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
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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**HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY**

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DEPOSITION OF STEPHEN ZADESKY
Redwood Shores, California
Monday, March 5, 2012

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Reported By:
LINDA VACCAREZZA, RPR, CLR, CRP, CSR. NO. 10201
JOB NO. 46058
TSG Reporting - Worldwide - 877-702-9580

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Q.

And do you remember any specific

issues regarding air gaps --

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A.

Yes.

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Q.

-- on the original iPhone?

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A.

Yes.

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Q.

Where was the air gap issue, like

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11:17

on the body of the phone, where was it located?
A.

Wherever two different materials

came together there was typically a gap.
Q.

And do you recall any specific

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meeting of two materials that was an issue that

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11:17

you addressed?

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A.

Yes.

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Q.

Where was it located?

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A.

The gap between the cover glass

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11:18

and the stainless steel bezel.

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Q.

And the stainless steel what?

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A.

Bezel.

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Q.

Okay.

So the -- was this on a

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model that was close to what was released as the

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original iPhone, meaning the issue of the air gap

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that you're talking about?

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A.

Yes.

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Q.

11:18

And what specifically was the

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issue that you were addressing?

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A.

Our testing showed that by making

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a small change in the gap between the glass and

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the stainless steel bezel that we could improve

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performance in drop testing.

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Q.

What was the difference,

11:19

increasing the gap or decreasing the gap?

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A.

Decreasing.

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Q.

And what is the role of the bezel

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that you're talking about, the stainless steel

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bezel that goes around the face of the original

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iPhone?

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MR. BEARD:

Objection.

11:19

Vague and

ambiguous.

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THE WITNESS:

It would depend on

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who you would ask.

For us, it was the

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primary structural member of the phone.

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11:19

The primary structural member of

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the phone.

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Q.

I just couldn't -- you dropped

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off, so I couldn't hear exactly how you ended the

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sentence.

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11:19

Thank you for repeating it.
For us, you mean product design or

mechanical engineering perspective?

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A.

Yeah, yeah, yes.

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Q.

And what specifically did the

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bezel do in that -- in terms of being the primary

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structural member of the phone?

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A.

It provides structural support and

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attachment points for the other internal

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components of the device.

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Q.

11:20

Did it have a role in attaching

the display and cover glass?
A.

Yes.

The cover glass and display

were some of the items attached.

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Q.

And what else?

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A.

It would be a really long list.

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11:20
A

lot of things.
Q.

And the bezel also attached those

units to the back housing; is that right?

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A.

I'm sorry, what's those units?

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Q.

The things that you said it

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supported.

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A.

Right.

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Q.

Or the attachment points that it

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created were to attach certain items to the back

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housing; is that right, so that it would be one

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11:20

solid unit?

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A.

Yes.

11:20

Some of the components were

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attached to the bezel.

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were attached to the bottom housing.

Some of the components
And then as

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part of the assembly process they would meet

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together.

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Q.

So either directly or indirectly, yes.
Did the bezel also have a role in

protecting the cover glass?

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A.

Yes.

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Q.

What was that role?

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A.

In a drop event, if the unit were

11:21

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to land on the stainless steel bezel rather than

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on the glass, it would protect the glass.

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Q.

Have there been designs that

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involved glass going all the way to the edge of

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11:21

the device?

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A.

On?

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Q.

On the iPhone?

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A.

On the M68?

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Q.

Yes.

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A.

I don't think so, no.

Q.

Do you remember any designs where

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11:21

Or I'm not

sure.

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the glass was proud of the bezel, meaning higher

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than the top of the bezel?

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A.

During the development of M68?

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Q.

Yes.

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A.

11:22

We go through so many different

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iterations at the beginning that I would be

TSG Reporting - Worldwide - 877-702-9580

11:22