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 FLETCHER ROTHKOPF
REDWOOD SHORES, CALIFORNIA
WEDNESDAY, FEBRUARY 29, 2012

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BY: ANDREA M. IGNACIO HOWARD, CSR, RPR, CCRR, CLR
CSR LICENSE NO. 9830
JOB NO. 46055
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having on iPhones during the development phase.

2

won't be able to remember them all.

3

product, there's hundreds of issues, so --

4
5
6

Q

I

Developing a

As you sit here, do you -- do you remember

any of those issues?
A

09:29
09:29
09:29
09:29
09:29

Sure.

09:29

7

Is there a specific type of technical issue

09:29

8

that you're -- you want me to try to remember or --

09:30

9

Q

No.

10

A

-- relating to any particular aspects?

11
12

I'm just --

Because, like I said, there are hundreds.
Q

09:30
09:30
09:30

As you sit here, do you -- do you recall --

09:30

13

are there categories of issues that you -- that you

09:30

14

recall?

09:30

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A

Sure.

09:30

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Q

What -- what are those categories of issues?

09:30

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A

Cosmetic issues; manufacturing issues; design

09:30

18

issues; and related to manufacturing issues, cost --

09:30

19

cost control issues; and then -- and then issues that

09:30

20

are brought about trying to meet the industrial

09:30

21

design.

09:30

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category.

09:30

23

Q

09:31

It kind of goes into the cosmetic issues

With respect to any version of the iPhone,

24

what issues do you recall having been brought about by

09:31

25

trying to meet the industrial design?

09:31

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A

Doing the white version of the iPhone was

09:31

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challenging.

3

new things we weren't expecting that would be

09:31

4

difficult to make that product white.

09:31

5

We had to pioneer a lot of -- a lot of

More issues around the home button.

That's a

09:31

09:31

6

really big, big detail to our ID team, so getting that

09:31

7

perfect is -- is always tricky.

09:31

8
9
10

Issues around the detail, the finishing of

09:31

the bottom housings and the -- the cosmetic and

09:31

structural parts for the -- for the phone.

09:31

11

Q

Anything else?

09:32

12

A

Like I said, there are -- there are hundreds

09:32

13

of different individual issues.

14

ones that come to mind as far as things that were

09:32

15

truly challenging and/or were being talked about a lot

09:32

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and took a lot of research just to solve.

09:32

Those are the main

09:32

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Q

Any others that come to mind as you sit here?

09:33

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A

No.

09:33

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Q

Any -- any smaller ones that come to mind as

20
21

Those are the big ones.

you sit here?
A

09:33
09:33

Tiny details around how to finish the screws

09:33

22

on the outside of the product.

23

on the -- that the user can see on the outside of the

09:33

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product.

09:33

25

wanted to pay a lot of attention to.

There are two screws

Those were, again, a detail that the ID team
And to an

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engineer, a screw is normally just a screw.

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this case they were really tricky, expensive,

09:33

3

laborious.

09:33

4

Q

Anything else?

09:33

5

A

Small, small design details.

6

issues on the phone.

But in

There were

That's all that comes to mind.

09:33

09:34
09:34

7

Q

Is there a white version of the iPod Touch?

09:34

8

A

There is.

09:34

9

Q

And did you encounter the same problems with

09:34

10

the white version of the iPod Touch that were

09:34

11

encountered with the white version of the iPhone?

09:34

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A

Many of them.

09:34

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Q

And what -- what were the -- what were the

09:34

14

challenges that you referred to doing the -- the white

09:34

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version of the iPhone?

09:34

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A

The main ones are making the -- the white ink

09:34

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on the back of the glass opaque enough that light

09:35

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doesn't shine through where you don't want it to shine

09:35

19

through, and making the sensors, particularly the

09:35

20

light-related sensors, like the ambient light sensor,

09:35

21

work properly, even though you have a much more

09:35

22

reflective surface around it than you did when you had

09:35

23

a black -- black ink.

09:35

24
25

Those are the big ones, but that -- that -iPhone had paved the way, and those guys had resolved

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most of the technical issues, so we could roll their

09:35

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findings into the iPod Touch.

09:35

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Q

Do you recall -- so -- so the two issues that

09:35

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you identified for me, using the white ink -- or

09:36

5

getting the white ink on the back of the glass opaque

09:36

6

enough so light didn't shine through where you didn't

09:36

7

want it to shine through, and then also the issue with

09:36

8

the ambient light sensors with the more reflective

09:36

9

surface, those are -- those are challenges that --

09:36

10

that you had to deal with on the white version of the

09:36

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iPod Touch?

09:36

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A

Yes.

