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

Filing 1346

Unredacted Exhibits to Bartlett Decl ISO Apple's Response to Samsung's Opening Memo Re Design Patent Claim Construction (Dkt. No. 1140) re 1256 Order on Administrative Motion to File Under Seal, by Apple Inc.. (Attachments: # 1 Exhibit 2, # 2 Exhibit 3, # 3 Exhibit 4, # 4 Exhibit 5, # 5 Exhibit 6, # 6 Exhibit 7, # 7 Exhibit 8, # 8 Exhibit 9, # 9 Exhibit 10, # 10 Exhibit 11, # 11 Exhibit 12, # 12 Exhibit 13, # 13 Exhibit 14, # 14 Exhibit 27)(Jacobs, Michael) (Filed on 7/25/2012) Modified text on 7/26/2012 (dhm, COURT STAFF).

Exhibit 2
(Submitted Under Seal)

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION

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APPLE INC., a California
corporation,

)
)
)
Plaintiff,
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vs.
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SAMSUNG ELECTRONICS CO., LTD., )
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.
)
________________________________)

No: 11-cv-01846
LHK

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DEPOSITION OF CHRISTOPHER STRINGER
Redwood Shores, California
Wednesday August 3, 2011

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Reported By:
LINDA VACCAREZZA, RPR, CLR, CRP, CSR. NO. 10201
JOB NO. 40906
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August 3, 2011
9:05 a.m.
Videotaped Deposition of
CHRISTOPHER STRINGER, held at Quinn
Emanuel, 555 Twin Dolphin Drive,
Redwood Shores, California, pursuant
to Subpoena before Linda Vaccarezza, a
Certified Shorthand Reporter of the
State of California.

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A P P E A R A N C E S:
QUINN EMANUEL URQUHART & SULLIVAN
Attorneys for Samsung Electronics
865 S. Figueroa St., 10th Floor
Los Angeles, California 90017
BY: MICHAEL ZELLER, ESQ.
TAMAR BUCHAKJIAN, ESQ.
MARGRET CARUSO, ESQ.

MORRISON & FOERSTER
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Attorneys for Apple Inc.
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425 Market Street
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San Francisco, California 94105
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BY: MICHAEL A. JACOBS. ESQ.
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PATRICK ZHANG, ESQ.
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Also present: Erica Tierney, Apple Inc.
Videographer: Adam Del Rio

