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

Filing 1360

Unredacted Declaration of Bill Trac in Support of Samsung's Reply in Support of Motion for Summary Judgment 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. Nos. 1068, 1069) (Attachments: # 1 Exhibit 1 to the Trac Declaration, # 2 Exhibit 2 to the Trac Declaration, # 3 Exhibit 8 to the Trac Declaration, # 4 Exhibit 9 to the Trac Declaration, # 5 Exhibit 10 to the Trac Declaration, # 6 Exhibit 14 to the Trac Declaration, # 7 Exhibit 15 to the Trac Declaration, # 8 Exhibit 16 to the Trac Declaration, # 9 Exhibit 17 to the Trac Declaration, # 10 Exhibit 18 to the Trac Declaration, # 11 Exhibit 19 to the Trac Declaration, # 12 Exhibit 20 to the Trac Declaration, # 13 Exhibit 21 to the Trac Declaration, # 14 Exhibit 22 to the Trac Declaration, # 15 Exhibit 23 to the Trac Declaration, # 16 Exhibit 24 to the Trac Declaration, # 17 Exhibit 25 to the Trac Declaration, # 18 Exhibit 26 to the Trac Declaration, # 19 Exhibit 27 to the Trac Declaration, # 20 Exhibit 28 to the Trac Declaration)(Maroulis, Victoria) (Filed on 7/26/2012) Modified text on 7/27/2012 (dhm, COURT STAFF).

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UNITED STATES DISTRICT COURT

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STATE OF CALIFORNIA

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SAN JOSE DIVISION

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--oOo--

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APPLE INC., A CALIFORNIA

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CORPORATION,

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PLAINTIFF,
vs.

) No.

11-CV-01846-LHK

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SAMSUNG ELECTRONICS CO.,

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LTD., A KOREAN BUSINESS

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ENTITY; SAMSUNG ELECTRONICS

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AMERICA, INC., A NEW YORK

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CORPORATION; SAMSUNG

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TELECOMMUNICATIONS AMERICA,

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LLC, A DELAWARE LIMITED

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LIABILITY COMPANY,

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DEFENDANTS.

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______________________________)

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VIDEOTAPED DEPOSITION OF ROBERT BRUNNER
HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY

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San Francisco, California

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Monday, March 5, 2012

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Reported By:
KATHLEEN WILKINS, CSR #10068, RPR, CRR, CCRR, CLR

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JOB NO. 47111
TSG Reporting - Worldwide - 877-702-9580

Highly Confidential - Attorneys Eyes Only

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referring to as the bezel.
A.

Let's see.

This -- this plastic

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material (indicating) which surrounds the display

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is commonly referred to as a bezel.

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Q.

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And on page 134 of Exhibit 1, the black

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Thank you.

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plastic that surrounds and sits above the display,

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that's also something you referred to as a

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"bezel"?

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A.

Yes, that is correct.

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Q.

On this Jaguar concept on page 134, is

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the flat panel display something that can be

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detached and used separate and apart from the rest

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of the device?

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A.

It's designed to be detached but not

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separately.

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behind the display is intended as a desktop

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computer which could be connected to virtually any

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monitor.

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intended as a module to attach should you want to

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make it portable.

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Q.

It was intended as -- the portion

And then the flat panel section was

And if you wanted to input information

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into this computer, can you do it through the

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display?

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A.

No.

No.

It was entirely based on

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keyboard and mouse interaction.
Q.

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So the display, even if detached, would

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never be used in a manner where a person would

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hold it with one hand and touch the display with

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the other -- with fingers of the other hand?

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A.

No, it would not.

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Q.

Let's look at page 144, the brain box.

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This is Exhibit 1, so it's the brain box --

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A.

Yes.

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Q.

-- picture we were talking about

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earlier?

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You testified that the brain box was a

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concept that was developed before you arrived at

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Apple.

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Do you have, as you sit here today,

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knowledge about what that concept looked like

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separate and apart from what you see in the

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picture?

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MR. WEBSTER:

Object.

That misstates

his testimony.

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THE WITNESS:

I do not recall ever

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seeing the concept in person.

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photographs of it.

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concept model, that I recall seeing it.

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BY MS. TUCHER:

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I have seen

I have never actually seen the

TSG Reporting - Worldwide - 877-702-9580

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Q.

Have you seen photographs of it other

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than the photograph that is on page 144 of

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Exhibit 1?

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A.

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I -- I think so, but

I'm not entirely positive.
Q.

Do you know what the back of the display

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MR. WEBSTER:

Object.

It calls for

speculation.

10

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screen looks like?

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I'm not positive.

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THE WITNESS:

It's -- it would be

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guesswork at this point.

Again, without seeing

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photographs, I think I know what it looks like,

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but I can't say with absolute certainty.

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BY MS. TUCHER:

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Q.

I'm not asking you to guess.

So if you

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can't give us any information about what the back

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of the product looks like, we will have to leave

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it there.

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A.

Mh-hmm.

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Q.

Let's look at page 174 of Exhibit 1, the

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PenMac device that you were asked about earlier.

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Does this device also have a raised

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plastic bezel surrounding the display screen?

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A.

Yes, it does.

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Q.

And is this device actually rectangular,

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