09:36

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Q

Do you recall -- you had mentioned that

09:36

14

the -- a lot of the challenges had been addressed by

09:36

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the folks doing the -- the white version of the

09:37

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iPhone, and that they had paved the way for you.

09:37

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Do you recall any of the challenges that the

09:37

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folks doing the white version of the iPhone

09:37

19

challenged -- encountered -- I'm sorry -- encountered,

09:37

20

other than the two that you've just described for me?

09:37

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A

Yes.

09:37

22

Q

What issues do you recall with respect to the

09:37

23
24
25

white version of the iPhone?
A

09:37

Figuring out how to make the -- the white

plastic around the glass not stain.

For example, inks

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coming off of someone's clothes when the phone was in

09:37

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their pocket staining the white plastic.

09:37

3

We don't have a proximity sensor on the iPod

09:37

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Touch, but they do on the phones, and getting that to

09:37

5

work through the white was also a challenge.

09:37

6
7

The appearance of the home button again in
white was a challenge.

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9
10

09:38
09:38

Those -- those are the ones I remember that
the product design team specifically had to deal with.
Q

You referred to the -- the challenge of

09:38
09:38
09:38

11

getting the white ink on the back of the glass opaque

09:38

12

enough so that light didn't shine through where you

09:38

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didn't want it to.

09:38

14

Where -- where is that -- where is that ink

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on the back of the glass?

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you're referring to?

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A

Is there an area that

09:39
09:39
09:39

The ink is everywhere except for some

09:39

18

specific locations.

19

screen doesn't shine through ink.

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a few other discrete locations where there are no --

09:39

21

there is no ink or there's different types of ink.

09:39

22

The ambient light sensor lives where the proximity

09:39

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sensor lives.

09:39

24

receiver hole or the home button hole.

25

Q

One is where the screen is.

The

09:39

And then there are

09:39

Obviously, there is no ink in the

So other than those locations you described,

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there's white -- white ink that's on the back of

09:39

2

the -- the glass cover of the iPhone?

09:39

3
4

A

When you see white on the front of

the iPhone, that's the ink on the back of the glass.

5
6

Right.

Q

What's the purpose of that ink -- white ink

on the back of the glass?

7

A

It's cosmetic.

It stops you from seeing all

09:39
09:39
09:39
09:39
09:39

8

the -- all the guts, if you will, on the inside of the

09:39

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phone.

09:40

10
11

Q

So if that -- if that ink weren't there, you

09:40

would see the components on the inside of the phone?

09:40

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A

And you would see the glue on the back of the

09:40

13

glass that was holding it onto the product and the

09:40

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not-pretty stuff.

09:40

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Q

So what was the -- the issue, as you recall

09:40

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it, with getting the white ink opaque -- opaque enough

09:40

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so that light didn't shine through?

09:40

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A

The issue was that a given layer of white ink

09:40

19

at a given thickness did not have the opacity of that

09:40

20

same thickness of black ink.

09:40

21

Q

And why -- why was that an issue?

09:41

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A

It's an issue because there are light sources

09:41

23

inside the product besides the active area of the

09:41

24

display, and you don't want those to shine through the

09:41

25

ink.

09:41

So the LEDs that light the back light for the

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display, those leak some undesired light, and you

09:41

2

don't want to be able to see that from the outside of

09:41

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the product.

09:41

4

Q

So the -- the -- the -- what was it about the

09:41

5

white ink that made that more of a challenge than --

09:41

6

than black -- the black ink --

09:41

7

A

It was --

09:41

8

Q

-- that was used on, I guess, the black

09:41

9
10

versions of the -- of the iPhone?
A

-- it was the lower opacity.

09:41
So for a given

09:42

11

intensity of stray light source, you'll be able to see

09:42

12

that more easily from the outside of the product with

09:42

13

a given thickness of white ink versus black ink.

09:42

14

Q

And is -- is that -- well, could that issue

09:42

15

be resolved just by using more than one -- using

09:42

16

additional layers of the -- of the white ink?

09:42

17

A

That's one of the ways that that's resolved.

09:42

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Q

How -- how was this issue resolved?

09:42

19

A

A combination -- a combination of factors:

09:42

20

More white ink, as you said; printing different colors

09:42

21

of ink that were more opaque behind the white ink; and

09:43

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I believe there was some amount of reformulation of

09:43

23

the white ink to make it more opaque for a given

09:43

24

thickness.

09:43

25

chemistry.

I wasn't directly involved in that

09:43

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2

Q

Are there -- were there any manufacturing

09:43

issues surrounding the -- the use of the white ink?

09:43

3

A

Yes.

09:43

4

Q

What were the -- the manufacturing issues?

09:43

5

A

The main one that my team was directly

09:44

6

dealing with -- and when I say "my team," I mean the

09:44

7

product design team -- is every time you print a layer

09:44

8

of ink, there's some fallout for that step.

