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

Filing 1314

NOTICE by Samsung Electronics America, Inc.(a New York corporation), Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC(a Delaware limited liability company) re 1269 Order on Administrative Motion to File Under Seal,,, Order on Motion to Remove Incorrectly Filed Document, Order on Motion for Miscellaneous Relief, Unredacted Declaration of Mark Tung in Support of Samsung's Conditional Motion for Relief (Dkt. No. 953) (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)(Maroulis, Victoria) (Filed on 7/24/2012)

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.

09:31

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09:31

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QI LING,

09:31

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having been sworn as a witness

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by the Certified Shorthand Reporter,

09:31

testified as follows:

09:40

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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

09:31

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

09:31

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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

09:32

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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

09:32

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.

11:21

I don't mean to limit it.

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A

As long as there is one people.

11:21

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Q

I want to know if anybody in San Jose worked

11:21

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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.

11:21
11:21
11:21

HQ regarding the double tap zoom.

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11:21

11:21
11:21
11:21
11:21

What requests do you

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remember?

11:21

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A

11:22

I think the complaint is after double tap

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

11:22

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quick enough.

11:22

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Q

HQ was complaining that when you double tap

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

11:22
11:22

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A

Too long to see the updated web page.

11:22

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Q

Was this the checkerboard problem?

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MR. TUNG:

11:22

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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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Confidential Attorneys' Eyes Only

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would see a checkerboard pattern instead of the

11:23

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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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11:23
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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

11:24

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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.

11:24

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Q

Any other requests from HQ relating to double

tap zoom in a browser?
A

11:24
11:24

Again, I forgot to say those requests are

11:25

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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.

11:25

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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?

11:25

TSG Reporting - Worldwide

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MR. TUNG:

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THE WITNESS:

What you mean by "replaced"?

11:25

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MR. KREEGER:

Q.

11:26

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:

11:26

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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11:26
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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

11:27
11:27
11:27
11:27
11:27
11:27

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

11:28

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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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11:28
11:28
11:28

MR. KREEGER:

Q.

Is there some other kind of

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glow?

You mentioned -- you had a question about blue

11:28

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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.

11:28
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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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11:28

Objection; mischaracterizes

testimony.

11:28
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THE WITNESS:

Strictly Google code; what do

you mean?

11:29
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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11:29
11:29