Apple Inc. v. Samsung Electronics Co. Ltd. et al
Filing
1429
OPPOSITION to ( 1420 MOTION TO ENFORCE COURT ORDERS REGARDING SONY DESIGNS ) filed by Samsung Electronics America, Inc.(a New York corporation), Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC(a Delaware limited liability company). (Attachments: # 1 Declaration of Curran M. Walker, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Exhibit 6, # 8 Exhibit 7, # 9 Exhibit 8, # 10 Exhibit 9, # 11 Exhibit 10, # 12 Exhibit 11, # 13 Exhibit 12, # 14 Exhibit 13)(Maroulis, Victoria) (Filed on 7/28/2012) Modified text on 7/30/2012 (dhm, COURT STAFF).
EXHIBIT 9
Confidential Business Information Pursuant to Protective Order
Page 1
1
UNITED STATES INTERNATIONAL TRADE COMMISSION
2
WASHINGTON, D.C.
3
4
5
In the Matter of:
6
CERTAIN ELECTRONIC DIGITAL
MEDIA DEVICES AND COMPONENTS
7
Inv. No.
337-TA-796
THEREOF
____________________________/
8
9
10
11
CONFIDENTIAL BUSINESS INFORMATION
12
PURSUANT TO THE PROTECTIVE ORDER
13
14
15
VIDEOTAPED DEPOSITION OF DOUGLAS SATZGER
16
SAN FRANCISCO, CALIFORNIA
17
THURSDAY, FEBRUARY 9, 2012
18
19
20
21
22
23
BY:
24
CSR LICENSE NO. 9830
25
JOB NO. 45787
ANDREA M. IGNACIO HOWARD, CSR, RPR, CCRR, CLR
TSG Reporting - Worldwide
(877) 702-9580
Confidential Business Information Pursuant to Protective Order
Page 6
1
MR. ZELLER:
2
MR. HALL:
3
MR. DAVIS:
4
MR. HUNG:
5
THE WITNESS:
6
THE VIDEOGRAPHER:
7
Will the court reporter please administer the
8
Mike Zeller for Samsung.
Scott Hall for Samsung.
Derek Davis here for the witness.
Richard Hung for Apple.
Doug Satzger.
Thank you.
oath, and we may proceed.
9
10
DOUGLAS SATZGER,
11
having been sworn as a witness
12
by the Certified Shorthand Reporter,
13
testified as follows:
14
15
EXAMINATION BY MR. ZELLER
16
MR. ZELLER:
Q.
Good morning.
17
A
Good morning.
18
Q
If you could please state your full name for
19
the record.
20
A
Douglas Bernard Satzger.
21
Q
And where do you currently reside?
22
A
California, Menlo Park.
23
Q
And are you currently employed?
24
A
Yes.
25
Q
What's your current job?
TSG Reporting - Worldwide
(877) 702-9580
Confidential Business Information Pursuant to Protective Order
Page 193
1
you're referring to?
2
A
Yes.
3
Q
And then if you take a look at Exhibit 2,
4
you'll see that there are a couple of more pages of
5
CAD drawings, as well as a file listing.
6
A
Yes.
7
Q
And then with respect to those two pages of
8
CAD images that are a part of Exhibit 2, do you also
9
recognize those as early iterations of the mobile
10
phone?
11
A
Yes.
12
Q
And I take it at some point the decision was
13
made not to go with the -- the design or the -- the
14
hardware that's shown here in Exhibits 1 and 2?
15
A
Yes.
16
Q
And -- and why -- what was the -- the reason
17
for that --
18
MR. HUNG:
19
MR. ZELLER:
20
MR. HUNG:
21
THE WITNESS:
Objection.
Q.
-- this change in direction?
Objection; foundation.
My recollection of it was that
22
to get the extruded aluminum design that was applied
23
to the iPod to work for the iPhone, there were too
24
many added features to allow it to be comfortable and
25
to work properly.
TSG Reporting - Worldwide
(877) 702-9580
Confidential Business Information Pursuant to Protective Order
Page 194
1
2
3
MR. ZELLER:
Q.
And if you can please tell
me what you mean by that?
A
If you put an iPod up to your ear, the sharp
4
edges, because of the processes, aren't comfortable,
5
and you can't get antennas to work properly in a fully
6
enclosed metal jacket.
7
So each one of those things needed to apply
8
other features that started.
