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

Filing 1350

UNREDACTED NOTICE OF MOTIONS AND MOTIONS in Limine by Samsung Electronics America, Inc.(a New York corporation), Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC(a Delaware limited liability company) re 1256 Order on Administrative Motion to File Under Seal, (Attachments: # 1 Exhibit C to the D'Amato Declaration, # 2 Exhibit E to the D'Amato Declaration, # 3 Exhibit G to the D'Amato Declaration, # 4 Exhibit H to the D'Amato Declaration, # 5 Exhibit J to the D'Amato Declaration, # 6 Exhibit K to the D'Amato Declaration, # 7 Exhibit L to the D'Amato Declaration, # 8 Exhibit M to the D'Amato Declaration, # 9 Exhibit N to the D'Amato Declaration, # 10 Exhibit T to the D'Amato Declaration, # 11 Exhibit V to the D'Amato Declaration, # 12 Exhibit W to the D'Amato Declaration)(Maroulis, Victoria) (Filed on 7/26/2012) Modified text on 7/27/2012 (dhm, COURT STAFF).

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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,
)
)
vs.
)No. 11-CV-01846-LHK
)
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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BE IT REMEMBERED, that on Wednesday,
February 22, 2012, commencing at the hour of 9:12
a.m. thereof, at the offices of Morrison & Foerster,
755 Page Mill Road, Palo Alto, California, before
me, Judie A. Nicholas, a Certified Shorthand
Reporter of the State of California, there
personally appeared.
TIMOTHY BENNER,
called as a witness by the Plaintiff, who, being by
me first duly sworn, was thereupon examined and
testified as hereinafter set forth.

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firm represents Apple, Inc.

2

MS. CARUSO:

09:12

Margret Caruso of Quinn

3

Emanuel Urquhart & Sullivan.

4

09:12

Yang from Samsung.

With me is Michelle

09:12

5

THE VIDEOGRAPHER:

6

Would the reporter please swear in the

7

09:12

Thank you.

09:12

witness.

09:12
09:12

8

TIMOTHY BENNER,

09:12

9

being first duly sworn,

09:12

was deposed and testified as follows:

09:12

10
11

THE VIDEOGRAPHER:

12

MR. ROBINSON:

09:12

Good morning, Mr. Benner.

Thank you for being here.

15
16

09:12

EXAMINATION BY MR. ROBINSON

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14

Thank you.

09:12
09:12

Could you please state your full name for

09:12

the record.

09:12

17

A.

Timothy John Benner.

09:12

18

Q.

Have you ever been deposed before?

09:12

19

A.

I have not.

09:12

20

Q.

So the procedures are -- it's fairly

09:12

21

simple, but I just want to review a few of the

09:12

22

rules.

09:12

23

The court reporter here is taking down

24

everything that we say.

25

quickly, in which case she might grumble a little

I might speak a little

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THE WITNESS:

The question I think you're

12:17

2

asking is, is there more than one.

3

survey.

4

Q.

There's one tracking survey?
?

12:17

5

A.

That I conduct.

12:17

6

Q.

Thank you.

12:17

And how does that tracking survey work?

12:17

7
8

There's one

12:17
12:17

You said it tracks across time; is that right?
?

12:17

9

A.

Yes.

12:17

10

Q.

Is it the same study that is administered

12:17

11

at different points in time?
?

12

MS. CARUSO:

13

THE WITNESS:

Objection:

12:17
Vague.

12:17

The survey itself is

12:17

14

modular.

15

across time and then there are pieces that come and

12:18

16

go as we look at different communication and the

12:18

17

effectiveness of that communication.

12:18

18

There are elements that are consistent

It's primarily brand focused, but it's

12:18

12:18

19

also looking at monitoring communications, so our

12:18

20

different ads and some competitive ads --

12:18

21

MR. CARUSO:

Mr. Robinson, before you go

12:18

22

on to another topic, I've had this Pavlovian

12:18

23

response since your client announced lunch.

12:18

24
25

MR. ROBINSON:

Oh, I'm so sorry, I

12:18

completely forgot.

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Let's take a break for lunch.

12:18

2

THE VIDEOGRAPHER:

12:18

3

and we're off record.

4

12:18

(A lunch break was taken.)

01:23

AFTERNOON SESSION

01:23

5
6
7

The time is 12:18 p.m.,

THE VIDEOGRAPHER:

The time is 1:24 p.m.

and we are back on the record.

