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

Filing 1438

Declaration of ALISON M. TUCHER in Support of 1420 MOTION to Enforce Court Orders Regarding Sony Designs filed by Apple Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C)(Related document(s) 1437 ) (Jacobs, Michael) (Filed on 7/29/2012) Modified text on 7/30/2012 (dhm, COURT STAFF).

Exhibit B

Confidential Business Information
Highly Confidential Attorney's Eyes Only

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UNITED STATES INTERNATIONAL TRADE COMMISSION
Washington, D.C.
In the Matter of
)
)
CERTAIN ELECTRONIC DIGITAL )
Inv. No. 337-TA-796
MEDIA DEVICES AND
)
COMPONENTS THEREOF
)
)

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION
APPLE INC., a California
) CIVIL NO. 11-CV-01846-LHK
corporation,
)
)
Plaintiff,
)
)
vs.
)
)
SAMSUNG ELECTRONICS CO.,
)
LTD., a Korean business
)
entity; SAMSUNG ELECTRONICS )
AMERICA, INC., a New York
)
corporation; and SAMSUNG
)
TELECOMMUNICATIONS AMERICA, )
LLC, a Delaware limited
)
liability company,
)
)
Defendants.
)
)

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CONFIDENTIAL BUSINESS INFORMATION
HIGHLY CONFIDENTIAL ATTORNEYS' EYES ONLY
VIDEOTAPED DEPOSITION OF SHIN NISHIBORI
MAY 2, 2012
HONOLULU, HAWAII
TSG JOb # 49110
Reporter: ADRIANNE IGE KURASAKI
TSG Reporting - Worldwide

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INTERPRETED ANSWER: Yes, it was a very 10:37AM
short time period because I was doing this on 10:37AM
the side of my project. So the idea itself was 10:37AM
about two days. And I worked with Carlos for 10:37AM
the drawing rendering. And so would be two
10:38AM
weeks. So if it's longer than this, it was
10:38AM
around two weeks that it took.
10:38AM
BY MR. ZELLER:
10:38AM
Q And was the March of 2006 time period 10:38AM
when you began working on this design idea here? 10:38AM
A I do not remember specific dates. I do 10:38AM
not remember.
10:38AM
THE CHECK INTERPRETER: "To that
10:38AM
extent."
10:38AM
BY MR. ZELLER:
10:38AM
Q Is it fair to say that you recall first 10:38AM
coming up with the idea for the design and then 10:38AM
working very soon thereafter on these designs 10:38AM
that are in Exhibit 1?
10:38AM
(The Check Interpreter speaks in Japanese.) 10:39AM
MS. TAYLOR: Objection. Vague.
10:39AM
Translate.
10:39AM
(Whereupon, the Interpreter translates.) 10:39AM
INTERPRETED ANSWER: Well, may I explain 10:39AM
how the direction of this process -- rather, may 10:40AM

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I explain how this idea came out?
10:40AM
BY MR. ZELLER:
10:40AM
Q Please.
10:40AM
A First, Jonathan Ive talked to me.
10:40AM
"Well, Shin, I have something to talk to you
10:40AM
about."
10:40AM
And he said, "You can just do this on
10:41AM
your side of your job. Just relax and enjoy
10:41AM
doing this. But can you start -- can you try
10:41AM
working on to create something that represents 10:41AM
something that if Sony attempts to create an
10:41AM
iPhone."
10:41AM
That's what he told me. But because of 10:41AM
my English, I'm not sure if I clearly understood 10:41AM
him. But this was what I understood.
10:41AM
THE CHECK INTERPRETER: Proposed
10:41AM
correction: "He said, 'You can do this as an
10:41AM
aside of your job and enjoy -- I want you to
10:42AM
enjoy doing this. But if Sony were to make an 10:42AM
iPhone, what would it be like? Would you make 10:42AM
it for me?' And because my English -- because 10:42AM
of my English, I'm not sure if I clearly
10:42AM
understood him, but this is what I understood." 10:42AM
THE INTERPRETER: May the interpreter
10:42AM
ask the witness to repeat his answer again?
10:42AM