09:44

9

more layers you add, the more fallout you have.

So the
So

09:44

10

it's a -- it's a yield-related process issue to print

09:44

11

more layers.

09:44

12

Q

Any other manufacturing issues in connection

09:44

13

with using the white ink on the white version of the

09:44

14

iPhone?

09:44

15

A

Yes.

09:44

16

Q

What -- what other manufacturing issues?

09:44

17

A

Laminating a touch sensor to the -- to the

09:44

18

back of the glass is more challenging when the ink is

09:44

19

thicker.

09:44

20

Q

Any others?

09:45

21

A

Not that I can think of directly relating to

09:45

22
23

the -- the white ink.
Q

You mentioned that one of the manufacturing

09:45
09:45

24

issues with the white ink used on the white iPhone --

09:45

25

and, I take it, also on the white iPod Touch; is that

09:45

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correct?

09:45

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A

Which one are you talking about?

09:45

3

Q

Well, I'm sorry.

09:45

4

That's not a good question.

Let me rephrase.

5

09:45

One of the manufacturing issues that you

09:45

6

mentioned about -- mentioned concerning the white ink

09:45

7

that's used with the white version of the iPhone, is

09:46

8

that the more layers you print, the more fallout there

09:46

9

is.

09:46

10
11
12
13
14

What do you mean by -- by "fallout"?
Something that causes you to throw a piece of

09:46

A

09:46

glass away in the factory.
Q

09:46

And so when you -- when you said "yield

09:46

issue," that means -- that's -- that's the same issue?

09:46

15

A

Yes.

09:46

16

Q

Yield -- well --

09:46

17

A

1 over yield equals fallout.

09:46

18

Q

I'm sorry.

09:46

19

A

I guess 1 minus yield equals fallout.

What over yield equals fallout?
So if

09:46

20

you have 40 percent yield, then you have 60 percent

09:46

21

fallout.

09:46

22

75 percent fallout.

23

other.

24
25

Q

If you have 25 percent yield, then you have
They're just the inverse of each

09:46
09:46

Got it.

09:46

And so in the manufacturing of the white

09:46

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version of the iPhone and -- and the white version of

09:47

2

the iPod Touch, was there more fallout with the cover

09:47

3

glass?

09:47

4
5
6

A

In the development phase, yes.

I don't know

what the production numbers are.
Q

And -- and so do you know if in the

09:47
09:47
09:47

7

production process that fallout issue with the glass,

09:47

8

with the white ink was -- was addressed or resolved?

09:47

9

A

I don't know.

09:47

10

Q

One of the other manufacturing issues that

09:48

11

you mentioned with respect to the white ink that's

09:48

12

used on the white version of the iPhone is that

09:48

13

laminating the touch sensor to the back of the glass

09:48

14

became more challenging; is that right?

09:48

15

A

Correct.

09:48

16

Q

And do you know how that issue was -- was

09:48

17

addressed?

09:48

18

A

Yes, yes.

09:48

19

Q

How was that issue addressed?

09:48

20

A

Changing the type of adhesive that's used and

09:48

21

the process that's used to laminate the touch sensor

09:48

22

to the glass.

09:48

23

Q

Were there any cost control issues related to

09:49

24

the white iPhone compared to the black version of the

09:49

25

iPhone?

09:49

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2

A

I know that it costs more to make a white one

than a black one.

09:49
09:49

3

Q

Do you know how much more?

09:49

4

A

No.

09:49

5

Q

Do you know why it costs more to make a white

09:49

6

version of the iPhone than a black version?

7

A

8

know.

9

Q

10
11
12

More ink process steps on the glass that I

I'm sorry.

More ink process steps on the

09:50
09:50

More layers of ink.

Just what we discussed

before, more -- and it costs more money.

13

09:50
09:50

glass?
A

09:50

And let's see.

One other would be -- I

09:50
09:50
09:50

14

mentioned the challenge in getting the white plastic

09:50

15

to not stain.

09:50

16

coating on top of the white plastic, and that painting

09:50

17

process costs money.

09:50

18
19
20

Q

One thing we do is paint a clear

And that's a step that doesn't take place

with the black version of the phone?
A

09:50

Correct.

09:50

I'm actually going to -- I'm going to correct

21

09:50

22

myself a little bit.

23

that painting process in production.

24

experimented it -- with it during development.

25

09:50

Q

I don't know if we actually used
I know that we

Any -- any other reasons that you're aware --

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that you're aware of that the white version of the

09:51

2

iPhone costs more than the black version?

09:51

3

A

Not that I can think of.

