriers.
Mr. Shin is an engineer at Samsung. Apple may present testimony
from Mr. Shin concerning the subjects of his depositions, including
without limitation the accused Samsung products, the user interface
and functionality of the accused Samsung products, Samsung’s
awareness, consideration, analysis, and emulation of Apple’s
designs, technology, products, and/or intellectual property, and the
authenticity of certain documents.
Mr. Sohn is STA’s President and Chief Executive Officer.
Apple may present testimony from Mr. Sohn concerning the
subjects of his deposition, including without limitation the accused
Samsung products, competition between Apple and Samsung,
similarity of Apple’s and Samsung’s products, Samsung’s
awareness, consideration, analysis, and emulation of Apple’s
designs, technology, products, and/or intellectual property, and its
awareness of Apple’s claims for patent infringement and trade dress
violations.

8
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Apple v. Samsung, No. 11-01846

EXHIBIT 3b
Deposition Designations

Witnesses
Van Der Velde, Himke

Van Lieshout, Gert-Jan

Yeo, JungMin

Name :
Name1:
Name2:

Substance of Testimony To Be Given
Mr. Van Der Velde is listed as a co-inventor on the ’941 patent and
currently works as a standards engineer at Samsung. Apple may
present testimony from Mr. Van Der Velde concerning the subjects
of his deposition, including without limitation the technical
background and state of the art relevant to the asserted claims of the
’941 patent, the ’941 patent and the asserted claims of the ’941
patent, the delayed disclosure of the ’941 patent to ETSI, the
general patenting and IPR disclosure process at Samsung, and
Samsung’s incentives to patent and/or contribute to technical
standards.
Mr. Van Lieshout is listed as a co-inventor on the ’941 patent,
currently works as a standards engineer at Samsung, and is a past
Chairman of the 3GPP RAN 2 working group. Apple may present
testimony from Mr. Van Lieshout concerning the subjects of his
deposition, including without limitation the technical background
and state of the art relevant to the asserted claims of the ’941 patent,
the ’941 patent and the asserted claims of the ’941 patent, the
delayed disclosure of the ’941 patent to ETSI, the general patenting
and IPR disclosure process at Samsung, and Samsung’s incentives
to patent and/or contribute to technical standards.
Ms. Yeo is an industrial designer at Samsung. Apple may present
testimony from Ms. Yeo concerning the subjects of her deposition,
including without limitation the accused Samsung products, the
design and development of Samsung’s tablet computer devices and
smartphone devices, Samsung’s awareness, consideration, analysis,
and emulation of Apple’s designs, technology, products, and/or
intellectual property, the availability of alternative designs, and
alleged functional constraints surrounding tablet design.

N.D. Cal. Case No. 11-cv-1846 only
N.D. Cal. Case No. 11-cv-1846; also ITC No. 337-TA-794, -796†
ITC No. 337-TA-794, -796 only

†

As Samsung has designated testimony from International Trade Commission Investigation Nos.
337-TA-794 & 796, Apple also does so.

9
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