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 10
FILED UNDER SEAL

Highly Confidential - Outside Counsels 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,

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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,
Defendants.
____________________________/

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H I G H L Y
C O N F I D E N T I A L
O U T S I D E C O U N S E L O N L Y

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VIDEOTAPED DEPOSITION OF SCOTT FORSTALL
REDWOOD SHORES, CALIFORNIA
THURSDAY, OCTOBER 27, 2011

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BY: ANDREA M. IGNACIO HOWARD, CSR, RPR, CCRR, CLR
CSR LICENSE NO. 9830
JOB NO. 43002
TSG Reporting - Worldwide

877-702-9580

Highly Confidential - Outside Counsels Eyes Only

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language in here are you sort of pointing to that

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reflects this notion of -- of pointing to a logical or

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semantical region?

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A

It talks about a plurality of boxes of

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content.

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refer to these sort of semantic or logical regions as

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one area I see in this that implies that.

And so in this case, boxes of content would

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Q

Okay.

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A

Let's see.

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Anything else?

Well, I mean, a structured electronic

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document, so this implies some level of structure.

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Structure itself would imply there are semantic

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regions, logical regions, within it, and that's what

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the structure entails.

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document itself helps describe this idea.

So the structured electronic

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So those are -- I mean, there might be

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something else I'm missing in there, but those are the

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two that I --

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Q

Okay.

What does "structured electronic

document" mean?
MR. JACOBS:

Objection; calls for a legal

conclusion.
MR. JOHNSON:

Q.

You can go ahead and answer

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unless he tells you not to answer something.

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just preserving the rights for the record.
TSG Reporting - Worldwide

877-702-9580

He's

Highly Confidential - Outside Counsels Eyes Only

Page 14
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A

Okay.

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Q

What does elect -- sorry -- what does

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Could you ask the question again.

"structured electronic document" mean?

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MR. JACOBS:

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THE WITNESS:

Same objection.
I don't know the legal

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definition, if there is a legal definition of

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structured electronic document.

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I can answer sort of my understanding of how
I would interpret structured electronic document to

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mean, and I would take it to mean a -- a document

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which has some form of structure in it, and that

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structure could come in many different forms.

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HTML is a great example of sort of a

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structured electronic document where it is a document

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that the actual organization of HTML implies different

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regions.

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object model, and all of this sort of builds and

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creates structure; and so there's sort of a render

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tree you have for this that's non-UI, and then you

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apply different styles and other things to then

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display it on the screen.

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a structure sort of as a piece of that.

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There's, like, divs and there's a document

MR. JOHNSON:

Q.

And so there is -- there is

If you -- if you turn to

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Figure 5A, I think, each one of the blocks that are

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labeled there, are those -- are those structured
TSG Reporting - Worldwide

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Highly Confidential - Outside Counsels Eyes Only

Page 15
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electronic documents like you were just referring to?
A

Well, you can infer -- or you could -- there

can be multiple different ways of looking at this.

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One way is to look at the entire web page as

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a structured electronic document, and then these are

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sort of the semantic regions I was talking about

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earlier.

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You could imagine that you could embed a
whole other document within a document as well.

So

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you could have maybe, you know, an Excel spreadsheet

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in a piece of this or a whole other web page inside of

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a frame, and then that itself could be considered a

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structured electronic document inside of another one.

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You know, from this you can't determine

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precisely which those blocks are, but it can be

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interpreted in multiple ways.

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Q

Okay.

So you could have, for example,

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block -- Block 1 could be its own structured

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electronic document, and then there could be something

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embedded within there, like the Excel spreadsheet or

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something else, which would then be another box of

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content; is that what you're saying?

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A

I'm not sure what you mean by "box of

content" there.
Q

Right.
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Page 16
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A

You could have --

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Q

I was -- yeah.

I mean, if you turn back to

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Claim 2, it talks about a structured electronic

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document "wherein the structured electronic document

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comprises a plurality of boxes of content."

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A

Uh-huh.

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Q

So -- and I'm not trying to put words in your

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mouth.

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I'm trying to understand.
What I understand structured electronic

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document to mean is that it can be very broad in a lot

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of senses, and it can be the whole web page, per se,

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and it can also be something smaller, like Block 1, if

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there is something that's embedded within it, like an

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Excel spreadsheet; is that accurate?

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MR. JACOBS:

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THE WITNESS:

Objection; form.
So there's a potential

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recursive nature of structure and -- I mean, you see

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its nature.

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something which is recursive and it is a structure to

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fractals, but when you zoom into them, there's a

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structure embedded within them.

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electronic document itself could embed other

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structured electronic documents within it.

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You see it's in fractals.

MR. JOHNSON:
Q

So a structured

Okay.

What is -TSG Reporting - Worldwide

A fractal is

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