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THE VIDEOGRAPHER: Good
morning. This is the start of the tape
labled Number 1 to the videotaped
deposition of Christopher Stringer in the
matter of Apple, Incorporated versus
Samsung Electronics Company, Limited.
This deposition is being held
at 555 Twin Dolphin Drive on the 5th
floor in Redwood Shores, California, on
August 3rd 2011. And the approximate
time is 9:31 a.m.
My name is Adam Del Rio, the
legal video specialist from TSG
Reporting. The court reporter today is
Linda Vaccarezza from TSG Reporting,
headquartered at 747 3rd Avenue, New York
City, New York.
Counsel and all present please
identify yourselves for the record,
beginning with the questioning attorney,
please.
MR. ZELLER: Mike Zeller, Quinn
Emanuel for Samsung.
MS. BUCHAKJIAN: Tamar Buchakjian,
Quinn Emanuel for Samsung.
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MS. CARUSO: Margret Caruso, Quinn
Emanuel, for Samsung.
MR. JACOBS: Michael Jacobs,
Morrison Foerster, for Apple.
MR. ZHANG: Patrick Zhang,
Morrison Foerster, for Apple.
MS. TIERNEY: Erica Tierney for
Apple.
THE VIDEOGRAPHER: Thank you.
Will the court reporter please administer
the oath, and we can proceed.
C H R I S T O P H E R S T R I N G E R:
called as a witness, having been duly
sworn by the Certified Shorthand
Reporter, was examined and testified as
follows:
EXAMINATION BY:
MR. ZELLER:
Q Good morning.
A Hi.
Q Have you ever had your deposition
taken before?
A Yes.
Q On how many times?
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Q. Any other purpose?
A. No.
Q. The iPad does, in fact, have a
black border underneath the clear flat surface.
True?
A. True.
Q. The iPad 2 does as well, true?
A. It does include a black version,
yes.
Q. What does the black border do for
the iPad?
MR. JACOBS: Objection. Vague.
THE WITNESS: Our intention is
that it creates a seamless black surface
on the entirety of the front of the
product when the display is off such that
when the display is lit, it magically
appears in the center of this previously
singular black surface.
Q. Does the black border of the iPad
perform any function at all?
MR. JACOBS: Objection. Vague.
THE WITNESS: No.
Q. Does the black border of the iPad
2 perform any function at all?
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form.
THE WITNESS: I did not do
anything other than to discuss with the
aforementioned designers.
Q. What is underneath the black
borders of the iPad product?
A. There are structural elements.
There are technologies and connecters and buttons
at some place beneath the black borders and in
front of the rear surface.
Q. That's true of the iPad 2 as well,
right?
MR. JACOBS: Object to the form.
THE WITNESS: Yes.
Q. Please tell me what's your
understanding as to why the display screen itself
for the iPad or the iPad 2 doesn't run from edge
to edge and it has borders.
A. Could you say that again?
Q. Please explain for me your
understanding as to why the iPad and the iPad 2
have a screen that doesn't run all the way to
each edge? Why don't they have edge-to-edge
display screens?
A. We chose to have a complete
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MR. JACOBS: Objection. Vague.
THE WITNESS: No, not to my
understanding of a described function.
Q. What did you do to try to
determine whether or not that black border for
the iPad and the iPad 2 performed any function?
A. The function was aesthetic, as I
described.
Q. My question is: What did you do
to determine whether or not the black border for
the iPad and the iPad 2 performed any function?
MR. JACOBS: Object to the form of
the question.
THE WITNESS: We discussed the
process of design and we recalled clearly
our objective in terms of creating that
singular black oily pond-like surface
across the front of the product. That
was the purpose of the black border.
Q. Anything else?
A. That was the purpose of the black
border.
Q. My question is: Did you do
anything else to investigate that?
MR. JACOBS: Objection. Vague,
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housing that without any breaks in product lines
extends up to the top surface of the product.
Q. Are there any technical challenges
to having an edge-to-edge display screen for a
portable electronic device?
A. There are technical challenges in
extending glass any amount past the display area
that needs to be transparent.
Q. It true that you understand a
purpose of the black border for the iPad and the
iPad 2 is in order to hide the electronic
components that are underneath the surface, true?
A. There are numerous ways to conceal
components beneath the edge of the screen.
Q. I'm not asking you about
alternatives. My question is: Is it not true
that that is, in fact, a purpose of the black
border?
A. The purpose of the black border is
a design goal which is to extend a single
monotone plain that resembles an oily pond across
the entire front surface of the product such that
the display when lit emerges magically from the
center.
Q. Please tell me yes or no. Does
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"Question: You'll agree with me
that the thicknesses of the iPad
and the iPad 2 are defined by the
technical specifications to be
met in a way, can be manufactured
and sold to consumers at a cost
that consumers will pay?")
MR. JACOBS: Objection. Form.
THE WITNESS: I don't agree with