9
the initial concept compared to this one, there's a
10
lot more features than this, and there's a lot more
11
parts so...
12
Q
I mean, if you look at
And so as a result, this phone design shown
13
in Exhibits 1 and 2 that we're talking about here to
14
the Stringer declaration would be more complicated to
15
manufacture, more prone to break, and all the other
16
kinds of disadvantages that having a more complex
17
product involved?
18
MR. HUNG:
19
20
21
22
Objection; calls for expert
opinion; mischaracterizes prior testimony.
THE WITNESS:
I -- from a design point of
view, it was a lot more challenging.
MR. ZELLER:
Q.
And from your understanding,
23
is having a more complicated product of that kind also
24
more challenging or expensive from a manufacturing
25
standpoint"?
TSG Reporting - Worldwide
(877) 702-9580
Confidential Business Information Pursuant to Protective Order
Page 195
1
2
MR. HUNG:
hypothetical; calls for an expert opinion.
3
4
Objection; vague; incomplete
MR. ZELLER:
Q.
standpoint?
5
MR. HUNG:
6
THE WITNESS:
7
Same objections.
I can't -- no, I wouldn't say
so.
8
9
Or from a reliability
MR. ZELLER:
Q.
You just don't know one way
or another?
10
A
I don't know, yes.
11
Q
And when you say from a design point of view
12
it was a lot more challenging, it was for those
13
reasons you mentioned earlier?
14
15
MR. HUNG:
Objection; vague; asked and
answered; mischaracterizes.
16
THE WITNESS:
17
MR. ZELLER:
Yes.
Q.
And you mentioned that it
18
was more difficult to get the antenna, for example, to
19
work in a fully enclosed jacket of the kind that's
20
shown here in Exhibits 1 and 2?
21
A
Yes.
22
Q
Do you recall, was there testing that you saw
23
or that you heard about being done that -- that backed
24
that up?
25
A
Yes.
TSG Reporting - Worldwide
(877) 702-9580
Confidential Business Information Pursuant to Protective Order
Page 196
1
Q
And then also you mentioned that another
2
aspect of this design that was shown in Exhibits 1 and
3
2 to the Stringer declaration is, is that by having
4
those sharper edges, it's just not as comfortable up
5
against the user's ear?
6
A
Yes.
7
Q
Were there other reasons why this was not as
8
comfortable from the -- the user perspective?
9
MR. HUNG:
Objection; vague; foundation.
10
THE WITNESS:
11
MR. ZELLER:
Not that I recall.
Q.
And I take it that people
12
within industrial design thought that -- that lack of
13
comfort, having something with the sharp edges up to
14
someone's ear or up next to their head was a -- was a
15
reason not to go with this design?
16
17
MR. HUNG:
Objection; foundation; calls for
speculation.
18
THE WITNESS:
I think that the solutions that
19
lent themselves to make it more comfortable were not
20
good for the overall design, the extruded shape.
21
MR. ZELLER:
Q.
And what were those -- those
22
solutions or potentially solu- -- potential solutions
23
you're referring to?
24
25
A
If you look at the -- there's no number on
this page, but under Exhibit 2, the second page of
TSG Reporting - Worldwide
(877) 702-9580
Confidential Business Information Pursuant to Protective Order
Page 197
1
images where all the images are, the parts on top and
2
bottom have a radius on them.
3
design point of view, detracts a lot from why you use
4
those materials and what the intent was originally.
And those, from a
5
If you look at the first exhibit, those edges
6
are sharp, which represents the manufacturing process
7
that we were familiar with with doing the iPods, and
8
the design intent was that you -- you cut and you put
9
a few holes into a metal extrusion without doing too
10
much to it, you know.
11
From my point of view, the first design is
12
actually very nice.
13
overworked.
14
15
So Steve did not like the solutions.
MR. ZELLER:
Q
The second design is way
And I see.
So if I -- Exhibit 1 represents at least one
16
iteration of the design and then Exhibit 2 shows
17
further revisions to that design --
18
A
Yes.
19
Q
-- that were made in order to try and address
20
these issues you were talking about in terms of
21
comforts and -- and having the antenna work --
22
A
Uh-huh.
23
Q
-- is that right?
24
A
Yes.
25
Q
And then once you got to, and you and the
TSG Reporting - Worldwide
(877) 702-9580
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?