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INTERPRETED ANSWER: Your question, your 10:43AM
last question is about did you come up with an 10:43AM
idea and started with this. However, I'd like 10:43AM
to say that it came -- first came from Jonathan 10:43AM
Ive -10:43AM
THE INTERPRETER: I'm sorry. Strike
10:43AM
that.
10:43AM
INTERPRETED ANSWER: Your last question 10:43AM
was about did you come up with an idea and then 10:43AM
started the project and then did the rendering 10:43AM
or CAD. But it's not. I'd like to say that it 10:43AM
came from Jonathan Ive first and then I came up 10:43AM
with an idea and it started then.
10:43AM
MS. TAYLOR: Were you correcting your 10:44AM
interpretation or did he strike his answer?
10:44AM
THE INTERPRETER: Yes, I said -- when 10:44AM
the Interpreter said "strike that," the
10:44AM
interpreter was correcting the entire
10:44AM
interpretation, yes. So anything after "strike 10:44AM
that" is my interpretation.
10:44AM
MR. ZELLER: The witness didn't say
10:44AM
"strike that"?
10:44AM
THE INTERPRETER: No.
10:44AM
BY MR. ZELLER:
10:44AM
Q So just so we have a clear understanding 10:44AM

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TSG Reporting - Worldwide

of this, so as you understood the conversation 10:44AM
you had with Mr. Ive, Mr. Ive was the one who 10:44AM
came up with the idea to say what would Sony do. 10:44AM
And that was the project that you started on? 10:44AM
(The Check Interpreter speaks in Japanese.) 10:44AM
INTERPRETED ANSWER: Well, it is not
10:45AM
that Jony came up with specific design idea to 10:45AM
me. But we did have a conversation and this is 10:45AM
what Jony said. And there's not -- what I just 10:45AM
told you is all, everything. And there's
10:45AM
nothing other than that.
10:45AM
BY MR. ZELLER:
10:45AM
Q Let me try it this way: Mr. Ive gave 10:45AM
you the general direction to work on an idea for 10:46AM
what Sony would do and then you came up with the 10:46AM
specific design idea?
10:46AM
A Right. I do not know who had the
10:46AM
original idea. But it is true that the
10:46AM
direction came from Ive. He asked me to make 10:46AM
something -- he request me -- requested me to 10:47AM
make something like that. So, yes, that's true. 10:47AM
THE CHECK INTERPRETER: "And then I went 10:47AM
forward with it."
10:47AM
BY MR. ZELLER:
10:47AM
Q And then what you did, in terms of
10:47AM

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chance to look at the images in Exhibit 2.
10:57AM
A Okay.
10:57AM
Q Do you recognize what these images are? 10:57AM
(The Check Interpreter speaks in Japanese.) 10:57AM
INTERPRETED ANSWER: Hai.
10:57AM
BY MR. ZELLER:
10:57AM
Q Please tell us what you recognize them 10:57AM
as.
10:57AM
A It is -- these are renderings that I
10:57AM
created based on my own thoughts or my
10:57AM
understanding of Sony-like designs -- Sony's
10:57AM
design, based on the request of Jonathan Ive.
10:58AM
Q And then when we looked at Exhibit 1, we 10:58AM
saw that there were some file dates for March of 10:58AM
2006.
10:58AM
(The Check Interpreter speaks in Japanese.) 10:58AM
THE CHECK INTERPRETER: The witness
10:58AM
said, "Yes."
10:58AM
MR. ZELLER: Give me the translation.
10:58AM
THE INTERPRETER: Sorry.
10:58AM
INTERPRETED ANSWER: Yes.
10:58AM
BY MR. ZELLER:
10:58AM
Q Do you recall whether or not the
10:58AM
renderings in Exhibit 2 were done at the same
10:58AM
time as these renderings in Exhibit 1 or were
10:58AM