that statement as stated.
Q. So the design of the iPad and the
iPad 2 has the profile of it made in a completely
arbitrary thickness independent of technical and
cost considerations; is that true? Is that your
testimony?
A. What we do is that we define the
technical specification as we design the product,
which means that we manipulate the technical
specifications and invent solutions in order to
package them within our designs.
Q. Are any aspects of the design of
the iPad and the iPad 2 dictated by functional
considerations?
A. No.
Q. You can't think of a single one
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surface?
MR. JACOBS: Object to the form.
THE WITNESS: I do not believe
that iPad -- iPad, the first iPad and the
second iPad differ in that one is flat
and one is not. It is subjective to the
idea that one is better than the other.
Q. Isn't it true that one functional
advantage to having electronic devices with a
flat surface is that it will sit flat on a table,
yes or no?
A. If that is an important criteria,
it is arguably so.
Q. So you can't even answer that
question whether one functional advantage of
having electronic device with a flat surface is
that it will sit flat on a table; is that right?
A. It's easier to pick up a device
that does not sit flat on a table.
Q. You can't think of a single
advantage from having an electronic device that
can sit flat on a table, is that your testimony?
MR. JACOBS: Object to the form.
THE WITNESS: I think the merits
of sitting flat on a table are
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that is. Is that true?
MR. JACOBS: Object to the form.
THE WITNESS: As I understand the
question.
Q. And the same is true of the iPhone
products; is that right? Not a single element of
the design of those products is dictated by
functional considerations at all, right?
MR. JACOBS: Objection. Form.
THE WITNESS: The design is
defined aesthetically, and we work very
hard to find technical solutions to
enable and implement the designs.
Q. Can you, as an industrial
designer, think of a single advantage, just even
one, to having an electronic device that is in
the form of a rectangle?
MR. JACOBS: Objection.
MR. ZELLER: Has even one occurred
to you?
MR. JACOBS: Object to the form.
THE WITNESS: I cannot relate to
the question. I do not understand it.
Q. Can you think of any advantage to
having an electronic device that has a flat
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subjective.
Q. So you don't think it's an
advantage to having an electronic device that can
sit flat on a table as opposed to rolling off of
it; is that right?
MR. JACOBS: Object to the form.
THE WITNESS: Having a surface
that is not flat does not indicate that
it would ever roll off a flat surface.
Q. Why is it that the back of the
iPhone 4 is flat as opposed to the earlier
versions of the iPhone? Do you know why?
A. We chose to put glass on both
front and back so that we could carry the same
aesthetic on both sides of the product.
Q. Isn't it true that one reason why
the surface of the back of the iPhone 4 is flat
is because consumers complained that the earlier
versions of the iPhone had rounded backs and
wouldn't sit flat on a table?
A. The reason the back of that phone
is flat is because we chose it to have the same
aesthetics as the front side of the product and
to be made in the same materials in the same
manner, giving the same visual appearance.
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Q. I asked you about one reason. You
keep on dodging this question. Isn't it true
that one reason why the surface of the back of
the iPhone four is flat is because consumers
complained, consumers complained that the earlier
version of the iPhone had rounded backs and
wouldn't sit flat on a table?
A. That is not the reason why we
dictated the design would be flat on the back
surface.
Q. You keep on saying that is not the
reason why. I'm asking you, isn't it true that
that was a reason?
A. I cannot say that it was a
contributing reason.
Q. Consumers did make that complaint,
true?
A. I do not know exactly what
complaints consumers made. I do not have a
recollection within the time frame.
Q. You say exactly. You know you
know full well that consumers complained about
that, don't you, generally?
A. I do not have a clear, dated
memory of when I may or may not have heard
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feedback. I have also never -- it has never been
dictated to us that we respond to consumer
comments.
Q. I'm not asking about what's been
dictated to you. I'm asking you about advantages
and disadvantages of designs. Do you not -don't you have enough information to be able to
talk about what an advantage or disadvantage
might be of a design?
MR. JACOBS: Object to the form.
THE WITNESS: We discuss every
detail of designs.
Q. Can you imagine any circumstance,
any one at all where it might be advantageous to
have an electronic device with a flat surface?
MR. JACOBS: Object to the form.
THE WITNESS: I can see so many
different ways a product can be. I do
not -- I don't think that way.
Q. So when you approach your design
functions there at Apple, you make the designs
100 percent completely arbitrary, divorced
entirely from purpose, function, cost or
manufacturability of the devices; is that true?
MR. JACOBS: Objection. Form.