01:23
01:23

8

(Exhibits 1603 marked

01:23

9

for identification.)

01:23

10

FURTHER EXAMINATION BY MR. ROBINSON

01:23

11

MR. ROBINSON:

Mr. Benner, we're back.

01:23

12

Before the break we were talking about the

01:23

13

Q.

tracking studies.
studies.

14

01:24

I'm going to hand what you has been

01:24

15

premarked as Exhibit 1603.

16

Samsung Q1 '11 Deep Dive, Continuous Tracking, with
Tracking

01:24

17

Bates stamp SAMNDCA00352115 through 352182.

01:24

18

This is entitled

01:24

Do you recognize Exhibit 1603?

01:24

19

A.

Yes.

01:24

20

Q.

Is that your name on the bottom of the

01:24

21

first page where it says "Owner"?

01:24

22

A.

Yes.

01:24

23

Q.

What does that mean?

01:24

24

A.

That means I am the designated "Owner" of

01:24

25

this document in terms of whose responsibility it

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is to, you know, produce it.

2
3

Q.

01:25

Is this one of the tracking studies that

you referred to earlier in your testimony today?

01:25
01:25

4

A.

Yes, it is.

01:25

5

Q.

Is Exhibit 1603 a true and correct copy of

01:25

6

an STA tracking study?
study

01:25

7

A.

To the best of my knowledge, yes.

01:25

8

Q.

Does STA prepare these tracking studies?
studies

01:25

MS. CARUSO:

01:25

9
10
11

THE WITNESS:

Objection:

Vague.

These studies are prepared

by an outside vendor under my supervision.
supervision

12

MR. ROBINSON:

13

A.

01:25

What is the outside

vendor?

14

Q.

15

Q.

01:25
01:25

The outside vendor's name is Hall &

01:25

Partners.

16

01:25

01:25

How often does STA receive a deliverable

01:25

17

from Hall & Partners in the form of one of these

01:25

18

tracking surveys?
?

01:25

19

MS. CARUSO:

20

THE WITNESS:

21

MR. ROBINSON:

01:25

These tracking surveys are

A.

01:25
01:25

Q.

And by "these," are you

referring to the Deep Dive?
?

24
25

Vague.

every quarter.
quarter.

22
23

Objection:

01:25

I am referring to the Deep Dive document,
,

yes.

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2

Q.

by Hall & Partners -- sorry.

3
4

Are there other tracking studies provided
t
prov
r vided
Strike that.

01:26

Are there other tracking surveys other
than the Deep Dive Surveys that STA receives?
receives

5

MS. CARUSO:

6

THE WITNESS:

Objection:

01:26

01:26
01:26

Vague.

01:26

Technically this is not a

01:26

7

survey, this is a report.

8

is done continuously and there are multiple

01:26

9

reports.

01:26

10
11

MR. ROBINSON:

Q.

There is one survey that

Thank you for that

01:26

clarification.

12

01:26

01:26

Is the Deep Dive Report the -- are there

01:26

13

other reports besides the Deep Dive Report that STA

01:26

14

receives in connection with this continuous

01:26

15

tracking?
ng

01:26

16

A.

Yes.

01:26

17

Q.

What are those?

01:26

18

A.

We get weekly reports that are Topline KPI

01:26

19

studies -- not studies, but reports/monitoring, and

01:26

20

anything else on a request basis that we would like

01:26

21

from the data within the reports, or within the

01:27

22

survey.

01:27

23

Q.

24
25

You referred to Topline KPA.
o
KPA

What does

KPA stand for?
for
for?
A.

01:27

KPI.

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Q.

Sorry, KPI?

01:27

2

A.

Key Performance Index.

01:27

3

Q.

And you mentioned that you receive weekly

01:27

4

reports.

5

01:27
Do the Deep Dive reports contain the

01:27

6

information that you would receive in the weekly

01:27

7

reports?

01:27

8
9
10
11

A.

Yes.

They are basically -- the data

01:27

that's given on a weekly basis is

01:27

contained/summarized in these reports.
reports.

01:27

Q.

You also mentioned that you receive other

01:27

12

reports on request.

13

an example?
?

01:27

A.

01:27

14

Can you name a few of those,
,

Typically they're not reports, they're

01:27

15

just looking at a particular data cut, usually in

01:27

16

response to a question from out of this document.

01:27

17
18

Q.

Can you think -- are they named anything

in particular?

