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 8
FILED UNDER SEAL

Highly Confidential Attorneys' Eyes Only

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION
APPLE INC., a California
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corporation,
)
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Plaintiff,
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vs.
) No: 11-CV-01846-LHK
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SAMSUNG ELECTRONICS CO., LTD,
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a Korean business entity;
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SAMSUNG ELECTRONICS AMERICA,
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INC., a New York corporation;
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SAMSUNG TELECOMMUNICATIONS
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AMERICA, LLC, a Delaware
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limited liability company
)
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Defendants.
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________________________________)

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**HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY**

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DEPOSITION OF JAEGWAN SHIN
San Francisco, California
Friday, January 27, 2012

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Reported By:
LINDA VACCAREZZA, RPR, CLR, CRP, CSR. NO. 10201
JOB NO. 44993
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MS. KIM:

Foerster for Apple.

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MS. YANG:

MR. TUNG:

Mark Tung from Quinn

09:32

Emanuel for Samsung.

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Michelle Yang from

Samsung.

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Samantha Kim, Morrison

THE VIDEOGRAPHER:

Will the court

reporter please swear in the witness.

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(Korean Interpreters sworn.)

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JAEGWAN SHIN,

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09:32

Having been duly sworn, by the

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Certified Shorthand Reporter, was

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examined and testified as follows:

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EXAMINATION
BY MR. KREEGER:

09:32

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Q.

Good morning.

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A.

Good morning.

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Q.

We met off the record, but my name

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is Matthew Kreeger, and I'm an attorney at

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Morrison Foerster.

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deposition.

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full name, please?

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A.

Yes.

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Q.

Mr. Shin, do you understand that

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We are here to take your

09:32

Could you begin by giving us your

My name is Jaegwan Shin.

I'm going to ask you a series of questions and

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SAMNDCA00201780, marked for

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identification.)

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BY MR. KREEGER:

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Q.

Have you seen the document that's

been marked as Exhibit 1338 before?

04:03

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A.

I don't recall.

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Q.

Have you seen documents in this

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format before?

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MR. TUNG:

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Objection.

THE WITNESS:

Vague.

This is a very

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common spreadsheet format documents.

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Q.

04:04

Mr. Shin, it appears that this

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spreadsheet lists a series of issues or perhaps

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bugs with the Galaxy Tab.

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document like this that lists bugs or issues with

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Samsung products?

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A.

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04:05

Yes, I have seen many documents

such as this.

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Have you ever seen a

Q.

Who generates documents of this

type?

04:05
MR. TUNG:

Objection.

Lacks

foundation.
THE WITNESS:

There is no

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particular person designated.

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be done by the QA team or it could be

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done by the R&D team.

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Q.

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Have you personally reported bugs

or issues with Samsung products?
A.

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No, I have not.
(Exhibit 1339, "Smartphone Feature

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Report," Bates stamped SAMNDCA00201683

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through SAMNDCA00201692, marked for

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04:07

identification.)

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BY MR. KREEGER:
Q.

Have you seen this document

04:07

before, Mr. Shin?

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A.

I don't recall.

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Q.

Do you know whether Samsung has

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replaced in certain products the bounce effect

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with a blue glow?

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04:08

MR. TUNG:

Caution the witness not

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to reveal the substance of any attorney-client

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communications in his answer.

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THE WITNESS:

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"blue glow"?

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Q.

What do you mean by
04:08

Well, has Samsung disabled the

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bounce effect on any of its products?

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MR. TUNG:

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THE WITNESS:

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Same caution.
Some models use the

bounce effects, some models don't.

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So

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I'm not quite sure as to that.

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ask me about disabling something?

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Q.

Did you

Has anyone in the San Jose lab

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worked on replacing the bounce effect with some

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other effect?

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A.

04:09
If you disable the bounce effect,

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then you would see the effects which was

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originally set at Google.

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might be someone who have worked on this.

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Q.

So I think that there

You think there might be someone

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at San Jose who worked on disabling the bounce

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effect so that you would see the effect

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04:11

originally set at Google?

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A.

Yes.

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Q.

And who do you think might have

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04:11

worked on that?
A.

If it is related to the browser, I

think it might be Qi Ling.

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(Exhibit 1340 was marked for

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identification but withdrawn.)

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04:12

BY MR. KREEGER:
Q.

Have you seen Exhibit 1340?
MR. TUNG:

Counsel, this is a

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privileged document.

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this back.

We need to claw
04:12

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MR. KREEGER:

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MR. TUNG:

All right.

Did you just mark

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Exhibit 1340?

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privileged document.

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I recognize this as a

MR. KREEGER:

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You don't need to

04:13

look at that.

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MR. TUNG:

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So I need to collect

the copies of it.

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MR. KREEGER:

I have some marking

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on this.

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it, but you can have the others.

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I'm going to have to destroy

MR. TUNG:

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04:13

I'm not going to take

the ones with markings on it.

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MR. KREEGER:

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We'll have to

destroy this.

04:13

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(Exhibit 1341, Email from Sangeon

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Kim dated April 27, 2011, Bates stamped

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SAMNDCA00202089 through SAMNDCA00202113,

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marked for identification.)

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BY MR. KREEGER:

04:14

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Q.

Have you seen Exhibit 1341 before?

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A.

I don't recall.

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Q.

If you turn to the page bearing

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Bates number that ends in 107, you'll see a

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table.

04:15

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