I think that the

09:51

4

other changes that we made aren't necessarily big cost

09:51

5

drivers, but I'm -- I'm not totally sure.

09:51

6

Q

So the main cost driver that you're aware of

09:51

7

is the -- the requirement to have more -- more ink

09:51

8

layers for the white ink than the black ink?

09:51

9

A

Correct.

09:52

10

Q

And does it cost more to make the white

09:52

11

version of the iPod Touch than the black version, for

09:52

12

these same reasons?

09:52

13

A

Yes, for -- specifically for the reason that

14

there are more layers of ink.

15

yeah, the only one I'm really sure about.

16

Q

That's one of them,

And do you know how much more it costs to

09:52
09:52
09:52
09:52

17

make a white version of the iPod Touch than a black

09:52

18

version?

09:52

19

A

I don't know exactly how much.

09:52

20

Q

Have you seen any documents that indicate

09:52

21

what the cost difference is between making a white

09:52

22

version of the iPod Touch than a black version?

09:52

23

A

Yes.

09:52

24

Q

And what -- what documents are those?

09:52

25

A

I don't remember the specific document

09:52

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that -- that has that, but I have seen that --

09:53

2

estimates of that price delta before.

09:53

3
4

Q

Do you recall any -- any of the documents

you've seen that estimate that price delta?

09:53
09:53

5

A

I don't recall which specific documents.

09:53

6

Q

So we had started down this path of

09:53

7

questioning when I'd asked you about technical issues

09:54

8

regarding the -- the iPhone that you were aware of.

09:54

9

And you listed for me a number of categories

09:54

10

of -- of those issues, and one of those categories was

09:54

11

issues brought about by trying to meet the -- the

09:54

12

industrial design.

09:54

13

And within that category, you mentioned a

09:54

14

couple of things, and one of them was the challenges

09:54

15

surrounding the white version of the iPhone, and

09:54

16

that's what we've -- we've just talked about.

09:54

17

One of the other issues in that category

09:54

18

was -- that you mentioned was issues around the home

09:54

19

button; do you recall that?

09:54

20

A

Yep.

09:54

21

Q

And what issue -- what issues around the home

09:54

22

button do you -- do you recall with respect to the

09:55

23

iPhone?

09:55

24
25

A

This is going to be boring, but white is less

opaque than black, and so you can see a shadow through

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the -- if we make a white button exactly the same way

09:55

2

we make the black button, in some cases you see a

09:55

3

shadow line through the -- through the button.

09:55

4

changed the structure of the button slightly to

09:55

5

address that.

09:55

6

And why did you need to -- so this is a --

09:55

7

this is a white version of the iPhone versus black

09:55

8

version of the iPhone issue as well?

09:55

9
10
11

Q

So we

A

Yes.

Specifically, my knowledge relates to

the white and black iPod Touch.
Q

Okay.

And so for the iPod Touch -- the white

09:55
09:56
09:56

12

version of the iPod Touch, to address the opacity

09:56

13

issue with respect to the white ink, you needed to

09:56

14

make some structural changes to -- to the home button;

09:56

15

is that correct?

09:56

16

A

Yes.

09:56

17

Q

And that's because you needed more layers

09:56

18
19

of -- of white ink on the home button area?
A

It's actually white plastic for the home

09:56
09:56

20

button, but we needed to keep the white plastic at

09:56

21

a -- at a minimum thickness.

09:56

22

And there are some -- some other cosmetic --

09:56

23

cosmetic issues related to having white parts, again,

09:56

24

like staining and -- it's easier to pick stuff out

09:56

25

with your eyes on a white better than it is on a black

09:56

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Q

2

resolved?

10:37

3

A

By alloy selection.

10:37

4

Q

And what was the -- the alloy selection?

10:37

5

A

I can't remember the specific alloy.

10:37

6
7
8

And how was that challenge addressed or

It's

just one of the many stainless steel alloys.
Q

Does -- does the bezel on the iPhone 3G and

3GS tie the housing together with the cover glass?

10:37

10:38
10:38
10:38

9

A

No.

10:38

10

Q

How -- how is the bezel on the iPhone 3G and

10:38

11

3GS different from the bezel on the original iPod

10:38

12

Touch in that respect?

10:39

13

A

On the original iPod Touch, the glass is

10:39

14

adhered to the bezel, and then the bezel is snapped

10:39

15

into the bottom housing.

10:39

16

aluminum.

17

The bezel is made out of

10:39

On the -- on the 3GS, the bezel and the

10:39

18

housing are glued together before the glass is

10:39

19

installed.

10:39

20

the bezel.

10:39

Q

10:39

21
22
23

Then the glass is not adhered directly to

On -- on the iPhone 3G and 3GS, does the

bezel help keep the glass in place?
A

10:39

10:39

25

I wouldn't say it's specifically designed to

would.