01:28

19

A.

No.

20

Q.

Are they large documents, or like one,

21

01:27

They're usually just data.

01:28

two-page things?

01:28
01:28

22

A.

Sometimes it's two sentences.
sentences.

01:28

23

Q.

How much does STA pay to receive the Deep
e

01:28

24
25

Dive reports from Hall & Partners?
?
A.

01:28

The cost has changed over time.

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THE WITNESS:

It's just a highlight of

01:43

2

those particular elements or those personalities to

01:43

3

draw attention to it.

01:43

4
5

MR. ROBINSON:

Q.

Do you see where it

01:43

says "Significant drivers of MPSA for Samsung"?
Samsung"
"?

01:43

6

A.

Yes.

01:43

7

Q.

What does MPSA refer to?
to

01:44

8

A.

It's an acronym which we use for one of

01:44

9
10
11
12
13

KP -- key performance indexes which stands for most

01:44

preferred single answer.

01:44

Q.

And what does that mean, in just sort of

01:44

survey terms?

01:44

A.

01:44

In English, it means the answer to the

14

question.

15

the bottom of the page.

The question is actually in the text at

01:44
01:44

16

Q.

I see?

01:44

17

A.

Now we'd like you to -- it's not,

01:44

18

actually.

19
20

I'll find it.

23
24
25

It's here.

It's the answer

to a specific question.
question.

21
22

01:44

01:44

"Among all of the mobile phone brands that
you aware of, which brand do you prefer the most."
Q.

What's the Bates number of the page you

just read from?
A.

01:44
01:44
01:44
01:44

It is page number 7, SAMNDCA00352121.

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Q.

Thank you.
Why does STA consider the items shown in

2

01:45
01:45

3

the blue box on page 12 that we were looking at

01:45

4

previously to be significant drivers of MPSA for
y

01:45

5

Samsung?

01:45

6

A.

That's slightly misleading in what it

01:45

They're significantly associated with the

01:45

7

says.

8

personality characteristics that are most

01:45

9

correlated to most preferred single answer.

01:45

10
11
12

Does that make sense?
Q.

01:45

Could you maybe say that in more regular

01:45

terms?

01:45

13

MS. CARUSO:

14

THE WITNESS:

15

a lot of statistical analysis.

01:45

MR. ROBINSON:

Sure.

01:45

That basically says that these personality

01:45

16
17

A.

Objection.

01:45

I don't know if I can.

Q.

It's

01:45

18

indices co-vary with MPSA.

19

relationship, it just means they're correlated,
,

01:46

20

they seem to move together.

01:46

21

Q.

01:46

I see.

01:46

Could I have you turn please to page 26 of

22
23

There's no causal

01:46

this report Bates SAMNDCA00352140.

01:46

24

A.

352140.

01:46

25

Q.

352140?

01:46

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A.

Okay.

01:46

2

Q.

Down at the bottom it looks like the

01:47

3

question being asked was, "Have you seen this

01:47

4

advertising on television in the past 7 to 5 days,"

01:47

5

do you see that?

01:47

6

A.

Yes.

01:47

7

Q.

Is that the question?

01:47

8

A.

It's actually 5 to 7 days.
days.

01:47

9

Q.

Oh, I'm sorry, 5 to 7 days.
days.

01:47

And then above the charts we see a legend

01:47

10
11

with a blue box and an A next to it, and it
,

01:47

12

attributed back to Samsung/Galaxy/Tab; below that
;

01:47

13

the letter B with a green box saying attributed

01:47

14

back to Apple/iPad/iPhone, and underneath there are
,

01:47

15

various charts.

01:47

16

Focusing on the chart above the

01:47

17

Samsung/Galaxy/Tab,
Samsung/Galaxy/Tab, what is being depicted in that

01:47

18

chart?

01:47

19

A.

This is the -- during the period of the

01:47

20

survey, looking AT consumers who recognized still

01:47

21

photos of the particular Samsung Galaxy Tab ad

01:48

22

which is in the bottom here, so they're presented a

01:48

23

photo which shows basically stills of the different

01:48

24

ads and they're asked if they recognize it or not.

01:48

25

If they say yes, they're asked, "Do you

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remember what brand this was for," and then it says

01:48

2

that 18 percent said it was for either Samsung,

01:48

3

Galaxy or Tab and 46 percent said Apple, iPad or

01:48

4

iPhone.

01:48

5

Q.