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THE WITNESS: Our purpose is to
make strong, iconic, beautiful products.
We take into account many factors and
trade-offs can be made.
Q. Tell us what factors you take into
account.
MR. JACOBS: In general, Counsel,
or -MR. ZELLER: Yeah.
MR. JACOBS: -- in connection with
a particular product?
MR. ZELLER: In general.
THE WITNESS: We take.
MR. JACOBS: Object to the form.
THE WITNESS: We take into account
what you may use it for, what you may use
it to do, its weight, and each of those
things are very broad, broad topics.
Q. Do you take into account
manufacturability ever?
A. We are constantly inventing ways
to realize our designs.
Q. Have there ever been times when
technical solutions could not be found for a
design that you envisioned there at Apple?
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A. I do not -- I am not able to be
specific about any instance, but I am sure that
at some point, that has occurred.
Q. Why is it for the iPad, the iPad 2
and the iPhones, that Apple chose to put those
products in the common shape of a rectangle?
A. We wanted to produce a very pure
and simple iconic shape that distinguished itself
from everything that had gone before it that had
not been clean, simple, elegant rectangles.
Q. Any other reason?
A. We chose to make instant iconic
statements that could be easily recognizable by
consumers.
Q. So the fact that those products
have display screens is completely unrelated to
the fact that they are in a rectangular shape
generally; is that true?
A. That's true, because the display
screen does not define the outside shape of that
product.
Q. I didn't say defined. I said
completely unrelated altogether. Is that your
testimony?
A. Yes.
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that you've now given for display screen. What's
the shape of them?
A. What's the shape of which? Could
you be specific?
Q. Start with the first one you had,
just go through them in order.
A. The active area is essentially
rectangular.
Q. What about the other display
screen definitions you've given, what shape are
those?
A. The LCD module is predominantly
rectangular but it can have surfaces removed,
notched. There can be mounting tabs. There can
be pockets and recesses, and it can vary in
thickness over the entire area, depending on
where the electronics may be housed, which can
all be manipulated to fit in to a design of any
given shape.
Q. Let's think of display screen in
the sense that a consumer using the iPad and iPad
2 would give to it. What's the shape of that
display screen from a consumer perspective?
MR. JACOBS: Objection. Form.
THE WITNESS: The visual portion
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of the display screen is rectangular.
Q. Is there any relationship at all
between the fact that the active area, the active
screen of the display screen, as you've now
defined it, is rectangular and the fact that the
overall product form is rectangular?
MR. JACOBS: Objection. Vague.
THE WITNESS: No.
Q. And the same is true of the iPhone
as well; is that right?
A. Correct.
Q. Why are the corners of the iPad
and the iPad 2 rounded?
A. It's an aesthetic decision.
Q. Are there any advantages to
consumers to having rounded corners?
MR. JACOBS: Objection. Form.
THE WITNESS: We set out to make a
beautiful, iconic, instantly recognizable
object, and that was our aesthetic
decision.
Q. Are there any functional
advantages or any manufacturing advantages or any
cost manufacturings -- cost advantages of any
kind for having a tablet product that has rounded
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corners?
A. It is disadvantage for the cost of
the tablet to have rounded corners.
Q. You did hear my question, right?
Was something -- was there something unclear
about my question to you?
A. You asked if there were
advantages.
MR. JACOBS: The question was
compound, Counsel, and the witness
properly dissected it. You want to
divide it up, maybe you won't get answers
you're not happy with.
MR. ZELLER: I asked if there were
any functional advantages. You heard
that word, right?
THE WITNESS: I heard that word.
Q. So why did you point out a
disadvantage?
A. Because it is the opposite of
advantage which would indicate that it was not an
advantage.
Q. Let's just start with some simple
questions. Tell me yes or no. Can you think of
a single advantage, functional advantage of any
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kind to having rounded corners for a tablet
computer product?
MR. JACOBS: Objection. Form.
THE WITNESS: Rounded corners is a
generic expression. There are small
rounded corners, there are big rounded
corners. I find it a subjective
question.
Q. So you can't answer that
question. It just doesn't make any sense to you;
is that true?
A. True.
Q. We need to change tapes.
MR. JACOBS: Let's break.
THE VIDEOGRAPHER: This marks the
end of Tape Number 2 in today's
deposition of Christopher Stringer. The
time is 3:02 p.m. and we are off the
record.
(recess taken from 3:02
THE VIDEOGRAPHER: This marks
the beginning of Tape Number 3 of today's
deposition of Christopher Stringer. The
time is 3:15 p.m. and we are on record.
BY MR. ZELLER:
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important?
A. I do not recall any breakdown of
which particular characteristics of a design
would have attracted consumers nor -Q. Whether or not you recall any
