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

Filing 1358

Unredacted Opening Supplemental Claim Construction Brief re 1256 Order on Administrative Motion to File Under Seal,re (Dkt. No. 1186 by Apple Inc.. (Attachments: # 1 Declaration of Ravin Balakrishnan, Ph.D., # 2 Exhibit 6 to Balakrishnan Declaration)(Jacobs, Michael) (Filed on 7/26/2012) Modified text on 7/27/2012 (dhm, COURT STAFF).

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HAROLD J. MCELHINNY (CA SBN 66781)
[e-mail]
MICHAEL A. JACOBS (CA SBN 111664)
[e-mail]
RICHARD S.J. HUNG (CA SBN 197425)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff and
Counterclaim-Defendant APPLE INC

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WILLIAM F. LEE
[e-mail]
WILMER CUTLER PICKERING
HALE AND DORR LLP
60 State Street
Boston, MA 02109
Telephone: [phone]
Facsimile: [phone]
MARK D. SELWYN (SBN 244180)
[e-mail]
WILMER CUTLER PICKERING
HALE AND DORR LLP
950 Page Mill Road
Palo Alto, California 94304
Telephone: [phone]
Facsimile: [phone]

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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APPLE INC., a California corporation,

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Plaintiff,
v.
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,

Case No. 11-cv-01846-LHK (PSG)
DECLARATION OF RAVIN
BALAKRISHNAN, PH.D., IN
SUPPORT OF APPLE’S OPENING
SUPPLEMENTAL CLAIM
CONSTRUCTION BRIEF

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Defendants.
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SUBMITTED UNDER SEAL

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DECL. OF RAVIN BALAKRISHNAN, PH.D. ISO APPLE’S OPENING SUPPLEMENTAL CLAIM CONSTRUCTION BRIEF
CASE NO. 11-cv-01846-LHK (PSG)
sf-3166749

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I, Ravin Balakrishnan, Ph.D., declare as follows:

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I am a tenured Professor in the Department of Computer Science at the University of

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Toronto, and have been asked by counsel for Apple Inc. (“Apple”) to provide analysis of the

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source code for the “Tablecloth” application that has been asserted as prior art to U.S. Patent No.

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7,469,381. I submit this declaration in support of Apple’s Opening Supplemental Claim

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Construction Brief.

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1.

Unless otherwise indicated, I have personal knowledge of the matters stated

herein. If called as a witness, I would testify to the facts set forth below.
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I reviewed the source code for the “Tablecloth” application contained on the hard

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drive produced by third party Mitsubishi Electric Research Laboratories (“MERL”) bearing the

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Bates number MERL00000001.

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3.

That source code refers to two separate copies of the Windows desktop image that

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are depicted when Tablecloth is executed. They are identified as “image1” and “image2”, and

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each is treated distinctly in various processes.

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I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct. Executed this 5th day of July, 2012, at Toronto, Canada.

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/s/
Ravin Balakrishnan, Ph.D.

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DECL. OF RAVIN BALAKRISHNAN, PH.D. ISO APPLE’S OPENING SUPPLEMENTAL CLAIM CONSTRUCTION BRIEF
CASE NO. 11-cv-01846-LHK (PSG)
sf-3166749

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