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

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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?

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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

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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

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