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

Filing 1384

Unredacted Exhibits to Arnold Declaration 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. 930, 945) (Attachments: # 1 Exhibit 46 to Arnold, # 2 Exhibit 47 to Arnold, # 3 Exhibit 48 to Arnold, # 4 Exhibit 49 to Arnold, # 5 Exhibit 50 to Arnold, # 6 Exhibit 51 to Arnold, # 7 Exhibit 52 to Arnold, # 8 Exhibit 54 to Arnold, # 9 Exhibit 55 to Arnold, # 10 Exhibit 56 to Arnold, # 11 Exhibit 57 to Arnold, # 12 Exhibit 58 to Arnold, # 13 Exhibit 60 to Arnold, # 14 Exhibit 63 to Arnold, # 15 Exhibit 64 to Arnold, # 16 Exhibit 66 to Arnold, # 17 Exhibit 68 to Arnold, # 18 Exhibit 69 to Arnold, # 19 Exhibit 71 to Arnold, # 20 Exhibit 73 to Arnold, # 21 Exhibit 74 to Arnold, # 22 Exhibit 75 to Arnold, # 23 Exhibit 76 to Arnold, # 24 Exhibit 77 to Arnold, # 25 Exhibit 78 to Arnold, # 26 Exhibit 79 to Arnold, # 27 Exhibit 80 to Arnold, # 28 Exhibit 81 to Arnold, # 29 Exhibit 82 to Arnold)(Maroulis, Victoria) (Filed on 7/26/2012) Modified text on 7/27/2012 (dhm, COURT STAFF).

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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
A T T O R N E Y S' E Y E S O N L Y

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VIDEOTAPED DEPOSITION OF PHIL HOBSON
REDWOOD SHORES, CALIFORNIA
TUESDAY, FEBRUARY 28, 2012

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BY: ANDREA M. IGNACIO HOWARD, CSR, RPR, CCRR, CLR
CSR LICENSE NO. 9830
JOB NO. 46054
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that your understanding?

15:34

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A

That's my understanding, yes.

15:34

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Q

Mr. Hamblin in his e-mail says:

15:34

"We have made some additional modifications

15:34

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to the Grape mechanical drop samples."

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15:34

Do you see that?

15:34

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A

Yes.

15:34

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Q

Do you know what he refers -- what he's

15:34

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referring to when he says "Grape mechanical drop

15:34

samples"?

15:34

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MR. GALLEGOS:

Objection; lacks foundation.

15:34

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THE WITNESS:

I don't know specifically what

15:34

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he's referring to.

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MR. KIDMAN:

15:34
Q.

Were you involved in any

drop testing that related to the touch panel?
A

Specifically just the touch panel?

I mean,

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15:34
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we did drop testing for -- for the general

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architecture.

15:35

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Q

And did the drop -- any of the drop testing

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that you participated in include samples of phones

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where the touch panel was in operation?

15:35

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MR. GALLEGOS:

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THE WITNESS:

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Objection; vague.
Yes.

I mean, we did drop

testing all the way up to production ramp.
MR. KIDMAN:

Q.

Were there any drop tests,

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the purpose of which was to determine the -- the --

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the impact on the touch panel?

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A

The touch panel was one of many components

we'd look at after getting drop test results.
Q

In this e-mail, Mr. Hamblin writes "the

changes are," and in the paragraph No. 1, he says:

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"We've added a black mask around the

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15:36
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perimeter of the bottom side of the cover sheet."

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Do you know what he's referring to there?

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MR. GALLEGOS:

Objection; lacks foundation.

15:36

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THE WITNESS:

I can only make an assumption.

15:36

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I don't know specifically what he's referring to.

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MR. KIDMAN:

Q.

Are you familiar with

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15:37

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something on the original iPhone that's referred to as

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the "black mask"?

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A

That typically is the ink layer on the

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underside of the cover glass to hide the mechanical

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bits inside the product.

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Q

And can you see the black mask from the

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exterior of the phone if you're -- if you're holding

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it and looking at the front of the phone?

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A

Yes.

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Q

And what -- what is the -- what is the

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black -- black mask?

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surrounds the active area of the screen?

Is that the black border that

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MR. GALLEGOS:

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THE WITNESS:

Objection; vague.

15:37

The black mask is -- again,

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it's an ink layer applied to the underside of the

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cover glass that hides all the mechanical parts inside

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the product.

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MR. KIDMAN:

Q.

And from the -- viewing the

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phone from the exterior, does the black mask appear as

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a border that runs around the active area of the

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display?

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MR. GALLEGOS:

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THE WITNESS:

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Objection; vague.
It depends on how you define a

border.

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15:38
MR. KIDMAN:

Q.

Well, if you're just looking

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at the -- holding the original iPhone and looking at

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the screen, is the black mask that you're referring to

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visible?

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A

From the front of the product, yes.

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Q

And that's the area that is between the

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active area of the display and the -- the bezel; is

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that -- is that correct?

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MR. GALLEGOS:

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THE WITNESS:

Objection; form; vague.

15:38

The black mask extends from the

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outer edge of the glass to the visible active area of

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the LCD.

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MR. KIDMAN:

Q.

And what components of the

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device does the black mask hide?

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MR. GALLEGOS:

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THE WITNESS:

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Objection; form.
I mean, most all the components

on the inside, mechanical components.

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MR. KIDMAN:

Q.

In his e-mail, Mr. Hamblin

goes on to say:

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"The critical dimension for the black mask

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location is to ensure a 0.2mm gap between the LCD

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active area and the edge of the black mask."

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Do you see that?

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A

Yes.

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Q

Do you have any understanding as to what he's

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referring to there?

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MR. GALLEGOS:

Objection; lacks foundation.

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THE WITNESS:

I can only make an assumption

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as to what he's talking about.

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MR. KIDMAN:

Q.

15:40

Well, what would your

understanding be based on?
A

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15:40

Based on what I read, my understanding would

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be he's talking about the gap between the active area

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of the LCD at 0.2, and then the edge of the black mask

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starts.

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Q

And the "0.2mm" refers to 0.2 millimeters; is

that correct?
A

15:41
15:41

Yes.

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Q

And is that 0.2-millimeter gap between the

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active area of the screen and the edge of the black

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mask, is that sometimes called the dead pixel area?

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MR. GALLEGOS:

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THE WITNESS:

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Objection; form.

15:41

I never heard it referred to as

that.

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15:41
MR. KIDMAN:

Q.

Do you have any

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understanding as to why the active area of the screen

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on the original iPhone does not extend all the way to

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the edge of the bezel?

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MR. GALLEGOS:

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THE WITNESS:

Objection; form.

15:41

There are things located around

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the border of the LCD that necessarily need to be

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there, things like seals between the different glass

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layers, traces for the electrical signals.

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need space for those things to reside.

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MR. KIDMAN:

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MR. GALLEGOS:

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THE WITNESS:

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Q.

So you

Any other reasons?
Objection; form.

No, that's the -- the main

reasons.

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MR. KIDMAN:

Q.

Any other -- I understand

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that may be the main reason, but are there any other

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reasons, whether you'd call them main reasons or not?

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MR. GALLEGOS:

Objection; form; vague; lacks

foundation.

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