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 12
FILED UNDER SEAL

Highly Confidential Attorneys' Eyes Only

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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APPLE INC., a California

)

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Corporation,

)

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Plaintiff,

)

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vs.

) No. 11-CV-01846-LHK

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SAMSUNG ELECTRONICS CO., LTD,

)

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a Korean business entity;

)

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SAMSUNG ELECTRONICS AMERICA,

)

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INC., a New York corporation;

)

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SAMSUNG TELECOMMUNICATIONS

)

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AMERICA, LLC, a Delaware

)

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limited liability company,

)

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Defendants.

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)
)

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HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY

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VIDEOTAPED DEPOSITION OF GREG CHRISTIE

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TUESDAY, OCTOBER 18, 2011

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REPORTED BY:

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JANIS JENNINGS, CSR 3942, CLR, CCRR

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JON NO: 42882
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material there.

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you want to ask him about the technical material in

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the body of the patent, that might be productive.

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But I think asking him just to read the claims is

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not fair and is harassing.

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If you want to look at the -- if

MS. DUCCA:

Counsel, you had the witness

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come in without reading the patent.

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deposition the way we need to take the deposition.

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I'm trying to figure out if he's even an inventor.

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He can't tell me what he invented.

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12

I'll take the

MR. JACOBS:

I don't think you've asked

that question very well.

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MS. DUCCA:

I asked him what he invented.

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He told me he can't tell me.

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BY MS. DUCCA:

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Q.

Can you tell me what you invented in the

'163 patent, sitting here today?
MR. JACOBS:

Objection.

Form.

Calls for

a legal conclusion.
THE WITNESS:

Without reviewing the

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claims and coming to agreement on words that may

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be foreign to my day-to-day use and my job and in

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my communication, I cannot answer that question

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accurately.

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BY MS. DUCCA:
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Q.

What is a structured electronic document?

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A.

I don't use that term.

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Q.

Okay.

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5
6
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What do you believe a structured

electronic document to be?
A.

If I don't use the term, I can't believe

what it is.
Q.

Is a web page a structured electronic

document?

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A.

I don't know.

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Q.

Can it be?

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A.

I don't know.

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Q.

What is a box?

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A.

A box?

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MR. JACOBS:

Objection.

Vague and

ambiguous.

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THE WITNESS:

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of four sides.

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A box is a figure comprised

BY MS. DUCCA:

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Q.

What is a box in the context of claim 2?
MR. JACOBS:

for a legal conclusion.

Object to the form.

THE WITNESS:

Calls

Lacks foundation.
What is a box...

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of content...

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that a box is an area with four sides.

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BY MS. DUCCA:

Well, that interesting.

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A box
I'm guessing

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Q.

2
3

Does it have to have four sides?
MR. JACOBS:

for speculation.

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Lack of foundation.

Calls

Calls for a legal conclusion.

THE WITNESS:

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sides?

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context of claim 2.

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Does it have to have four

BY MS. DUCCA:

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9
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Q.

And just to be clear, sitting here today,

you can't -- you as an inventor on the patent cannot
tell me what a structured electronic document is?

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I don't know the answer to that in the

A.

I don't use the term "structured

electronic document."

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Q.

Is that a yes or a no?

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what it means?

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Can you tell me

not.

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A.

I don't care whether you use it or

It's not a phrase I use; therefore, I

don't know what it means.
Q.

So then sitting here today as an inventor

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on the '163 patent, you cannot tell me what a

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structured electronic document is; correct?

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A.

That is correct.

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Q.

What is a gesture?

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A.

In what sense?

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Q.

In the sense of claim 2.

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A.

In the sense of claim 2...
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