breakdown, do you have any knowledge or
information on that subject?
A. You're asking me about specific
portions of a design, so you're asking me for a
specific breakdown. I do not understand the
question any other way.
Q. Do consumers consider it to be
important from a design perspective, an aesthetic
perspective, that the iPhone and the iPad
products are rectangular?
A. No, I've never seen any comment of
that nature.
Q. Do consumers consider it to be
important from an aesthetic or design perspective
that the iPhone and the iPad products have
rounded corners?
A. I do not -MR. JACOBS: Objection. Form.
THE WITNESS: -- have any survey
data of that particular issue.
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of one piece; is that true?
A. We designed something that we
thought was most beautiful as the singular volume
free of complication such that it is a very calm
and attractive object.
Q. Do you have knowledge or
information as to whether any particular elements
or features of the designs of the iPhone or the
iPad products are important to consumers?
A. Could you tell me what you mean by
"features" in this instance?
Q. It's unclear to you?
A. Yes.
Q. Do you know what the word
"element" means?
A. Yes.
Q. That was part of my question, too.
A. Uh-huh.
Q. So do you know what a "design
element" is?
A. I have my understanding of what
that means.
Q. Do you have any knowledge or
information as to whether any particular design
elements of the iPad or the iPhone products are
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Q. So you don't know?
A. When you refer to "rounded," I
imagine a multitude of shapes. You need to be
more specific in what I'm comparing them to.
Q. I'm not comparing it to anything.
I'm asking about the rounded corners that the
iPhone and the iPad products use.
Do you have any information or
information as to whether or not consumers
consider it to be important, from an aesthetic or
design perspective, that those products have
rounded corners?
A. My understanding of what you're
referring to regarding rounded corners is the
front view of the product, whereas a more
sophisticated understanding of design would
interpret the surface, the entirety of the back
form, it is a singular surface.
The fact that we have one surface
that envelopes the entire back of the product and
the size of the product creates a very simple
appearance.
Q. And from your perspective, it's
important to consumers, so far as the design or
the aesthetics of the phone, that those are all
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important to consumers?
A. I know that the complete solution
is attractive to consumers. I do not have
information that breaks down feature by feature,
element by element, to what degree the consumer
responds positively to that product.
Q. You mentioned earlier that Apple
was making to look -- make the designs look calm
and attractive.
Please tell me what that means?
A. We strive towards simplification.
In many instances, that means removing parts,
integrating parts, and generally creating
something that is the least that it can be.
Q. What do you mean by "the least it
can be"?
A. The iPad is essentially two parts,
the housing and the clear glass front, with just
one gap between those two parts, which is quite
unique for a product. It is entirely unique, in
my understanding, of products that previously
existed in this category. That is the kind of
simplicity that I'm referring to.
Q. Anything else?
A. That is the biggest most
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Uh-huh.
Q. And, specifically, it's the front
surface of the first iPhone along with a -- at
least the bezeled portion of it inside profile?
A. That is correct.
Q. Let me show you what was
previously marked as Exhibit 7, which is U.S.
design Patent 618677.
Do you recognize this document?
A. Yes.
Q. What do you recognize this
document as?
A. The first iPhone.
Q. And, specifically, you recognize
this as the front surface of the first iPhone,
and in this view doesn't depict the bezel?
A. Yes.
Q. You'll see that Exhibit 7 has a
list of inventors?
A. Yes.
Q. And if I asked you the same
questions about who participated and contributed
what in terms of the ideas and the designs that
are depicted here in Exhibit 7, you would give me
the same answers?
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constraints or any other constraints that you're
aware of about where a slot for the speaker that
goes to the ear of a phone can be located?
A. If you really think about it, you
could put it pretty much anywhere.
Q. Are there any constraints that you
know, from a technical or commercial viability
perspective, on the placement?
A. It would be more commercial viable
to put it to the left a little.
Q. Why is the shape of the ear piece
hole in a -- with kind of rounded edges?
A. Excuse me? Why?
Q. Why is the shape of this ear piece
hole in a slot shape?
A. It is a slot shape for aesthetic
reasons, and that it's a very simple, calm shape
that allowed us to get an opening over the
location where the receiver is on the product.
Q. What's the purpose of that
opening?
A. There is a need not to occlude the
path of the sound.
Q. It's the hole where people put
their ear up to the phone to hear, right?
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A. I would give you the same answers