6

And that's a significant difference at the

95 percent confidence level, right?
level

01:48
01:48

7

A.

Correct.

01:48

8

Q.

What this is saying is essentially nearly
y

01:48

9

half of those who saw the still photo of the

01:48

10

Samsung Galaxy Tab thought they were actually

01:48

11

looking at an Apple advertisement?

01:48

12

They were not

01:48

13

looking at a photo of the Galaxy Tab, they were

01:48

14

looking at a photo which showed six different

01:48

15

scenes of the communication, the advertisement for

01:49

16

the Galaxy Tab.

01:49

17

different images.

18
19
20
21
22

A.

Q.

No, that's not correct.

01:49

Those who saw -- is it at photo array what

they see?
A.

Not all of them had product in the

What do they see?

01:49

They see six different images of different

scenes within the advertisement.
advertisement.
Q.

01:49

01:49
01:49

And, looking at that display, then nearly

01:49

23

half of those responded to this survey question

01:49

24

saying that they thought what they were seeing was

01:49

25

an Apple advertisement; is that right?
;

01:49

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A.

What they were looking at -- they were not

01:49

2

looking at the display at this point.

They're

01:49

3

relying on the recall of the advertisement and

01:49

4

saying they thought that the advertisement in

01:49

5

question was either an Apple iPad or iPhone

01:49

6

advertisement.

01:49

7

Q.

So, yes, in response to this prompt then,

01:49

8

looking at -- having looked at the display of the

01:50

9

Samsung Galaxy Tab still photo advertisement

01:50

10

images, nearly half of the respondents said they

01:50

11

thought they had seen an Apple advertisement?

01:50

12
13

A.

What they thought, they said, was it was

an advertisement for the Apple brand.

14

01:50
01:50

In this case, this was done at a time when

01:50

15

the Galaxy Tab had just been introduced and the

01:50

16

iPad had been in the market for some time, and this

01:50

17

is -- the sample that we're looking at here is a

01:50

18

smaller sample, so there is more variation in

01:50

19

there.

01:50

20

Q.

What was the sample size?

01:50

21

A.

For the people who recognized the

01:50

22
23

Galaxy -- the Samsung Tab ad, 448.
Q.

01:50

But this result shows, does it not, that

01:51

24

the misattribution back to Apple was significant at

01:51

25

the 95 percent confidence level, right?
level

01:51

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A.

Yes.

01:51

2

Q.

Did STA consider it a problem that the
t

01:51

3

Galaxy Tab advertisement was being misattributed to

01:51

4

Apple?

01:51

5

A.

The -- as the statement here says, the

01:51

6

linkage to Samsung has improved, but the Galaxy Tab

01:51

7

execution -- misattribution was declined -- I'm

01:51

8

sorry, this is looking at Galaxy 2.

01:51

9

can't say strike that.

10

Strike -- I

01:51

But, yes, we considered it a problem

01:51

11

because this communication should have been for the

01:51

12

Galaxy Tab.

01:51

13

attributed correctly to Samsung.

14

Q.

However, the execution was not being

01:51

What did STA do, if anything, about the

01:51

15

misattribution that was occurring between the

01:52

16

Galaxy Tab and the Apple iPad?

01:52

17
18
19

MS. CARUSO:

Objection:

Beyond the scope;

lacks foundation.
THE WITNESS:

01:52
01:52

In this case, this was --

01:52

20

Samsung was breaking into the tablet market which

01:52

21

was firmly established for a period of time by

01:52

22

Apple being the only product available.

01:52

23

remember exactly how many months that, basically,

01:52

24

stronghold held.

01:52

25

I can't

For the Galaxy, the first Galaxy Tab ad

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there was a great deal of misattribution.

2

second Galaxy Tab ad, that misattribution dropped

01:52

3

as awareness of Samsung's Tabs grew, so looking

01:52

4

back and improving the communication to make sure

01:52

5

that it was distinctive from Apple and identifiable

01:52

6

as Samsung.

01:52

Q.

01:52

7

For the

Didn't the advertising change as well --

01:52

8

the style of the advertising change as between the

01:53

9

Galaxy Tab and Galaxy Tab 2, right?

01:53

10
11
12
13
14

MS. CARUSO:

Objection:

Assumes facts not

in evidence; vague.

01:53

THE WITNESS:

01:53
Can you specify more exactly

what you're asking?

01:53

MR. ROBINSON:

01:53
Q.

