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).

EXHIBIT 24
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,
Plaintiff,

)
)
)
)
vs.
) Case No. 11-cv-01846-LHK
)
SAMSUNG ELECTRONICS CO.,
)
LTD., a Korean business
)
entity; SAMSUNG ELECTRONICS )
AMERICA, INC., a New York
)
corporation; SAMSUNG
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TELECOMMUNICATIONS AMERICA, )
LLC, a Delaware limited
)
liability company,
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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 STEPHEN GRAY
Palo Alto, California
Friday, May, 4, 2012

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BY: HEIDI BELTON, CSR, RPR, CRR, CCRR
CSR LICENSE NO. 12885
JOB NO. 49273

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TSG Reporting - Worldwide

877-702-9580

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enlarged in the zone view.

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Q.

16:37:05

Does -- would you agree that Claim 50

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requires -- I'm looking at the -- sort of the middle of

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the claim near line 32 -- that what is required is

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enlarging and translating the structured electronic

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document so that the first box is substantially

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centered?

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MS. MAROULIS:

Objection; vague.

16:37:22

Calls for

legal conclusion.

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THE WITNESS:

I think you have -- with the

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proviso there maybe alterations in the language.

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think you've -- you've correctly read the limitation

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16:37:37

starting at line 31.

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MS. MAROULIS:

But I

We've been going for over an

hour.

16:37:53

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THE WITNESS:

Would you like to take a break

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MR. MONACH:

Let me just finish up with this.

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MS. MAROULIS:

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soon?

Okay.

BY MR. MONACH:
Q.

16:37:57

Is it your opinion that in the transition from

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the world view to the zone view shown on page 4 of your

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Appendix 7, that what has been enlarged and translated

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is the same structured electronic document that is shown

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in the world view?

16:38:30

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A.

No.

The document which is being shown in the

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zone view on page 4 is a box of content from the

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16:38:32

structured electronic document shown in the world view.

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Q.

Which is -- so the thing shown on the right is

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a different structured electronic document than the

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structured electronic document shown in the world view,

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right?

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MS. MAROULIS:

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THE WITNESS:

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Objection; vague.
I thought I said something

different, so let me try again.

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16:39:00

16:39:16

The selection of -- of the box shown in --

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okay.

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identified in red a first box.

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a first gesture enlarges and centers that box of content

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in the zone view shown on the right.

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BY MR. MONACH:

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In the world view on the left, there is

Q.

Selection of that box by

16:39:38

But there is no enlarging and translating of

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the structured electronic document shown on the left;

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rather, the distinct -- in your view -- structured

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electronic documents in those four tiles are enlarged

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and centered?

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MS. MAROULIS:

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Assumes

facts.

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Objection; vague.

16:39:57

BY MR. MONACH:

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Q.

Is that right?

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16:40:06

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A.

I believe that the enlarged and centered zone

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view is a box of content found on the world view.

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comprised of individual tiles or structured electronic

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documents on their own.

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or created from an enlargement of the world view

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structured electronic document into the zone view.

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16:40:11

BY MR. MONACH:

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Q.

It is

But it is from -- it is derived
16:40:29

So the world view electronic document, the

36-tile document is not enlarged as an entity and then
translated to center those four boxes, right?

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MS. MAROULIS:

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THE WITNESS:

16:40:48

Objection; vague.
I don't have any reason to

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believe that -- well, let me say it slightly

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differently.

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what the -- the software performed with respect to

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enlarging and centering.

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are that are intended for LaunchTile, there is no reason

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for me, sitting here today, to believe that the

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structured electronic document that is -- that is the

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world view is not enlarged and the portion of it that

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was selected in that box of content simply enlarged and

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translated into the zone view.

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BY MR. MONACH:

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Q.

I'm not sure, sitting here today, exactly
16:41:15

But given what the functions

16:41:34

Let's look at the content from these four

boxes that are shown in the center of the world view and

TSG Reporting - Worldwide

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16:41:46