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they done later on?
10:58AM
A In my recollection, the ones listed here 10:59AM
from one, two, three, four, five, six, seven,
10:59AM
are the ones here, listed as jpegs here.
10:59AM
Q So you think these are the same images? 10:59AM
A I think they are the same.
10:59AM
Q And I take it that the Sony-like designs 10:59AM
that were done in CAD form that you worked on
10:59AM
with the CAD operator, were they on Apple's CAD 10:59AM
system?
10:59AM
MS. TAYLOR: Objection. Vague.
11:00AM
INTERPRETED ANSWER: Well, I'm not too 11:00AM
sure about what you're referring to as "CAD
11:00AM
system," whether you're calling it as the
11:00AM
software company. If you're asking about the
11:00AM
location of CAD system and Apple -11:00AM
MS. TAYLOR: Wait, wait.
11:01AM
THE CHECK INTERPRETER: She's not done. 11:01AM
INTERPRETED ANSWER: -- then it is.
11:01AM
THE CHECK INTERPRETER: "If you're
11:01AM
asking about the location of the CAD system at 11:01AM
Apple company, if that's where it was made,
11:01AM
then, no doubt, it was made there."
11:01AM
BY MR. ZELLER:
11:01AM
Q Was the -- were these CAD images on any 11:01AM

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other computer there at Apple, like your own
11:01AM
computer that you know of, other than the CAD
11:01AM
operator's computer?
11:01AM
I'm sorry. Let me withdraw that.
11:01AM
THE INTERPRETER: Yes, I'm so sorry.
11:01AM
If the interpreter may ask for a few minutes of 11:01AM
break, that would be wonderful.
11:01AM
MR. ZELLER: Sure. Absolutely. Yeah. 11:01AM
We'll do that.
11:01AM
THE VIDEOGRAPHER: Off the record. It's
11:02 a.m.
(A recess was taken from 11:02 a.m. to 11:11 a.m.)
THE VIDEOGRAPHER: This will be the
11:11AM
start of Tape No. 2. We are on the record. It 11:11AM
is now 11:12 a.m.
11:12AM
BY MR. ZELLER:
11:12AM
Q Focusing your attention on the CAD
11:12AM
renderings that we've marked as Exhibits 1 and 11:12AM
2. Do you know what computers those CAD images 11:12AM
were on?
11:12AM
A I'm sorry, this is what Carlos did, so 11:12AM
the only knowledge that I have is that was done 11:12AM
by -- or on Carlos' computer.
11:12AM
Q Do you remember whether those CAD images 11:12AM
were ever on your computer?
11:13AM

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TSG Reporting - Worldwide

A For this picture -- well, I had the need 11:13AM
to send these pictures to Jonathan Ive, who was 11:13AM
on business trip, by e-mail. So I incorporated 11:13AM
those pictures into my computers. However, it 11:13AM
was not the CAD image. It was on jpeg.
11:14AM
Q So there were jpeg images of the CAD
11:14AM
renderings that were made and then you e-mailed 11:14AM
those to Mr. Ive?
11:14AM
A Right.
11:14AM
Q Were any of those jpeg images the ones 11:14AM
that are here in Exhibit 2?
11:14AM
A Yes, these are the ones that was sent to 11:14AM
him.
11:14AM
Q Are they all of the jpegs?
11:14AM
A I'm not sure if it's all.
11:14AM
Q Let me try it this way: Of the jpegs 11:15AM
that you sent, do you recognize these as being 11:15AM
the jpegs that you sent, all of these pages?
11:15AM
A I'd like to confirm, what do you mean 11:15AM
"sent," mean to sent to Jonathan Ive; correct? 11:15AM
Q Right.
11:15AM
A It was very difficult to send everything 11:16AM
by e-mail, so I'm sure I selected some and
11:16AM
omitted some and sent it to him by e-mail.
11:16AM
I believe that the ones I sent to him 11:16AM