10:39

24

I can imagine some situations where it

do that.

10:39

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Q

Is -- is the -- is the bezel that's used with

10:39

2

the iPhone 3G and 3GS different from the bezel used on

10:39

3

the original iPhone?

10:39

4

A

It's different.

10:40

5

Q

How is it different?

10:40

6

A

Honestly, I'm not familiar enough with the

10:40

7

part -- I'm not familiar enough with the part to

10:40

8

answer that question in detail.

10:40

9

different part.

I know it is a

I don't even know if it's the same

10

alloy or a different alloy.

11

steel.

12

Q

I know they're both

10:40
10:40
10:40

Does the bezel on the iPhone 3G and 3GS help

10:40

13

prevent the edge of the cover glass from -- from

10:40

14

getting chipped?

10:40

15
16

A

I can imagine some situations in which it

would help.

10:40
10:40

17

Q

What situations would that be?

10:40

18

A

Were you to drop the phone at such an angle

10:40

19

that it impacted the bezel instead of the glass.

20

Q

21

true?

22

A

Any other situations where that would be

10:40
10:41
10:41

There are other things you could do to your

10:41

23

phone besides drop it where you would impact the bezel

10:41

24

before impacting the glass, and that would help reduce

10:41

25

chipping.

10:41

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2
3

Q

Does the bezel on the iPhone 3G and 3GS help

protect the -- the device from -- from impacts?
A

That's a -- that's a difficult question to

10:41
10:41
10:42

4

answer because inherently, anything on the outside of

10:42

5

the device could help protect the inside of the

10:42

6

device.

10:42

7

which situations, I don't know.

8
9

Whether the bezel specifically helps and in

Maybe you can be more specific about what
helps to protect means.

Are we talking about drop?

10:42
10:42
10:42

10

Are we talking about rain?

11

there's a lot of different protection -- types of

10:42

12

protection.

10:42

13

10:42

Protection from -- from the phone if it were

10:42

14

to be dropped or, you know, inadvertent -- you know,

10:42

15

some sort of inadvertent blow.

10:42

16

Q

Are we talking about --

A

Again, situations where the bezel ends up

10:42

17

between the -- some foreign object and the glass would

10:42

18

be situations where it was protecting, you could say.

10:43

19
20
21

Q

Can you think of instances where the bezel

would provide that kind of protection?
A

The -- the drop instance that I mentioned

10:43
10:43
10:43

22

before where you drop at such an angle that you impact

10:43

23

the bezel before the glass.

10:43

24
25

Maybe if you had the -- the phone in your
purse with a sharp object, like keys, and they hit the

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2

bezel before they hit the glass.
Q

10:43

What about if you, like, inadvertently bang

10:43

3

the phone against some sort of, you know, solid

10:43

4

object?

10:43

5

A

Yes, however you -- I mean, whether you're

10:43

6

dropping the phone or something is coming toward it,

10:43

7

if the bezel gets between the glass and that object,

10:43

8

it could serve as protecting.

10:43

9
10

Q

You said that the -- the bezel on the

10:44

iPhone 3G and 3GS has both -- both has -- strike that.

10:44

11

You said that the bezel on the iPhone 3G and

10:44

12

3GS has both a cosmetic and a functional part.

10:44

13

What -- what did you mean by that?

10:44

14

A

The cosmetic part means the part that the

10:44

15

user sees from the outside of the phone.

16

functional part means things like screw holes or

10:44

17

brackets or flanges that serve to keep the bezel

10:44

18

connected to the rest of the -- the rest of the phone.

10:44

19
20

Q

And the

Does the bezel on the iPhone 3G and 3GS

provide structural support for the -- for the device?

10:44

10:45
10:45

21

MR. OVERSON:

Objection; vague; foundation.

10:46

22

THE WITNESS:

When you say "structural

10:46

23

support," what -- what do you mean, structural

10:46

24

support?

10:46

25

MR. KIDMAN:

Q.

Is that -- is that -- you

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know, is that a term that you're familiar with?

10:46

2

A

Yes, but -- yeah, it is.

10:46

3

Q

What -- what's -- what's your understanding

10:46

4

of the term structural support when it's used in

10:46

5

connection with a device like -- like the iPhone?

10:46

6

A

Something that would, for example, protect

10:46

7

the display from deflection during a drop event, like

10:46

8

a frame.

10:46

Q

10:46

9

And -- and using that definition of the term

10

structural support, does the bezel on the iPhone 3G

10:46

11

and 3GS provide structural support for the device?

10:46

12

A

I don't think it protects the display from --

10:46

13

from deflection during drop.

