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?
11:06
11:06
You've accused the Browser feature of this
particular device of infringing, right?
A
11:06
11:06
Thank you.
Q
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11:06
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?
A
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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