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was the one -- were the ones that could show
11:16AM
details. Because as -- the details, for
11:16AM
example, the buttons and switches, are the ones 11:17AM
that I had represented Sony's image to express. 11:17AM
That is why.
11:17AM
Q So if I understand correctly, with
11:17AM
respect to the images in Exhibit 2, you sent at 11:17AM
least some subset of them to Mr. Ive as jpegs? 11:17AM
A Yes.
11:17AM
Q And I take it when you sent that, you
11:17AM
did a cover e-mail that went with the images?
11:17AM
A Not in my recollection.
11:18AM
Q When you say not in your recollection, 11:18AM
you just sent -- how did you transmit them to
11:18AM
Mr. Ive?
11:18AM
A In my recollection, it was quite simple, 11:19AM
addressed to Jony, and it was about -- it was
11:19AM
regarding Sony and I came up with a rendering, 11:19AM
please take a look at it. It was a very simple 11:19AM
paragraph. And I selected some pictures out of 11:19AM
it and then I put it onto the mail application 11:19AM
and sent it off to him.
11:19AM
Q If I understand then correctly, you
11:19AM
attached at least some of these images as jpegs 11:19AM
to an e-mail that you sent to Mr. Ive over
11:19AM

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Apple's e-mail system?
11:19AM
A Yes, that's correct.
11:20AM
Q And then your e-mail had the text that 11:20AM
you described?
11:20AM
A Yes. Yes.
11:20AM
Q Do you remember, was anyone other than 11:20AM
yourself and Mr. Ive on this e-mail?
11:20AM
A Well, it's not clear. I'm on -- I had a 11:20AM
direct communication with Jonathan Ive only and 11:21AM
I was really doing this on the side, so I do not 11:21AM
think so. But this is -- maybe.
11:21AM
Q Do you remember one way or another?
11:21AM
A Yes.
11:21AM
THE INTERPRETER: The interpreter will 11:21AM
repeat the question.
11:21AM
INTERPRETED ANSWER: Are you asking who 11:21AM
was in or who was not in?
11:21AM
MR. ZELLER: Well, I'm just trying to 11:21AM
make sure I understand your last answer.
11:21AM
If you could translate.
11:21AM
(Whereupon, the Interpreter translates.) 11:21AM
INTERPRETED ANSWER: If I answer
11:21AM
clearly, I do not know.
11:21AM
BY MR. ZELLER:
11:21AM
Q That's what I wanted to make sure is you 11:21AM

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just don't have a clear memory one way or
11:22AM
another whether anyone else was on the e-mail? 11:22AM
A Yes. But one thing I'd like to point
11:22AM
out is that nobody was on this project -11:22AM
rather, it's not a project. It is a Sony thing. 11:22AM
Sony story.
11:23AM
Nobody else was involved. So I just
11:23AM
assumed that nobody else is involved or heard
11:23AM
anything or involved in the e-mail. But I
11:23AM
didn't really -- I do not really see the actual 11:23AM
e-mail myself, so I don't -- I can't answer
11:23AM
hundred percent.
11:23AM
Q Did you actually type up the e-mail to 11:23AM
Mr. Ive and send it to him or did someone else 11:23AM
do that?
11:23AM
A Myself. I did it myself.
11:23AM
Q Do you recall about how much time passed 11:23AM
between the time you got the general direction 11:23AM
from Mr. Ive to do this work and then when you 11:23AM
came up with these CAD images that are
11:23AM
Exhibits 1 and 2?
11:23AM
A Yes. Yes, from the idea to the
11:24AM
completion of the sketch, it probably took
11:24AM
between one week to ten days. I would say less 11:24AM
than ten days.
11:24AM

