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

Filing 1312

Declaration of Mark Tung in Support of 1269 ORDER by Judge Lucy H. Kohi> filed bySamsung Electronics America, Inc.(a New York corporation), Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC(a Delaware limited liability company). (Attachments: # 1 Exhibit 3, # 2 Exhibit 4, # 3 Exhibit 5, # 4 Exhibit 6, # 5 Exhibit 7, # 6 Exhibit 8, # 7 Exhibit 9, # 8 Exhibit 11, # 9 Exhibit 12, # 10 Exhibit 13, # 11 Exhibit 14, # 12 Exhibit 15)(Related document(s) 1296 ) (Maroulis, Victoria) (Filed on 7/24/2012) Modified on 7/25/2012 (fff, COURT STAFF).

EXHIBIT 5
FILED UNDER SEAL

Confidential Attorneys' Eyes Only

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION

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APPLE INC., a California
corporation,

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Plaintiff,
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vs.

CASE NO.

11-cv-01846-LHK

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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,
Defendants.
____________________________/

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C O N F I D E N T I A L
A T T O R N E Y S E Y E S O N L Y

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VIDEOTAPED DEPOSITION OF QI LING
SAN FRANCISCO, CALIFORNIA
WEDNESDAY, FEBRUARY 1, 2012

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BY: ANDREA M. IGNACIO HOWARD, CSR, RPR, CCRR, CLR
CSR LICENSE NO. 9830
JOB NO. 45295
TSG Reporting - Worldwide

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MR. TUNG:

Mark Tung from Quinn Emanuel for

Samsung.

09:31

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09:31
MS. YANG:

Michelle Yang for Samsung.

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QI LING,

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having been sworn as a witness

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by the Certified Shorthand Reporter,

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testified as follows:

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09:40

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EXAMINATION BY MR. KREEGER

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MR. KREEGER:

09:31

Good morning, Mr. Ling.

My

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name is Matthew Kreeger, and I'm an attorney for

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Apple, and I'm here to take your deposition today.

09:32

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Q

Have you ever been deposed before?

09:32

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A

No.

09:32

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Q

Why don't we start by -- if you could give us

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your full name.
A

Sure.

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09:32
09:32

My last name is L-I-N-G, Ling.

First name is

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Q-I, Qi.

09:32

Q

09:32

And where do you live, Mr. Ling, your home

address?

09:32

A

09:32

Home address is 1235 Wildwood Avenue,

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Apartment 190, Sunnyvale.

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sorry -- 94089.

ZIP code is 4 -- I'm

09:32
09:32

TSG Reporting - Worldwide

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THE WITNESS:

Anyone.

11:21

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MR. KREEGER:

Q.

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I don't mean to limit it.

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A

As long as there is one people.

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Q

I want to know if anybody in San Jose worked

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on this feature as part of the browser.

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MR. TUNG:

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THE WITNESS:

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team.

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Objection; lacks foundation.

Anybody else, I don't know.
MR. KREEGER:

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MR. TUNG:

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THE WITNESS:

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I can only say for the Tiger

Q.

What about the Tiger team?

Objection; vague.

MR. KREEGER:

I remember we got requests from

Q.

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HQ regarding the double tap zoom.

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11:21

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11:21

What requests do you

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remember?

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A

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I think the complaint is after double tap

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zoom out, there's -- the update of the web page is not

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quick enough.

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Q

HQ was complaining that when you double tap

zoom out, it took too long to update the web page?

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A

Too long to see the updated web page.

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Q

Was this the checkerboard problem?

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MR. TUNG:

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THE WITNESS:

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Objection; vague.
What do you mean by

"checkerboard problem"?
MR. KREEGER:

Q.

11:23
11:23

Was the problem that you

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would see a checkerboard pattern instead of the

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updated web page?

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A

I believe not every version has a

checkerboard.
Q

11:23

So you mentioned that HQ had an issue with it

taking too long to update the page on a zoom out.

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11:23

Do you remember any other requests from HQ

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that had anything to do with the double tap zoom

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feature?

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A

In a browser?

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Q

In a browser.

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A

I think there is a request that HQ complains

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the time user finished a finger gesture to the

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animation really start, the time is too long.

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Q

Any other requests from HQ relating to double

tap zoom in a browser?
A

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11:24

Again, I forgot to say those requests are

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specifically for a particular product, not for the

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whole -- not for all product.

It's just saying for

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this product, this is slow, or something like that.

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Q

Understood.

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A

No, I cannot remember any.

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Q

Do you know whether in -- whether or not in

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some Samsung products, the bounce effect has been

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replaced by a blue glow?

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TSG Reporting - Worldwide

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MR. TUNG:

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THE WITNESS:

What you mean by "replaced"?

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MR. KREEGER:

Q.

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Objection; vague.

Are there any products

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that -- are there any Samsung products where, instead

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of bouncing it, there is a blue glow?

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A

Blue glow?

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Q

Yes.

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A

You mean the product on the market or the

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product in our lab?

binaries, not official binaries.

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Because we are using testing

MR. TUNG:

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I'll just caution you not to

reveal products -- future products in development.

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MR. KREEGER:

Q.

11:26

What about in your lab?

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Have you come across any Samsung products where,

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instead of bouncing, there's a blue glow?

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A

I think I saw a tablet with old binary that

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has a bounce effect.

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bounce effect and with a blue glow writing.

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Q

And with new binary, there's no

Do you know who was involved in designing the

source code that created the blue glow?
A

Created blue glow?

I think it's created by

Google.
Q

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So in the Samsung tablet you were looking at,

it was Google code that created the blue glow?
A

11:27

I'm not 100 percent sure.

TSG Reporting - Worldwide

I only look at a

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device.
Q

I'm not looking at the source code.

11:27

Did anybody at the San Jose -- to your

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knowledge, did anybody at the San Jose Mobile

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Communications Lab have any involvement in

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implementing source code that would create this blue

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glow?

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MR. TUNG:

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THE WITNESS:

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Objection; lacks foundation.
Again, it's just created by

Google, not by us.

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MR. KREEGER:

Q.

Is there some other kind of

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glow?

You mentioned -- you had a question about blue

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glow.

Are there other colors of glow that you've seen

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implemented in Samsung devices instead of a bounce?

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A

In the honeycomb version, it is blue glow.

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And in the gingerbread version, I think it's not blue

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glow; it's another color.

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only.

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Q

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I'm talking about browser

11:28
And you think, again, that's -- that's

strictly Google code?
MR. TUNG:

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Objection; mischaracterizes

testimony.

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THE WITNESS:

Strictly Google code; what do

you mean?

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11:29

MR. KREEGER:

Q.

The code that creates the

blue or other color glow instead of a bounce, that's

TSG Reporting - Worldwide

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