14

it will contribute to the overall rigidity and

10:47

15

stiffness of the device.

10:47

16

Q

It is a stiff part, so

Is there some -- some level of stiffness or

10:46

10:47

17

rigidity that -- that you want to achieve with a

10:47

18

device like the -- like the iPhone?

10:47

19
20

A

Sometimes you want it to be stiff and

sometimes you don't.

10:47
10:47

21

Q

What -- what do you mean by that?

10:47

22

A

There are different events that the phone

10:47

23

will experience in the field where stiffness will be

10:47

24

either advantageous or disadvantageous.

10:47

25

Q

What are events where it would be

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have a kind of black stripe on the top and the bottom,

11:58

2

and that bottom black stripe is where the home button

11:58

3

sits.

11:58

4

Some of the designs didn't have that black

11:58

5

stripe.

6

top and bottom, less border on the top than bottom.

11:58

7

No home button at all.

11:58

8
9

Q

So it was mostly screen with no border on the

When you say some of these designs had no

11:58

11:58

black strip on the top or the bottom, when you say

11:58

10

black strip, is that sometimes what's called, at least

11:58

11

with respect to the iPhone, the black mask?

11:58

12

A

Yes, and I don't mean to say there was no

11:58

13

black mask at all, but there wasn't that kind of

11:58

14

thicker black mask at the top and the bottom.

11:58

15

Q

The black mask at the -- at the top and the

11:58

16

bottom was narrower than the black mask on the -- the

11:59

17

product that shipped?

11:59

18
19
20

A

Correct.

Narrower and more close in width to

the left and right sides.
Q

Any -- any other differences between the

11:59
11:59
11:59

21

design explorations you saw and the -- the design of

11:59

22

the device as it shipped, industrial design?

11:59

23

A

No.

11:59

24

Q

On those design explorations that you saw

11:59

25

where the black mask was narrower at the -- at the --

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at the top and at the bottom, in those design

12:00

2

explorations, was the -- was the screen larger to --

12:00

3

to fill that area?

12:00

4

A

I would say actually that the product was

12:00

5

shorter as opposed to the screen getting larger, so it

12:00

6

maintained that rectangular aspect ratio.

Just bring

12:00

7

in the whole product to make that black mass smaller.

12:00

8

Have you -- have you seen any design

12:00

explorations for any version of the -- the iPod Touch

12:00

10

where the screen runs all the way to the -- to the

12:00

11

edge of the -- the -- the front glass?

12:00

9

Q

12

A

Industrial designs?

12:00

13

Q

Yeah.

12:01

14
15

Let's -- let's start with -- let's

start with that.
A

12:01

The reason I'm distinguishing between them is

12:01

16

because there are things that they ask for that are

12:01

17

industrial designs that I've never seen a mechanical

12:01

18

design for, because sometimes they ask for certain

12:01

19

things we just don't know how to do the mechanical

12:01

20

design for.

12:01

21

Q

22

Okay.

But fair -- that's a fair distinction.

Have -- have you seen any industrial designs

12:01
12:01

23

of any version of the iPod Touch where the screen ran

12:01

24

all the way to the edge of -- of the top glass?

12:01

25

A

Yes.

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Q

Have you seen any mechanical designs where

12:01

2

the screen ran all the way to the edge of the top

12:01

3

glass?

12:01

4

A

No, not mature kind of shippable mechanical

5

designs, only crazy brainstorm ideas.

6

call a design, really.

7

Q

Okay.

Nothing I would

And are you aware of any reason why

12:01
12:01
12:01
12:01

8

those industrial designs where the screen ran all the

12:02

9

way to the edge of the top glass were not adopted?

12:02

10

A

Yes.

12:02

11

Q

And what are those reasons?

12:02

12

A

There's a -- with current display technology,

12:02

13

there is necessarily a border between where the active

12:02

14

region of the display ends and where the glass that

12:02

15

makes up the display ends.

12:02

16

So there's a dead zone, if you will, a border

12:02

17

around the display itself, and that's there because

12:02

18

there are a bunch of electrical traces running from

12:02

19

the top to the bottom.

12:02

20

The display is made of two pieces of glass

12:02

21

that need to be sealed together hermetically in order

12:02

22

for a normal LCD display to function properly, and so

12:02

23

there's some sort of overhead there that necessarily

12:02

24

creates a border so that the screen can actually run

12:02

25

to the very edge of the product.

12:02

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Q

And this border where the active region of

12:04

2

the display ends and where the glass that makes up the

12:04

3

display ends, is -- is there a name for that that --

12:04

4

that you've used or heard?

12:04

5

A

Actually, the border.

Yep, we call -- we

12:04

6

refer to them as border rules or border design rules,

12:05

7

and that every time we do a display, we look at how

12:05

8

much length will there be.

