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

Filing 1349

Declaration of Jason R. Bartlett in Support of 1348 OBJECTIONS TO SAMSUNG'S SUBMISSION IDENTIFYING ATTORNEYS' FEES AND COSTS PURSUANT TO THE COURT'S JULY 11, 2012 ORDER filed by Apple Inc.. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5)(Related document(s) 1348 ) (Jacobs, Michael) (Filed on 7/25/2012) Modified text on 7/27/2012 (dhm, COURT STAFF).

Exhibit 4

In The Matter Of:
Apple Inc. v.
SamSung Electronics Co., Ltd., et al.

Saku Hieta
July 13, 2012

Behmke Reporting and Video Services, Inc.
160 Spear Street, Suite 300
San Francisco, California 94105
[phone]

Original File 20242Hieta.txt

Min-U-Script® with Word Index

Saku Hieta
July 13, 2012

Apple Inc. v.
SamSung Electronics Co., Ltd., et al.
Page 1

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION

- - - - - - - - - - - - - - - - - - - APPLE INC., a California corporation,

)

Plaintiffs,
vs.

)
)

CASE NO.

11-CV-01846-LHK

SAMSUNG ELECTRONICS CO., LTD., et al.

)

- - - - - - - - - - - - - - - - - - - -

HIGHLY CONFIDENTIAL - OUTSIDE ATTORNEYS' EYES ONLY

VIDEOTAPED DEPOSITION OF
SAKU HIETA
FRIDAY, JULY 13, 2012

BEHMKE REPORTING AND VIDEO SERVICES, INC.
BY: CHRISTINE A. TRISKA, CSR NO. 12826, RPR
160 SPEAR STREET, SUITE 300
SAN FRANCISCO, CALIFORNIA 94105
[phone]

Page 3

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

APPEARANCES OF COUNSEL:
FOR PLAINTIFF:
WILMER, CUTLER, PICKERING, HALE
AND DORR LLP
BY: MARK D. SELWYN, ATTORNEY AT LAW
950 Page Mill Road
Palo ALto, CA 94304
Telephone: [phone]
Fax: [phone]
Email: [e-mail]

FOR THE DEFENDANTS:
QUINN, EMANUEL, URQUHART, OLIVER
AND HEDGES, LLP
BY:

ERIC E. WALL, ATTORNEY AT LAW

50 California Street, 22nd Floor
San Francisco, CA 94111
Telephone: [phone]
Fax: [phone]
Email: [e-mail]

ALSO PRESENT:
CYNDI WHEELER, IN-HOUSE COUNSEL, APPLE
BRIAN MONROE, CLVS

Page 2

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

Videotaped Deposition of SAKU HIETA, taken on behalf

of DEFENDANTS, at the Law Offices of Quinn Emanuel, 555
Twin Dolphin Drive, Redwood Shores, California, commencing

at 7:25 A.M., FRIDAY, JULY 13, 2012, before Christine A.
Triska, Certified Shorthand Reporter No. 12826, pursuant

to Notice.

Min-U-Script®

Page 4

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

I N D E X
FRIDAY, JULY 13, 2012
SAKU HIETA

PAGE

Examination by MR. WALL

7, 27

Examination by MR. SELWYN

27

-O0O-

QUESTIONS WITNESS INSTRUCTED NOT TO ANSWER:

BEHMKE REPORTING AND VIDEO SERVICES, INC.
[phone]

PAGE

LINE

NONE

(1) Pages 1 - 4

Saku Hieta
July 13, 2012

Apple Inc. v.
SamSung Electronics Co., Ltd., et al.
Page 5

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

EXHIBITS
SAKU HIETA
Number

Description

Exhibit 1

Page

Declaration of Saku Hieta
Submitted Under Seal
- 11 pages

Exhibit 2

6

Step-In License Agreement by
Apple, Infineon Technologies
Delta GmbH and Infineon North
America
- 5 pages

21

Page 7

1 behalf of Apple and the witness. With me today is Cyndi
2 Wheeler of Apple.
3
THE VIDEOGRAPHER: And the court reporter
4 today is Christine Triska, Certified Shorthand Reporter,
5 contracted by Behmke Reporting and Video Services, Inc.
6
Would the court reporter now please swear in
7 the witness?
8
9
SAKU HIETA,
10
after having been first duly
11
sworn, testified as follows:
12
THE WITNESS: I do.
13
14
VIDEOTAPE OPERATOR: You may begin.
15
16
EXAMINATION
17 BY MR. WALL:
18
Q Good morning.
19
A Good morning.
20
Q Can you please state your full name for the
21 record?
22
A My full name is Saku Pietari Hieta.
23
Q What is your home address?
24
A It's 12433 Brooklyn Drive in Saratoga,
25 California.

