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

Filing 1351

Unredacted Claim Construction Brief 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, re (Dkt. No. 1183) (Attachments: # 1 Exhibit 2 to the Schmidt Declaration, # 2 Exhibit 4 to the Schmidt Declaration, # 3 Exhibit 9 to the Schmidt Declaration, # 4 Exhibit 10 to the Schmidt Declaration, # 5 Exhibit 11 to the Schmidt Declaration, # 6 Exhibit 12 to the Schmidt Declaration, # 7 Exhibit 13 to the Schmidt Declaration, # 8 Exhibit 14 to the Schmidt Declaration)(Maroulis, Victoria) (Filed on 7/26/2012) Modified text on 7/27/2012 (dhm, COURT STAFF).

EXHIBIT 11
FILED 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,

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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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H I G H L Y 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 ANDRE BOULE
REDWOOD SHORES, CALIFORNIA
WEDNESDAY, OCTOBER 26, 2011

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BY: ANDREA M. IGNACIO HOWARD, CSR, RPR, CCRR, CLR.
CSR LICENSE NO. 9830
JOB NO. 42861
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structured electronic document on the touch screen

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display, wherein the structured electronic document

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comprises a plurality of boxes of content."

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Do you recall any discussions regarding a
structured electronic document?

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MR. BARTLETT:

conclusion; vague; and asked and answered.

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THE WITNESS:

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MS. DUCCA:

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Objection; calls for a legal

Q

Yes.
Okay.

Which -- what conversations do you recall

regarding structured electronic documents?

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A

We've had many discussions about displaying

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web pages, which is an example of, you know, an

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electronic document comprising a plurality --

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plural -- sorry -- plurality of boxes, so -- yeah, I'm

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not sure which conversations you -- you're referring

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to.

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Q

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document?

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And -- well, what is a structured electronic

MR. BARTLETT:

Objection; calls for a legal

conclusion.
THE WITNESS:

Yeah, I'm not sure how to

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describe it more than, you know, the -- the name kind

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of describes what it is.

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and it's structured.

It's an electronic document,

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MS. DUCCA:
Q

Okay.

Can it include a web page?
MR. BARTLETT:

Objection; calls for a legal

conclusion.
THE WITNESS:

I think a web page is an

example of a structured electronic document, yes.
MS. DUCCA:

Q.

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with images embedded?

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MR. BARTLETT:

How about a Word document

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Same objections; calls for a

legal conclusion.
THE WITNESS:

I'm not familiar with the Word

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document format, but I would presume that, yes, it's a

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structured electronic document.

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MS. DUCCA:

Q.

How about a Word document

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with no images embedded?

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electronic document?

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MR. BARTLETT:

Is that a structured

Objection; calls for a legal

conclusion.
THE WITNESS:

I wouldn't make a distinction

between with or without images.
MS. DUCCA:

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or an eBook?

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Q.

What about an electronic book

document?

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Is that a structured electronic

MR. BARTLETT:

Objection; calls for a legal

conclusion.
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THE WITNESS:

As far as my understanding,

yes.

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MS. DUCCA:

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MR. BARTLETT:

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Q.

How about a JPEG, an image?
Objection; calls for a legal

conclusion.

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THE WITNESS:

Well, that -- that might be a

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little bit more difficult to -- to answer.

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it depends on -- it depends on what you mean by

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"structured electronic document."

But again,

There -- there

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could be different possible interpretations, and that

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could be one.

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MS. DUCCA:

MR. BARTLETT:

Objection; vague; calls for a

legal conclusion.

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Now, you didn't invent a

structured electronic document; did you?

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Q.

THE WITNESS:

Which specific structured

electronic document are you referring to?

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MS. DUCCA:

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document.

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Q

Just a structured electronic

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Did you ever -- did you invent a structured

electronic document?
MR. BARTLETT:

Objection; vague; calls for a

legal conclusion.
THE WITNESS:

I probably have over the course

of my career.
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CERTIFICATE OF REPORTER

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I, ANDREA M. IGNACIO HOWARD, hereby certify

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that the witness in the foregoing deposition was by me

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duly sworn to tell the truth, the whole truth, and

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nothing but the truth in the within-entitled cause;

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That said deposition was taken in shorthand

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by me, a Certified Shorthand Reporter of the State of

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California, and was thereafter transcribed into

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typewriting, and that the foregoing transcript

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constitutes a full, true and correct report of said

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deposition and of the proceedings which took place;

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That I am a disinterested person to the said
action.

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IN WITNESS WHEREOF, I have hereunto set my
hand this 26th day of October, 2011.

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_______________________________________
ANDREA M. IGNACIO HOWARD, RPR, CCRR, CLR, CSR No. 9830

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