Apple Inc. v. Samsung Electronics Co. Ltd. et al
Filing
1359
Unredacted Exhibits to Kanada Declaration in Support of Apple's Opposition to Samsungs Motions in Limine re 1256 Order on Administrative Motion to File Under Seal, re (Dkt. No. 1206) by Apple Inc.. (Attachments: # 1 Exhibit 2, # 2 Exhibit 3, # 3 Exhibit 4, # 4 Exhibit 5, # 5 Exhibit 6, # 6 Exhibit 7, # 7 Exhibit 9, # 8 Exhibit 10, # 9 Exhibit 12, # 10 Exhibit 41)(Jacobs, Michael) (Filed on 7/26/2012) Modified text on 7/27/2012 (dhm, COURT STAFF).
Exhibit 41
(Submitted Under Seal)
In The Matter Of:
APPLE, INC.,
v.
SAMSUNG ELECTRONICS CO., LTD.,
___________________________________________________
JUN WON LEE - Vol. 1
March 5, 2012
___________________________________________________
HIGHLY CONFIDENTIAL
BUSINESS INFORMATION
IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION
---o0o--APPLE, INC., a California
corporation,
Plaintiff,
vs.
Case No.
4:11-cv-01846-LHK
SAMSUNG ELECTRONICS CO., LTD.,
et al.,
Defendants.
__________________________
/
DEPOSITION OF
JUN WON LEE
___________________________
Monday, March 05, 2012
HIGHLY CONFIDENTIAL BUSINESS INFORMATION
REPORTED BY:
RACHEL FERRIER, CSR 6948
(3-441636)
HIGHLY CONFIDENTIAL BUSINESS INFORMATION
JUN WON LEE - 3/5/2012
30
1
THE INTERPRETER:
2
MR. HEYISON:
3
5
-- to resolve this so I can move
on here.
4
10:11:41
THE INTERPRETER:
MR. HEYISON:
7
THE INTERPRETER:
MR. HEYISON:
10
Q
11
Great.
Okay.
So this person is SVP in this
A
Okay.
Excellent.
Apple?
12
13
14
10:12:27
Boo sa jang is EVP and
context, I believe.
9
10:11:55
Okay.
jeon moo is SVP.
6
8
So --
15
Now, at the first meeting, who attended from
Jim Luton, patent counsel, and the general
counsel came too.
Q
I don't remember the name, though.
If I suggest to you Bruce Sewell, is that the
general counsel from Apple that attended the meeting?
16
A
Apple's own general counsel, Bruce Sewell.
17
Q
Where was the meeting?
18
19
10:12:54
MR. WEINSTEIN:
THE WITNESS:
20
Objection; outside the scope.
Seoul.
BY MR. HEYISON:
21
Q
Can you give me a month and a year?
22
A
I don't remember the date.
23
24
10:13:16
25
at remembering the dates.
Q
Okay.
I'm not really good
I have to look at the record.
So did anybody make any written
presentations?
617-542-0039
Merrill Corporation - Boston
www.merrillcorp.com/law
HIGHLY CONFIDENTIAL BUSINESS INFORMATION
JUN WON LEE - 3/5/2012
31
1
MR. WEINSTEIN:
2
THE WITNESS:
3
Probably Samsung did some kind of
presentation -- oh, Apple did --
4
10:14:17
Objection; beyond the scope.
THE INTERPRETER:
Interpreter's correction:
5
Apple -- probably Apple did some kind of presentation,
6
but Samsung did not make any presentation.
7
BY MR. HEYISON:
8
9
10:14:36
Q
Okay.
Please tell me in as much detail as you
can -- strike that.
10
Okay.
11
MR. WEINSTEIN:
12
THE WITNESS:
13
14
10:15:02
the time.
How long did the meeting last?
Objection; outside the scope.
I don't remember those dates at
BY MR. HEYISON:
15
16
Q
I don't have all those things in my head.
Please tell me in as much detail as you can
what Apple said and what Samsung said.
17
MR. WEINSTEIN:
18
THE WITNESS:
Objection; outside the scope.
Samsung mostly was listening to
19
about Samsung's smartphone infringed Apple phone's
patents and design, so they were complaining about our
22
infringement about Apple's patent and design in their
23
phone.
24
10:16:20
20
21
10:15:52
what Apple said in the first meeting.
BY MR. HEYISON:
25
Q
617-542-0039
Apple was talking
Anything else that you recall Apple saying?
Merrill Corporation - Boston
www.merrillcorp.com/law
HIGHLY CONFIDENTIAL BUSINESS INFORMATION
JUN WON LEE - 3/5/2012
32
1
MR. WEINSTEIN:
2
THE WITNESS:
3
10:16:47
I don't remember any specific
contents in detail.
4
BY MR. HEYISON:
5
Q
And so what did Apple say in response?
6
MR. WEINSTEIN:
7
MR. HEYISON:
8
Q
9
10:17:06
Objection; outside the scope.
Samsung.
Thank you.
What did Samsung say in response?
MR. WEINSTEIN:
10
Objection; outside the scope.
THE WITNESS:
Same objection.
Samsung contended that there was
11
no such infringement and also requested the evidences
12
for the contention of the infringement.
13
BY MR. HEYISON:
14
10:17:49
Q
Okay.
At that first meeting you attended,
15
Mr. Lee, did Samsung assert that Apple was infringing
16
any of Samsung's patents?
17
MR. WEINSTEIN:
18
THE WITNESS:
Objection; outside the scope.
Samsung did not assert that any
19
10:18:32
specific Samsung's patent was infringed.
20
BY MR. HEYISON:
21
Q
At that meeting, that first meeting, did
22
23
infringing any Samsung patents?
24
10:19:10
Samsung tell Apple that Samsung believed Apple was
MR. WEINSTEIN:
25
THE WITNESS:
617-542-0039
Objection; outside the scope.
It is possible that Samsung might
Merrill Corporation - Boston
www.merrillcorp.com/law
HIGHLY CONFIDENTIAL BUSINESS INFORMATION
JUN WON LEE - 3/5/2012
165
1
CERTIFICATE OF REPORTER
2
I, RACHEL FERRIER, a Certified Shorthand
3
Reporter, hereby certify that the witness in the
4
foregoing deposition was by me duly sworn to tell the
5
truth, the whole truth, and nothing but the truth in the
6
within-entitled cause;
7
That said deposition was taken down in
8
shorthand by me, a disinterested person, at the time and
9
place therein stated, and that the testimony was
10
thereafter reduced to typewriting by computer under my
11
direction and supervision and is a true record of the
12
testimony given by the witness;
13
That before completion of the deposition,
14
review of the transcript [X] was [ ] was not requested.
15
If requested, any changes made by the deponent (and
16
provided to the reporter) during the period allowed are
17
appended hereto.
18
I further certify that I am not of counsel or
19
attorney for either or any of the parties to the said
20
deposition, nor in any way interested in the event of
21
this cause, and that I am not related to any of the
22
parties thereto.
23
DATED:
24
_____________________________
RACHEL FERRIER, CSR No. 6948
25
617-542-0039
Merrill Corporation - Boston
www.merrillcorp.com/law
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