Page 6

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

FRIDAY, JULY 13, 2012; 7:25 A.M.
...
(Deposition Exhibit 1
was marked for identification.)
THE VIDEOGRAPHER: Here marks the beginning
of DVD Number One in the deposition of Saku Hieta in the
matter of Apple, Incorporated versus Samsung Electronics
Company Limited in the United States District Court for

the Northern District of California, San Jose Division.
Case number is 11-CV-01846-LHK. Today's date
is July 13, 2012, and the time on the video monitor is
7:25 a.m.
The video operator today is Bryan Monroe
employed by Behmke Reporting and VIDEO SERVICES, INC. at

160 Spear Street, Suite 300 in San Francisco,
California.
This video deposition is taking place at 555
Twin Dolphin Drive in Redwood Shores, California and was

noticed of Eric Wall, Esquire, of Quinn Emanuel LLP.
Counsel, would you please voice identify
yourselves for the record?
MR. WALL: Eric Wall of Quinn Emanuel for
Samsung.
MR. SELWYN: Mark Selwyn from Wilmer Hale on

Min-U-Script®

Page 8

1
Q What is your business address?
2
A Business address would be One Infinite Loop in
3 Cupertino, California.
4
Q Do you understand that you are testifying
5 under oath today subject to the penalty of perjury, same
6 as in a court?
7
A I do.
8
Q Is there any reason you can't give your best
9 testimony today?
10
A No.
11
Q I'd like to show you what's been marked as
12 Exhibit One.
13
A Okay.
14
Q Can you please Identify Exhibit One?
15
MR. SELWYN: Do you have one more copy?
16
MR. WALL: Sorry.
17
(Whereupon, counsel hands
18
the document to Mr. Selwyn.)
19
MR. SELWYN: Thanks.
20
THE WITNESS: Okay.
21 BY MR. WALL:
22
Q What is Exhibit Number One?
23
A This is the declaration I gave in January
24 regarding this matter.
25
Q And is that your signature on the third page

BEHMKE REPORTING AND VIDEO SERVICES, INC.
[phone]

(2) Pages 5 - 8

Saku Hieta
July 13, 2012

Apple Inc. v.
SamSung Electronics Co., Ltd., et al.
Page 29

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SOW pertaining to the PMB 9801 chip set?
A No. That was also preexisting.
Q I take it you have no information regarding
the negotiation of that agreement; correct?
A Correct.
MR. WALL: No further questions.
MR. SELWYN: I have no further questions.
Apple designates the entirety of the transcript "Highly
Confidential - Outside Attorneys' Eyes Only" pursuant to

the protective order. I thank the witness. Your
deposition is concluded.
THE VIDEOGRAPHER: Okay. This concludes the
deposition of Saku Hieta. The total number of DVDs we
used today was one, and the original will be retained by
Behmke Reporting and VIDEO SERVICES, INC. at 160 Spear

Street, Suite 300, in San Francisco, California
California.
We are going off the record. The time on the
video monitor is 8:07 a.m.
(At 8:07 A.M., the deposition
proceedings concluded.)

_______________________________
SAKU HIETA
Page 30

1 STATE OF CALIFORNIA
)
2
)
ss.
3 COUNTY OF SANTA CLARA
)
4
5
I hereby certify that the witness in the
6 foregoing deposition, SAKU HIETA, was by me duly sworn to
7 testify to the truth, the whole truth, and nothing but the
8 truth, in the within-entitled cause; that said deposition
9 was taken at the time and place herein named; that the
10 deposition is a true record of the witness's testimony as
11 reported by me, a duly certified shorthand reporter and a
12 disinterested person, and was thereafter transcribed into
13 typewriting by computer.
14
I further certify that I am not interested in
15 the outcome of the said action, nor connected with, nor
16 related to any of the parties in said action, nor to
17 their respective counsel.
18
IN WITNESS WHEREOF, I have hereunto set my
19 hand this 13th day of July, 2012
20
21
22
23
_________________________________
24
CHRISTINE A. TRISKA, CSR NO. 12826
25
STATE OF CALIFORNIA

Min-U-Script®

BEHMKE REPORTING AND VIDEO SERVICES, INC.
[phone]

(8) Pages 29 - 30