of the related question that you asked regarding
the iPad.
Q. In other words, you can't break it
out into a particular person's specific
contribution, right?
A. It is the product of this team.
Q. And the same is true of Exhibit
6. If I were to ask you those questions, you
would give me the same answer?
A. That is correct.
Q. Focusing your attention on Exhibit
6 and 7. You'll see that the speaker slot is
located in a particular position?
A. I see it.
Q. Why was the slot put in that
position?
A. Because it was the most calm and
simple impression that we could create for that
feature on the front face of the product.
Q. Are there any user constraints
that you're aware of concerning the placement of
the speaker slot on the phone?
A. Repeat the question.
Q. Sure. Are there any user
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A. That is correct.
Q. Were there alternative designs
that Apple considered where the ear hole there,
the slot was in places other than the upper half
of the phone?
A. I believe there were some concepts
where the slot was not on the front face, if that
answers your question.
Q. From your perspective, is it
important from a design perspective where this
ear hole slot is placed on a design?
A. From a design perspective?
Q. Yes?
A. From an aesthetic -Q. Right?
A. -- purpose? We found this to be
the most attractive location and -- yeah.
Q. Let me ask you this: Assuming
that the ear hole slot was moved up higher on the
phone, on the front surface of the phone than
what's depicted here near the top, from your
perspective, would that make the design
substantially different or would it still be
substantially the same?
A. Substantially the same.
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but I do recall exhaustive meetings discussing
what form factor we would want of such a device.
Q. And how about the aesthetic
aspects of the device, where did those come from?
A. We, the team that is credited on
the patent documents, all -- actually, I just
went blank and forgot the question.
Q. How were the aesthetic aspects of
the device?
A. Yeah. Those mentioned in the
design team were all active participants in
thrashing through and creating, representing
ideas, either verbally or in sketches or in
whatever way you choose to. There are no rules.
It is a very free-flowing, very creative. The
design team has been together. Essentially, we
have been accumulating designers in the last 18
years. I've been there nearly 16. Many of us,
we have never lost a designer that we truly value
in that period of time. So that the level of
discussion is very free-flowing, very natural,
and very much in tune where we have a very
productive dynamic.
Q. With respect to the iPhone, was
the general process that you've described
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followed?
A. Yes.
Q. And so it's a little nearer in
time, can you describe in general how the iPhone
was designed, the process of design for the
iPhone?
A. The original iPhone or all the
iPhones?
Q. Let's start with the original
iPhone, the one that's reflected in the design
patents that are before us today, the 087 and 677
design patents.
A. How it was designed?
Q. Let me ask a slightly different
question.
A. Can you ask a more specific
question?
Q. You talked about in connection
with the iPad this idea of an oily puddle?
A. Uh-huh.
Q. What -- do you have a similar -do you have a formulation to describe the design
aesthetic or your design goal for the original
iPhone?
A. The iPhone was leveraging that
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idea heavily in that we wanted to have that same
black, mysterious, oily surface that projected
the full extent of the front face of the product
which the magical experience of the display
appearing, and to be able to interact with it.
Also, we wanted to create this strong looking
metal band around the perimeter of the product,
which we call the metal bezel, which is an
uninterrupted surface that extrudes all the way
around the product, and not being affected by any
other features, whether that be IO's, switches or
speaker details, so that we had a very distinct,
clear icon that you could recognize readily from
a good long range indisputably an Apple product.
I think it has to be added that
you may note that our products rely on this
maniacal design process in order to get a strong,
marketable icon that represents a product in an
entirely new way such that we do not even need to
put our brand on the front of the product, which
we do not do on iPods or iPhones or iPads.
MR. JACOBS: I have no further
questions. I do want to note that we
have brought with us, in case you had
wanted to ask, a secure computer with CAD
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designs on it so that the witness could
be asked about CAD designs, and I'm
holding it for the video camera now.
Other than that, I think we are done.
MR. ZELLER: And we obviously
reserve our rights and I think you intend
to leave, if I understand things
correctly.
MR. JACOBS: Off the record.
THE VIDEOGRAPHER: This marks the
end of Tape Number 5 of five and
concludes today's deposition of
Christopher Stringer. The time is
7:04 p.m. and we are off the record.
(Time noted: 7:04 p.m.)
___________________
CHRISTOPHER STRINGER
Subscribed and sworn to before me
This
day of
, 2011.
______________________________________