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TSG Reporting - Worldwide

And the reason is that -- that I was
11:25AM
trying to accelerate the process was that
11:25AM
Jonathan Ive was on business trip and I wanted 11:25AM
to finish creating the model before he returns. 11:25AM
So I was sending him e-mails and then I -- and 11:25AM
then I got his confirmations. And then from the 11:25AM
very short turnaround time, I sent the model to 11:26AM
the outsourcing company to make it and then
11:26AM
completed it.
11:26AM
Q At the time when Mr. Ive gave you the
11:26AM
general direction, were you familiar with Sony 11:26AM
designs?
11:26AM
A Part of the reason is that I worked for 11:27AM
Panasonic for nine years. And my latter half of 11:27AM
my employment, for four and a half years, I was 11:27AM
involved in the audio division. And a part of 11:27AM
me, I have a respect for Sony products. And I 11:27AM
had some image in my head about what Sony
11:28AM
products are; so, for example, switches or
11:28AM
things like that that's specific to Sony.
11:28AM
So -- but roughly, what I included in
11:28AM
this drawing is what if -- what would Sony would 11:28AM
do -- what would Sony do. For example, the jog 11:28AM
shuttle or the buttons and layout and how the
11:28AM
brand is placed on and so forth.
11:28AM

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that's what I tried to express. But with that 11:50AM
said, I don't quite understand your question any 11:50AM
more than that."
11:50AM
BY MR. ZELLER:
11:50AM
Q Let me try it this way: Focusing on
11:50AM
that time period when Mr. Ive gave you the
11:50AM
general direction, you had seen at least some 11:50AM
Sony products?
11:50AM
A Well, there's -- there's no situation 11:51AM
that I created this design looking at Sony
11:51AM
products. However, it is correct that I
11:51AM
expressed what I have in my mind as the image of 11:51AM
what Sony is in the form of buttons and other 11:51AM
details.
11:51AM
Q Do you recall which type of Sony mobile 11:52AM
devices you had seen as of the time Mr. Ive gave 11:52AM
you this general direction?
11:52AM
A I do not remember.
11:52AM
Q As of the time when Mr. Ive gave you
11:52AM
this general direction, had you seen any kind of 11:52AM
Sony communication device, portable
11:52AM
communication device?
11:52AM
MS. TAYLOR: Objection. Vague.
11:53AM
INTERPRETED ANSWER: I do not have a
11:53AM
recollection that I saw the project with my own 11:53AM

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eyes directly. I might have some images or
11:53AM
memory that -- of the products I had seen
11:53AM
before. But it is not that I looked at the
11:53AM
project directly with my own eyes.
11:53AM
THE CHECK INTERPRETER: Proposed
11:53AM
correction: The lead interpreter said
11:53AM
"project." The checking interpreter believes
11:53AM
she misspoke.
11:54AM
THE INTERPRETER: Product. Product.
11:54AM
THE CHECK INTERPRETER: Product.
11:54AM
INTERPRETED ANSWER: For example, for
11:54AM
example like this, I had -- I remembered Sony
11:54AM
used this type of camera. They used to have a 11:54AM
tiny little camera like this. So I remember -- 11:54AM
I had some memory that they used the type of
11:54AM
camera like this at that time. But, however, it 11:54AM
is not that I looked at product and worked on
11:54AM
the design.
11:54AM
BY MR. ZELLER:
11:54AM
Q All right. I think you're getting a
11:55AM
little ahead of my question. What I'm trying to 11:55AM
find out is something specific. Do you remember 11:55AM
which Sony mobile devices you had seen as of the 11:55AM
time or before the time Mr. Ive gave you this
11:55AM
general direction?
11:55AM

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MS. TAYLOR: Objection. Vague.
11:55AM
INTERPRETED ANSWER: That's what I do
11:56AM
not remember.
11:56AM
BY MR. ZELLER:
11:56AM
Q Do you remember which Sony mobile
11:56AM
devices you saw after Mr. Ive gave you the
11:56AM
general direction?
11:56AM
A As for the Sony mobile devices, I'm
11:56AM
repeating that I did not look at it while I was 11:56AM
working on the design, so I do not remember what 11:57AM
I looked at. However, I might have touched on 11:57AM
the Sony device that was sold in the market.
11:57AM
But as I say, I do not remember.
11:57AM
THE CHECK INTERPRETER: Proposed
11:57AM
correction: "As for Sony mobile devices, I
11:57AM
repeat what I said. It's not the case that I
11:57AM
was looking at any mobile devices while working 11:57AM
on the design. I don't remember what I may have 11:57AM
seen at that time. But it's possible I touched 11:57AM
a phone that was sold in the market placed by
11:57AM
Sony at that time. However, I don't recall at 11:57AM
all."
11:57AM
MR. ZELLER: Let's please mark as
11:58AM
Exhibit 3 a multipage document. First page is 11:58AM
an e-mail from Richard Howarth dated March 8,
11:58AM

