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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09:33
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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
TSG Reporting - Worldwide
It could
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04:05
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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.
TSG Reporting - Worldwide
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So
04:09
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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?
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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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