12:05

9

there be between the end of the active area and the

12:05

end of the physical display, the glass.

12:05

10
11
12
13
14
15

Q

How much distance will

And what's -- what's the size of that border

on the -- on the original iPod Touch?
A

Oh, I can't remember the exact number.

12:05
On

the order of 2 millimeters-ish.
Q

12:05

So is that border, that region where the

12:05
12:05
12:05

16

active region of the display ends and where the glass

12:05

17

of the display ends, is that different from the --

12:05

18

what we refer to as the "black mask"?

12:05

19

A

It is different from the black mask, yes.

12:05

20

Q

And in that border where the active region of

12:05

21

the display ends and where the glass makes up where

12:06

22

the display ends, is that sometimes called the "dead

12:06

23

pixel zone"?

12:06

24
25

A

That -- that's different.

12:06

So the dead pixels, also known as the

12:06

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viewable but not active area, make up part of the

12:06

2

border region.

12:06

3
4
5

Q

And what's the rest of that border region

made up of?
A

12:06
12:06

Metal traces that are right angles from the

12:06

6

top and bottom of the display, some glue area that

12:06

7

fills the two pieces of glass and the display are made

12:06

8

out of together, and some overhead to allow for the

12:06

9

manufacturing tolerance of cutting a piece of glass.

12:06

10

There may be some other things in there too.

12:06

11
12

Those are the big ones that I know about.
Q

Excuse me.

12:06

Other than what you've just described for me,

12:07

13

are you aware of any other reasons why any of these

12:07

14

industrial design explorations where the -- where the

12:07

15

display runs all the way to the edge of the glass were

12:07

16

-- were not adopted?

12:07

17

A

There will also be challenges around

12:07

18

protecting the display.

19

display stopped right at the edge of the active area

12:08

20

of the display, the display glass is not very strong,

12:08

21

so you wouldn't want to expose that to the outside

12:08

22

world.

You need to build some kind of cage around it.

12:08

And in the original iPod Touch that was

12:08

24

shipped, how would you describe that cage that's built

12:08

25

around the display?

12:08

23

Q

Even if the glass of the

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A

It's a -- there are a couple of aspects that

12:08

2

make up that cage.

3

kind of cradles the entire display and protects it

12:08

4

when the things are shifting around inside the product

12:08

5

in a catastrophic event, like a drop.

12:09

6

the housing creates part of that cage and it's

12:09

7

always -- always a challenge to try to use, you know,

12:09

8

the -- that does not -- the industrial design network,

12:09

9

we're kind of forced to be using it in a way that

12:09

10

will -- that we can take advantage of and actually

12:09

11

protect stuff that's inside the product.

12:09

12
13
14

One of them is a metal frame that

And then the --

So that would be part of the overall cage
around the display.
Q

And on the original iPod Touch that shipped,

12:08

12:09
12:09
12:10

15

that -- that -- what you described, the cage, is -- is

12:10

16

that the area that would be below the -- what we've

12:10

17

called the "black mask"?

12:10

18

Yes.

12:10

19

All of that cage area would be below the

12:10

20

black mask because the display is underneath the

12:10

21

covered glass.

12:10

22

display is -- has to be under the black mask.

23

A

Q

And so anything that's around the

12:10

And so that -- that cage that's -- that's

12:10

24

built around the display is -- if I'm holding the

12:10

25

phone and looking at the front face, I would not see

12:10

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that cage, because it's concealed by the black mask?
A

12:10
12:10

You wouldn't see that, that cage, because

3

Correct.

12:10

4

it's concealed by the black mask from the top, and the

12:10

5

rest of the cosmetic part of enclosure from the --

12:10

6

from the sides and bottom.

12:10

7

Q

You said that some of the design explorations

12:11

8

that you saw for the original iPad Touch were thicker

12:11

9

than the version that actually shipped; correct?

12:11

10

A

Yes.

12:11

11

Q

And do you -- do you know why those thicker

12:11

12
13

design explorations were not adopted?
A

I know one of the reasons.

12:12

One of them is

12:12

14

that we were considering putting a component inside

12:12

15

the iPod Touch that required more space.

12:12

16

not to put that component inside the iPod Touch.

12:12

17

That's one thing that enabled us to make it thinner.

12:12

We decided

18

Q

What was that component?

12:12

19

A

A hard drive.

12:12

20

Q

And so because that component was not used,

12:12

21

you were able to make the form factor of the version

12:12

22

that shipped thinner?

12:13

23

A

Correct.

12:13

24

Q

Why didn't -- why didn't you just keep the

12:13

25

same thickness?

Even though -- even though that

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component wasn't used, why didn't you just keep it --

12:13

2

keep it the same thickness?