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TSG Reporting - Worldwide

2006, with images attached.
11:58AM
(Exhibit No. 3 marked for identification.) 11:58AM
BY MR. ZELLER:
11:58AM
Q You're not on this cover e-mail?
11:58AM
ENGLISH ANSWER: No, I never seen this 11:58AM
e-mail so I don't know that (In English.)
11:58AM
BY MR. ZELLER:
11:58AM
Q But I did want to ask you about the
11:58AM
pictures. If you can look at those, please.
11:58AM
And you'll see with the page ending 121 at the 11:58AM
bottom, there's a number of pages of images.
11:58AM
Let me take these one by one for a moment.
11:59AM
Focusing your attention on this page
11:59AM
that ends on 121, do you recognize what's on the 11:59AM
left-hand side here?
11:59AM
A No.
11:59AM
Q Is this a model that you worked on?
11:59AM
A No, it is not.
11:59AM
Q Directing your attention to the next
11:59AM
page, which is 122. Do you recognize what's on 11:59AM
the right-hand side as being something you
11:59AM
worked on?
11:59AM
A It's not whether I worked on the design. 12:00PM
I have seen this -- I might have seen the camera 12:00PM
part. It's close to what I worked on, but it is 12:00PM

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Confidential Business Information
Highly Confidential Attorney's Eyes Only
Page 58
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Page 59
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WITNESS CERTIFICATE
I, SHIN NISHIBORI, do hereby certify
that I have read the foregoing pages, inclusive,
and corrections, if any, were noted by me; and
that same is now a true and correct transcript
of my testimony.
Dated ______________________________________
______________________________________
SHIN NISHIBORI

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CERTIFICATE
I, ADRIANNE IGE KURASAKI, C.S.R., in and for the
State of Hawaii, do hereby certify:
That on Wednesday, May 2, 2012, at 10:03 a.m.,
appeared before me SHIN NISHIBORI, the witness whose
testimony is contained herein; that, prior to being
examined, the witness was by me duly sworn or affirmed;
that the proceedings were taken down by me in computerized
machine shorthand and were thereafter reduced to print
under my supervision; that the foregoing represents, to
the best of my ability, a true and correct transcript of
the proceedings had in the foregoing matter.
I further certify that I am not counsel for any of
the parties hereto, nor in any way interested in the
outcome of the cause named in the caption.

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Signed before me this _________
day of __________________________, 20_______.

____________________________________________

Certain Electronic Digital Media Devices, Case 337-TA-796/
Apple Inc. v Samsung Electronics Company, Ltd., et al.,
Civil No. 11-CV-01846
Videotaped Deposition of SHIN NISHIBORI
Taken on May 2, 2012

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This 57-page Deposition of SHIN NISHIBORI, dated
May 2, 2012, was subscribed and sworn to before me this
2nd day of May, 2012, in the First Circuit of the State of
Hawaii, by Adrianne Ige Kurasaki.

______________________________________
Adrianne Ige Kurasaki, CSR 388
State of Hawaii

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NAME OF CASE:
DATE OF DEPOSITION:
NAME OF WITNESS:
Reason Codes:
1. To clarify the record.
2. To conform to the facts.
3. To correct transcription errors.
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From _____________________ to _____________________
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From _____________________ to _____________________
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From _____________________ to _____________________
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From _____________________ to _____________________
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From _____________________ to _____________________
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________________________

TSG Reporting - Worldwide

877-702-9580

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