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 C

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

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other. And I think I now understand, what you're
saying is that the space in between, that depicts the
housing.
A Yes.
Q And now I'm trying to figure out: Do the two
lines -- where they diverge there, do those -- do
those signify some edge of the housing?
MR. JACOBS: Objection; form.
THE WITNESS: I see a surface in between
those lines that is adjacent to the cover glass that
is on the same plane as the cover glass, butting up
against the edge of the cover glass.
MR. ZELLER: Q. And one reason you reached
that conclusion is because of the drawings in the
other figures?
A That's how -- yes.
Q What other figures were you referring to,
just so we have a clear record on that, that were
helping you in your understanding?
A Figure 1, Figure 3, and Figure 5 -- well, 5,
6, 7, and 8 equally, along with Figure 9, I create an
image of a product.
Q Would you please mark as Exhibit 1172 a
multipage document bearing Bates
Nos. APLNDC-NCC0000247 through '281, and it's a

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collection of field CAD drawings.
(Document marked Exhibit 1172
for identification.)
THE WITNESS: Okay.
MR. ZELLER: Q. Do you recognize anything
that's depicted here in Exhibit 1172?
A Yes.
Q What do you recognize these as?
A I recognize an exercise that Shin Nishibori
worked on. I do not recall when, but the dates would
indicate it was in '06, March of '06.
Q And even though you don't recall, as you've
said, is there any reason for you to think it was not
in the 2006 time period?
A No.
Q Did you work on this project yourself?
A This is an exercise. I see that as distinct
from a project. It could be considered as to be some
abstract portion of a project, that being the iPhone.
Q I'm happy to call it either. So just so we
have -- we understand we're talking about the same
thing. So whether it's exercise or project, focusing
on this design work that was done that pertained in
particular to these designs that are shown here in
Exhibit 1172 with the name Sony on it, can you please

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tell me generally what that -- what the purpose of
that was.
A It was a -- just a fun exercise where Shin
made an object resembling an iPhone that would -almost in a role-playing kind of way, what would Sony
do if they were us?
Q Do you have an understanding -- and that's
the reason why Sony is -- is on this?
A Yeah. It was fun.
Q Do you know who came up with the idea for
this exercise?
A I do not recall.
Q Did you yourself prepare any designs or
drawings that was part of this exercise?
A No.
Q Do you know if anyone other than
Mr. Nishibori did?
A No.
Q Generally speaking, I take it you recognize
the images here in Exhibit 1172 as filled in CAD
drawings?
A Rendered, shaded, yes.
Q And do you know were any three-dimensional
models created as part of the exercise that we're
talking about?

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TSG Reporting - Worldwide

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?
A Not sufficiently clear. I can't recall.
Q You're just not sure?
A Uh-huh.
Q I'm sorry. You need to give an audible -A Yes.
Q Yeah. Okay.
Is there anything else that you remember
generally about this exercise?
A No.
Q Let me show you what was previously marked as
Exhibit 751, which is a copy of United States design
patent 622,270.
A Yes.
Q Do you recognize the '270 design patent as a
design patent that you're a named inventor on?
A Yes.
Q And, generally speaking, do you recognize
what -- what product or object is depicted here?
A The iPod Touch.
Q Was this the first iPod Touch?
A I think so. Yes, I believe that is the case.

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Highly Confidential - Outside Counsel's Eyes Only
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No. 3 of 3 and concludes today's deposition of Chris
Stringer.
The time is 3:23 p.m., and we are off record.
(WHEREUPON, the deposition ended at
3:23 p.m.)
---oOo---

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JURAT

I, CHRISTOPHER STRINGER, do hereby certify
under penalty of perjury that I have read the
foregoing transcript of my deposition taken
on November 4, 2011; that I have made such
corrections as appear noted herein in ink,
initialed by me; that my testimony as
contained herein, as corrected, is true and
correct.

DATED this ____ day of _____________, 2011,
at _____________________________, California.

__________________________________
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
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action.
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IN WITNESS WHEREOF, I have hereunto set my
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hand this 4th day of November 2011.
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_______________________________________
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ANDREA M. IGNACIO HOWARD, RPR, CCRR, CLR, CSR No. 983023
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TSG Reporting - Worldwide

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INDEX
DEPOSITION OF CHRISTOPHER STRINGER
EXAMINATION
PAGE
BY MR. ZELLER
BY MR. JACOBS

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EXHIBITS
EXHIBIT
PAGE
Exhibit 1161 Reply Declaration of Christopher 5
Stringer in support of Apple's
Motion for a Preliminary
injunction; 50 pgs.
Exhibit 1162 Colored Photograph Ad of iPad
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Thinner and Lighter; 1 pg.
Exhibit 1163 U.S. Patent No. D627,777 S;
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7 pgs.
Exhibit 1164 U.S. Patent No. D637,596 S;
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7 pgs.
Exhibit 1165 U.S. Patent No. D621,825 S;
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14 pgs.
Exhibit 1166 Sketchbooks, Bates Nos.
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APLNDC0000037650 - '95; 46 pgs.

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