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 12
FILED UNDER SEAL

HIGHLY 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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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 RICHARD WILLIAMSON
REDWOOD SHORES, CALIFORNIA
FRIDAY, OCTOBER 28, 2011

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BY: ANDREA M. IGNACIO HOWARD, CSR, RPR, CCRR, CLR
CSR LICENSE NO. 9830
JOB NO. 42876
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Q

Do you have an engineering -- do you have any

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independent knowledge of what a structured electronic

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document is?

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A

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MR. BARQUIST:

THE WITNESS:
language.

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Objection; vague and

ambiguous; calls for a legal conclusion.

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Yes.

I will not interpret the legal

I can tell you about the engineering work.

MR. MACK:

Okay.

I'm not asking for the

legal interpretation.
Q

Just do you have -- have you heard the term

structured electronic document used at Apple before?
A

I can tell you about the way we talk about

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structured documents from an engineering perspective

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and what a structured document is.

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Q

Okay.

My question was, though, have you

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heard the term structured electronic document at Apple

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before?

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MR. BARQUIST:

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Other than in connection with meetings with

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Objection.

counsel, you may answer it.

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MR. MACK:

Q.

I mean, in your work as an

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engineer, have you ever heard of the term structured

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electronic document?

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A

I use the term structured document a lot,
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especially as it relates to the double tap technology

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that we have.

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Q

Okay.

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A

A structured document is something that has a

And what is a structured document?

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visual structure with structurally interesting

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components.

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structured document, whether it be a .pdf document

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with an imposed structure or whether it be a web page

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with a structure or an .rtf document.

And there are many examples of a

So a structured

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document is something that, you know, a normal human

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can look at and identify areas of interest.

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Q

Okay.

So would it be safe to say a

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structured document has some sort of layout associated

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with it; is that fair?

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MR. BARQUIST:

Objection; vague and

ambiguous.

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THE WITNESS:

I'm not sure.

I mean, that's

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different than the definition I just gave you.

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you know, I think of a structured document more in

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terms of its visual appearance and having visually

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interesting elements that you can zoom in to.

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MR. MACK:
Q

So,

Okay.

So would a -- would a plain text document be

a structured document?
MR. BARQUIST:

Objection; incomplete

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hypothetical; calls for a legal conclusion.

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THE WITNESS:

To the extent that that's a --

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you know, trying to impose a legal question to me, I'm

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not sure I'm qualified to answer that.

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MR. MACK:

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legal definition.

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Q

Like, would you consider a text document a

structured document from the definition you just gave?

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MR. BARQUIST:

Objection; vague and

ambiguous; incomplete hypothetical.

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Yeah, but I'm not asking for the

THE WITNESS:

What kind of text document?

I

mean, you need to be more specific.

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MR. MACK:

Just a -- you know, not a rich

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format; just a regular form -- regular text document,

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a .txt file that you're displaying on a screen.

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Q

Would that -- would you consider that a

structured document?

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MR. BARQUIST:

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vague and ambiguous.

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THE WITNESS:

Objection; lacks foundation;

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context.

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I mean, it all depends on the

MR. MACK:
Q

Okay.

But you gave examples of a web -- you gave

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examples of some structured documents; correct?

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And you said a web page is a structured
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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 28th day of October 2011.

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

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