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CERTIFICATE
STATE OF CALIFORNIA )
)
COUNTY OF SAN FRANCISCO )
I, LINDA VACCAREZZA, a Certified
Shorthand Reporter for the State of
California, do hereby certify:
That CHRISTOPHER STRINGER, the
witness whose deposition is hereinbefore
set forth, was duly sworn by me and that
such deposition is a true record of the
testimony given by such witness.
I further certify that I am not
related to any of the parties to this
action by blood or marriage; and that I
am in no way interested in the outcome of
this matter.
IN WITNESS WHEREOF, I have hereunto
set my hand this 3rd day of
August, 2011.
________________________________
LINDA VACCAREZZA, CSR. NO. 10201

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-------------I N D E X---------------WITNESS
EXAMINATION BY
PAGE
C. STRINGER MS. MOSER
5
--------------EXHIBITS---------------PLAINTIFF'S
PAGE
Exhibit 47
Hand-drawn Sketch...................35
Exhibit 48
Multipaged Document Bates stamped
APLNDC 00014225 through '14228......85
Exhibit 49
Apple Confidential - Need to Know
Vision..............................105
Exhibit 50
Multi-Paged Document of Images of
Smartphones and Computer
Tablets............................236
Exhibit 51
Tablet Device......................251
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EXHIBITS (CONT'D)
Exhibit 52
Tablet Device......................252
Exhibit 53
Color Photocopy of Tablet.........253
Exhibit 54
Color Copy of Tablet Device.......255
Exhibit 55
Color Photocopy of PVD Device.....260
Exhibit 56
HP Device Specification...........267
Exhibit 57
Various Drawing Designs...........268
Exhibit 58
Various Drawing Designs.........283
Exhibit 59
Drawing Design...................288
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EXHIBITS (CONT'D)
Exhibit 60
Screen shot of File Names........306
Exhibit 61
Multi-Page Document bearing Bates
Numbers APLNDC 00014237 through
'14244...........................306
Exhibit 62
Multi-Paged Document bearing Bates
Number APLNDC 0004232 through
14236.............................306

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