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

Filing 1445

Declaration of JASON R. BARTLETT in Support of 1444 Apple's Response to Samsung's Objections to Apple's Opening Statement Demonstrative Exhibits, filed by Apple Inc.. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2)(Related document(s) 1444 ) (Jacobs, Michael) (Filed on 7/29/2012) Modified text on 7/30/2012 (dhm, COURT STAFF).

Exhibit 1

Highly Confidential Pursuant to Protective Order

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

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HIGHLY CONFIDENTIAL
UNDER THE PROTECTIVE ORDER

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DEPOSITION OF JUSTIN DENISON
Dallas, Texas
Wednesday, September 21st, 2011

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Reported by:
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Daniel J. Skur, Notary Public and CSR
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JOB NO. 41964
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P R O C E E D I N G S

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VIDEOGRAPHER:

This is tape 1 in the

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video deposition of Justin Denison.

Today

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is Wednesday, September 21st, 2011.

We're

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now on record at approximately 9:36 a.m.

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Will the attorneys please introduce

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themselves for the record.

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MR. HUNG:

Richard Hung of Morrison

& Foerster on behalf of Apple, Inc.

With

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me today is Diana Kruze, also of Morrison &

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Foerster and also for Apple.

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MS. MAROULIS:

Victoria Maroulis

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with Quinn Emanuel, counsel for Samsung,

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and with me is Mark Tung of Quinn Emanuel,

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Cindy Moreland of STA, and we have an

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interpreter, Ann Park.

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JUSTIN DENISON,

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having been duly sworn, testified as follows:

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EXAMINATION

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BY MR. HUNG:

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Q.

Morning, Mr. Denison.

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A.

Morning.

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MR. HUNG:

Before we get started, I

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did have a discussion with Ms. Maroulis,

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and I just wanted to note a couple of
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A.

Outside of the name that I've

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already offered, I don't believe that there

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are -- is anyone else other than Cindy Moreland

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who is the general counsel of STA and is

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present today.

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directly, but the Quinn Emanuel attorney

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Margaret --

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I've not referred to her

MS. MAROULIS:
A.

Caruso.

-- Caruso, thank you, and Quinn

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Emanuel attorney Mark Tung, who is seated here

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today as well.

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BY MR. HUNG:

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Q.

Did you have a separate meeting with

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the individuals to whom you just referred apart

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from the conversations with the individuals

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listed on Exhibit 225?

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A.

Yes.

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Q.

When did that meeting occur?

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A.

I have had several meetings with the

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Quinn Emanuel attorneys to prepare for this

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deposition, the first of which occurred last

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week, and the most recent of which occurred

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yesterday, not counting this morning.

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Q.
discussed.

Again, I don't want to know what you
I just want to know how long those
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meetings were.

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aggregate?

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How long were those meetings in

In aggregate, I would estimate that

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I spent two to three full days in discussions

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with the Quinn Emanuel attorneys.

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Q.

Is this separate and apart from the

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10 to 12 hours that you testified you spent

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speaking with the individuals listed on Exhibit

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225?

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MS. MAROULIS:
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Objection, vague.

As I understand the question,

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outside of the teleconference time I spent with

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the individuals that are on this sheet of

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paper, yes, the time frame I gave you is

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approximate.

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BY MR. HUNG:

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Q.

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Dallas?

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A.

Yes.

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Q.

The Dallas area?

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A.

The meetings -- the meetings with

Okay.

Did those meetings occur in

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the Quinn Emanuel attorneys occurred in the

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Dallas area.

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MS. MAROULIS:

I think he's talking

about Richardson.
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hypothetical, beyond the scope.

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BY MR. HUNG:

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Q.

What steps does Samsung take, if

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any, to ensure that its employees do not copy

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Apple's designs in developing its Android smart

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phones?

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MS. MAROULIS:

Objection, beyond the

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scope to the extent it goes beyond products

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at issue.

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A.

When conferring with the designers

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for the products at issue, in all cases I

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specifically asked them if they had considered

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or studied or drawn direct comparisons or what

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have you versus the relevant Apple products,

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whether it be tablet or smart phone in either

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case, and in each case the designers said that

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they had not.

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Q.

Did you ask them whether they had

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used -- let's focus first on the Infuse 4G.

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Did you ask the designers on the Infuse 4G

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whether they had used any Apple product as

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inspiration for the design of the Infuse 4G?

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MS. MAROULIS:

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asked and answered.

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A.

Objection, vague,

I specifically asked the engineers
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C E R T I F I C A T E

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STATE OF TEXAS

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COUNTY OF DALLAS

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I, Daniel J. Skur, a Notary Public

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within and for the State of Texas, do

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hereby certify:

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That JUSTIN DENISON, the witness
whose deposition is hereinbefore set forth,

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was duly sworn by me and that such

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deposition is a true record of the

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testimony given by such witness.

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I further certify that I am not

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related to any of the parties to this

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action by blood or marriage; and that I am

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in no way interested in the outcome of this

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matter.

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IN WITNESS WHEREOF, I have hereunto

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set my hand this 21st day of September,

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2011.

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___________________________________
Daniel J. Skur

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Notary Public, State of Texas.
My Commission Expires 7/10/2014

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