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 4
Highly Confidential - Outside Counsel's Eyes Only
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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
O U T S I D E C O U N S E L O N L Y
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VIDEOTAPED DEPOSITION OF CHRISTOPHER STRINGER
REDWOOD SHORES, CALIFORNIA
FRIDAY, NOVEMBER 4, 2011
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BY: ANDREA M. IGNACIO HOWARD, CSR, RPR, CCRR, CLR
CSR LICENSE NO. 9830
TSG JOB NO. 43706
TSG Reporting - Worldwide
(877) 702-9580
Highly Confidential - Outside Counsel's Eyes Only
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themselves for the record.
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MR. ZELLER:
Mike Zeller for Samsung.
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MR. JACOBS:
Michael Jacobs from Morrison &
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Foerster for Apple.
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Apple Legal.
With me is Cyndi Wheeler from
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THE VIDEOGRAPHER:
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Will the reporter please swear the witness.
Thank you.
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CHRISTOPHER STRINGER,
having been sworn as a witness,
by the Certified Shorthand Reporter,
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testified as follows:
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THE VIDEOGRAPHER:
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Please proceed.
Thank you.
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EXAMINATION BY MR. ZELLER
MR. ZELLER:
Let's please mark as
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Exhibit 1161 the Reply Declaration of Christopher
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Stringer in Support of Apple's Motion for Preliminary
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Injunction.
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(Document marked Exhibit 1161
for identification.)
MR. ZELLER:
Q.
Please let me know when
you've reviewed 1161.
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collection of field CAD drawings.
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(Document marked Exhibit 1172
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for identification.)
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THE WITNESS:
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MR. ZELLER:
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Okay.
Q.
Do you recognize anything
that's depicted here in Exhibit 1172?
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A
Yes.
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Q
What do you recognize these as?
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A
I recognize an exercise that Shin Nishibori
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worked on.
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indicate it was in '06, March of '06.
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Q
I do not recall when, but the dates would
And even though you don't recall, as you've
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said, is there any reason for you to think it was not
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in the 2006 time period?
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A
No.
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Q
Did you work on this project yourself?
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A
This is an exercise.
I see that as distinct
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from a project.
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abstract portion of a project, that being the iPhone.
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Q
It could be considered as to be some
I'm happy to call it either.
So just so we
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have -- we understand we're talking about the same
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thing.
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on this design work that was done that pertained in
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particular to these designs that are shown here in
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Exhibit 1172 with the name Sony on it, can you please
So whether it's exercise or project, focusing
TSG Reporting - Worldwide
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Highly Confidential - Outside Counsel's Eyes Only
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tell me generally what that -- what the purpose of
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that was.
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A
It was a -- just a fun exercise where Shin
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made an object resembling an iPhone that would --
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almost in a role-playing kind of way, what would Sony
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do if they were us?
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Q
Do you have an understanding -- and that's
the reason why Sony is -- is on this?
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A
Yeah.
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Q
Do you know who came up with the idea for
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It was fun.
this exercise?
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A
I do not recall.
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Q
Did you yourself prepare any designs or
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drawings that was part of this exercise?
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A
No.
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Q
Do you know if anyone other than
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Mr. Nishibori did?
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A
No.
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Q
Generally speaking, I take it you recognize
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the images here in Exhibit 1172 as filled in CAD
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drawings?
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A
Rendered, shaded, yes.
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Q
And do you know were any three-dimensional
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models created as part of the exercise that we're
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talking about?
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A
I believe so, but I am not absolutely
certain.
Q
Generally speaking, do you have a memory
of -- of seeing some kind of model or model number?
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A
Not sufficiently clear.
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Q
You're just not sure?
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A
Uh-huh.
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Q
I'm sorry.
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A
Yes.
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Q
Yeah.
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I can't recall.
You need to give an audible --
Okay.
Is there anything else that you remember
generally about this exercise?
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A
No.
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Q
Let me show you what was previously marked as
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Exhibit 751, which is a copy of United States design
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patent 622,270.
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A
Yes.
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Q
Do you recognize the '270 design patent as a
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design patent that you're a named inventor on?
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A
Yes.
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Q
And, generally speaking, do you recognize
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what -- what product or object is depicted here?
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A
The iPod Touch.
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Q
Was this the first iPod Touch?
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A
I think so.
Yes, I believe that is the case.
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J U R A T
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I, CHRISTOPHER STRINGER, do hereby certify
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under penalty of perjury that I have read the
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foregoing transcript of my deposition taken
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on November 4, 2011; that I have made such
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corrections as appear noted herein in ink,
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initialed by me; that my testimony as
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contained herein, as corrected, is true and
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correct.
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DATED this ____ day of _____________, 2011,
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at _____________________________, California.
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__________________________________
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SIGNATURE OF WITNESS
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CERTIFICATE OF REPORTER
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I, ANDREA M. IGNACIO HOWARD, hereby certify
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that the witness in the foregoing deposition was by me
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duly sworn to tell the truth, the whole truth, and
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nothing but the truth in the within-entitled cause;
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That said deposition was taken in shorthand
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by me, a Certified Shorthand Reporter of the State of
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California, and was thereafter transcribed into
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typewriting, and that the foregoing transcript
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constitutes a full, true and correct report of said
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deposition and of the proceedings which took place;
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That I am a disinterested person to the said
action.
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IN WITNESS WHEREOF, I have hereunto set my
hand this 4th day of November 2011.
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_______________________________________
ANDREA M. IGNACIO HOWARD, RPR, CCRR, CLR, CSR No. 9830
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TSG Reporting - Worldwide
(877) 702-9580
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