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

Filing 1291

Statement (Joint) Regarding Use of Representative Products at Trial by Samsung Electronics America, Inc.(a New York corporation). (Attachments: #1 Declaration, #2 Exhibit, #3 Exhibit, #4 Exhibit, #5 Exhibit, #6 Exhibit, #7 Exhibit)(Maroulis, Victoria) (Filed on 7/23/2012)

EXHIBIT 2

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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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A

11:05

What I said before is I'm accusing the

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That's not quite what I said before.

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particular products that are listed in paragraph 37,

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running those particular applications that I examined

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in counsel's office and every other product out there

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that is of the same model and version of software and

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hardware, and also, I've looked at the code for each of

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these that are in the family of code and any device of

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the same type that's running that same chunk of code

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would also infringe.

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(Balakrishnan Exhibit 5 was marked for
purposes of identification.)
Q
Tab 7.0.

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MR. JOHNSON:

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MR. BUSEY:

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This is Exhibit 5?
Right.
Could I see that just a moment?

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11:06

You've accused the Browser feature of this

particular device of infringing, right?
A

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Thank you.
Q

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MR. BUSEY:

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11:05

I'm going to mark, as Exhibit 5, a Galaxy

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11:05

And you're representing this is the Galaxy

Tab 7.0?

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11:07
11:07

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Q

You tell me what it is.

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A

It says Galaxy Tab.

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It looks like the 7.0,

but you can't tell whether, can't 100 percent tell

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without the box.

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Q

Yeah, it's the 7.0.

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A

Okay.

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Q

So you've accused the Browser feature of

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infringing in this particular device, right?
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I've accused it in the device I saw at

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counsel's office -- sorry, Apple's counsel's office --

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and to the extent it's the same device on the same

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software, it would infringe.

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Q

Okay.

Well, take a look at the Browser

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function on, on this particular device, and this is the

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way it came out of the box.

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And I want to ask you whether this
particular Browser function infringes the '381 patent?

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11:08
11:08

(Witness reading.)
So this particular version of the Browser

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A

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that I'm looking at on this Galaxy Tab appears to do a

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hard stop instead of the functionality of the '381

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patent.

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Q

And you don't know what version of Browser

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you looked at on the Galaxy Tab that's referenced in

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your report?

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A

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As I said, it was the default Browser that

came on the device.
Q

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You don't know what that is, though?

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