12:13

3

A

Because it -- because it looks nicer when

12:13

4

it's thinner.

5

team will push us to make products as thin as

12:13

6

possible, even though there are some exceptions to

12:13

7

that.

12:13

8

Q

What are -- what would those exceptions be?

12:13

9

A

So having -- having rounded corners on the

12:13

So in general, the industrial design

12:13

10

top or having a curve on the bottom housing creates

12:13

11

challenges to making the product its absolute

12:13

12

thinnest.

12:13

13

So there are some tradeoffs there, and the

12:13

14

reason is that basically, all of the things that we're

12:13

15

trying to fit inside of these products are rectangles.

12:13

16

And fitting a bunch of rectangles inside a rectangle

12:13

17

is more efficient than -- than fitting a bunch of

12:13

18

rectangles inside an amorphous shape.

12:14

19

Think of it kind of like a Tetris game.

If

12:14

20

you had some curved -- some curved outside instead of

12:14

21

a flat bottom, it would be much more difficult to pack

12:14

22

the pieces in efficiently.

12:14

23

So in the case of, you know, the iPod Touch,

12:14

24

the generation after that, it has a curved bottom, and

12:14

25

it's actually thicker, and that was a tradeoff.

12:14

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Q

Do you recall anything further that they said

in response to that design option?

14:40
14:40

3

A

No.

14:40

4

Q

Was it a short conversation?

14:40

5

A

Yes.

14:40

6

Q

Do you recall who expressed the view that it

14:40

7

didn't look or feel nice?

8
9
10
11
12
13
14

A

14:40

I -- I don't recall exactly who said that,

no.

14:40
14:40

Q

Was it more than one person who expressed

that view?
A

14:40

I believe so, yes.

It was pretty -- it was a

clear -- a clear "no" from the team -- the ID team.
Q

14:40

And other than saying that they didn't like

14:40
14:40
14:40

15

the way that it looked -- well, other than saying that

14:40

16

it didn't look or feel nice, do you recall any -- in

14:40

17

any more detail what their reaction was?

14:40

18

They're a very polite group of individuals,

14:41

19

and they probably thanked us for doing the work and

14:41

20

showing them the data.

14:41

21
22

A

Q

Do you have any understanding as to what was

meant when they said it didn't feel nice?

14:41
14:41

23

A

Yes.

14:41

24

Q

And what's your understanding in that regard?

14:41

25

A

When you run your finger over the transition

14:41

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between the glass and the -- the housing or bezel or

14:41

2

bumper or whatever around it, that that didn't feel

14:41

3

nice.

14:41

4

Q

It didn't feel good.
Do you have any understanding one way or

14:41

5

another as to whether the design where the cover glass

14:41

6

was sub-flush to the edge of the device would be more

14:41

7

difficult to clean than design -- the design where the

14:42

8

cover glass was flush with the edge of the device?

14:42

9
10

A

I don't specifically know that to be true,

but intuitively, I understand what you're suggesting.

14:42
14:42

11

Q

What do you mean by that?

14:42

12

A

I understand that it could be more difficult

14:42

13

to clean a device that had something set in from some

14:42

14

raised edges because you would collect stuff,

14:42

15

anything, in that -- in that corner created by the new

14:42

16

raised edge.

14:42

17

Q

So intuitively, that makes some sense to you?

14:42

18

A

Yes.

14:42

19

Q

Have you seen any designs of any version of

14:42

20

the iPhone where the cover glass sat either proud to

14:42

21

the edge of the device or sub-flush to the edge of the

14:43

22

device?

14:43

23

A

Yes.

14:43

24

Q

And -- and in what context have you seen

14:43

25

those designs?

14:43

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A

Models in the industrial design studio, and

14:43

2

models that the PD team has created based off of those

14:43

3

designs from the industrial design team.

14:43

4

Q

And are you aware of any drop testing that

14:43

5

was done on those designs of the iPhone where the

14:43

6

cover glass sat proud of the edge and sub-flush to the

14:43

7

edge of the device?

14:43

8
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A

Proud -- can you rephrase.

Sorry.

It can't

be proud and sub-flush.
Q

Yeah, let me -- so to clarify, have you seen

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design -- iPhone designs where the cover glass sat

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proud to the edge of the device?

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A

Yes.

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Q

And have you also seen iPhone designs where

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the cover glass sat sub-flush to the edge of the

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device?

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A

No, I haven't seen designs like that.

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Q

Okay.

Have you seen any drop testing for the

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iPhone designs where the cover glass sat proud to the

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edge of the device?

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A

Yes.

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Q

And have you had any involvement in those

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drop tests?

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A

Yes.

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Q

And what was your involvement in those drop

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