The misattribution that

01:53

15

occurred between the Samsung Galaxy Tab

01:53

16

advertisement and I guess misattributed to Apple,
,

01:53

17

that was because the advertisements were confusing,
,

01:53

18

they were similar, the Samsung advertisements and
,

01:53

19

Apple advertisements?

01:53

20

MS. CARUSO:

Objection:

Calls for a legal

01:53

21

conclusion; mischaracterizes the record; assumes

01:53

22

facts not in evidence; vague.

01:53

THE WITNESS:

01:53

23

I take issue with your

24

statement of it's confusing, the way it was said

01:53

25

similarly confusing.

01:53

The issue wasn't that it was

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confusing, the issue was that the iPad had been

01:53

2

very firmly established in the marketplace, and so

01:53

3

when people saw an ad on TV that had a large

01:53

4

tablet-like display, the immediate reaction is it

01:54

5

must be an iPad.

01:54

6

This is at a time when -- breaking into

01:54

7

the market, so it's actually not unexpected to see

01:54

8

that, because very few people that Samsung was

01:54

9

making these products, and growing that awareness,
,

01:54

10

changing from one to the next, is the natural

01:54

11

progression of trying to break in and make people

01:54

12

become more aware of Samsung as a tablet

01:54

13

manufacturer.

01:54

Q.

01:54

14

Does STA disagree that the misattribution

15

occurred because the Galaxy Tab looked similar to

01:54

16

the Apple iPad?

01:54

17
18

MS. CARUSO:

21
22
23

Beyond the scope;

lacks foundation.

19
20

Objection:

THE WITNESS:

01:54
01:54

I'm sorry, could you say it

again?

01:54
01:54

MR. ROBINSON:

Q.

Could we have that

01:54

question read back, please.
THE REPORTER:

Question:

01:54
"Does STA

01:54

24

disagree that the misattribution occurred because

01:54

25

the Galaxy Tab looked similar to the Apple iPad?"
iPad?
?"

01:54

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MS. CARUSO:

Objection:

Beyond the scope;

lacks foundation; mischaracterizes the record.

3

THE WITNESS:

01:55
01:55

Could you rephrase the

01:55

4

question.

5

The negative phrasing of the question is throwing

01:55

6

me off.

I'm not sure what you're asking.

01:55

MR. ROBINSON:

01:55

7
8

I'm confused by the "Does STA disagree."

Q.

Do you agree that the

Galaxy Tab looks similar to the Apple iPad?

01:55

01:55

9

A.

In this case, this Galaxy Tab does not.

01:55

10

Q.

Why is that?

01:55

11

A.

It's half the size.

01:55

12

(Exhibit No. 1604-1613

13
14

01:55

marked for identification.)
Q.

I think -- I want to show you a bunch of

15

other documents.

16

questions about them.

17

I'm not going to ask you detailed

01:55
01:55
01:55
01:55

What I'm going to ask is do you recognize

01:55

18

this documents, do they have your name on them, and

01:55

19

are they true and correct copies of the documents

01:56

20

that they are.

01:56

21

Exhibits 1604 through 1613, and I'll place this

01:56

22

enormous stack in front of you, and -- counsel,

01:56

23

here's your copy.

01:56

24

this in two phases if we wanted to go through it

01:56

25

more quickly.

01:56

They have been premarked as

And I think we can probably take

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MS. CARUSO:

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8
9
10

It would be the strategy

group.

02:34
02:34

MR. ROBINSON:

Q.

Who is involved with

the strategy group?
A.

02:34
02:34

As mentioned earlier, Justin Denison and

his team.
Q.

02:34
02:34

THE WITNESS:

5
6

Lacks foundation;

calls for speculation.

3
4

Objection:

02:34
02:34

Thank you.

02:34

I have no further questions at this time,

02:34

11

subject to the same reservations and the same

02:34

12

objection by counsel --

02:34

13
14
15

MS. CARUSO:

Yes.

This time we're getting

out of here.

02:34
02:34

THE VIDEOGRAPHER:

This marks the end of

02:34

16

Disk Number 2 of 2, and concludes today's

02:34

17

deposition of Timothy Benner.

02:34

18

2:35 p.m., and we are off the record.

19
20
21

The time is

02:34

(The deposition adjourned
at 2:35 p.m.)
--oOo--

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Signed under penalty of perjury:

24

__________________________

25

Timothy Benner

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