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

Filing 1379

Unredacted Exhibits to Gray and Van Dam Decs ISO Samsung's MSJ 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, (Dkt. Nos. 931, 937 (Attachments: # 1 Exhibit 7 to Gray, # 2 Exhibit 8 to Gray, # 3 Exhibit 9 to Gray, # 4 Exhibit 10 to Gray, # 5 Exhibit 11 to Gray, # 6 Exhibit 12 to Gray, # 7 Exhibit 13 to Gray, # 8 Exhibit 14 to Gray, # 9 Exhibit 15 to Gray, # 10 Exhibit 2 to Van Dam)(Maroulis, Victoria) (Filed on 7/26/2012) Modified text on 7/27/2012 (dhm, COURT STAFF).

EXHIBIT 2

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION

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APPLE INC., a California
corporation,

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Plaintiff,
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vs.

CASE NO. 11-CV-01846-LHK

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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,

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Defendants.
_____________________________/

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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
O U T S I D E
C O U N S E L

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VIDEOTAPED DEPOSITION OF RAVIN BALAKRISHNAN, Ph.D.
SAN FRANCISCO, CALIFORNIA
TUESDAY, AUGUST 16, 2011

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BY: ANDREA M. IGNACIO HOWARD, CSR, RPR, CCRR, CLR
CSR LICENSE NO. 9830
JOB NO. 41176
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did zoom in.

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in, I need to spend a bit more time making sure

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whether it has to or not.

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now on this device.

But whether or not it has to be zoomed

I have not done that right

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MR. JOHNSON:

Okay.

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THE WITNESS:

So, on this device, I went

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through the -- the preamble.

It's clearly a

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computer-implemented method.

It has a device with a

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touchscreen display.

It is displaying right now a

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first portion of an electronic document.

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electronic document here happens to be a photograph or

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an image, some kind of a picture of something.

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MR. JOHNSON:

Q.

The

Is the electronic doc --

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what -- what does an "electronic document" mean in the

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context of this patent?

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MR. MONACH:

Object to form to the extent

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it's calling for a legal conclusion, but you can give

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your views on that.

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THE WITNESS:

In the context of this patent,

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my understanding, having read the patent and the

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claims, is the electronic document is some visual

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representation on the screen that has a defined length

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and a width, as an example, or defined set of

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boundaries, because they may not have to be a

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rectangular set of boundaries.
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MR. JOHNSON:

Q.

So can it -- it can be

anything with a defined length and width?
A

It could be any visually represented thing

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with a defined boundary.

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"boundaries," because length and width may connote a

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rectangular thing.

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necessarily.

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Q

It may not be a rectangle,

So an electronic document is anything

that can be visually represented with a defined
boundary?

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Okay.

I'd rather use the word

MR. MONACH:

Object to the form of the

question; object as calling for a legal conclusion.

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THE WITNESS:

In the context of this patent

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and the claims, reading the patent and the claims, I

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would say that would be a -- my definition of an

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electronic document would be something visually

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representable on the screen that -- that has a defined

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set of boundaries.

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MR. JOHNSON:

Okay.

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Q

How about the next limitation?

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A

Okay.

So, as I said earlier, it's got a

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first portion of an electronic document.

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went through that.

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Q

And -- and -- I'm sorry.

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A

I'm sorry.
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