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

Filing 1468

OBJECTIONS to Apple's Proposed Examination Exhibits and Materials For Second Day of Trial 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 Kara M. Borden, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3)(Maroulis, Victoria) (Filed on 7/30/2012)

EXHIBIT 2

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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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C O N F I D E N T I A L
A T T O R N E Y S E Y E S O N L Y

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VIDEOTAPED DEPOSITION OF QI LING
SAN FRANCISCO, CALIFORNIA
WEDNESDAY, FEBRUARY 1, 2012

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BY: ANDREA M. IGNACIO HOWARD, CSR, RPR, CCRR, CLR
CSR LICENSE NO. 9830
JOB NO. 45295
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WEDNESDAY, FEBRUARY 1, 2012
9:31 a.m.

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VIDEOTAPED DEPOSITION OF QI LING,

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taken at MORRISON & FOERSTER, LLP,

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425 Market Street, San Francisco,

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California, pursuant to Notice, before me,

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ANDREA M. IGNACIO HOWARD, CLR, CCRR, RPR,

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CSR License No. 9830.

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A P P E A R A N C E S:

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FOR APPLE INC.:

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MORRISON & FOERSTER

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By:

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425 Market Street

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San Francisco, California 94105

MATTHEW I. KREEGER, Esq.

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FOR SAMSUNG ELECTRONICS CO. LTD:

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QUINN EMANUEL URQUHART & SULLIVAN

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By:

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555 Twin Dolphin Drive

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Redwood Shores, California

MARK TUNG, Ph.D., Esq.

94065

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ALSO PRESENT:

Pete Sais, Videographer
Michelle Yang, Samsung

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---oOo--23
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SAN FRANCISCO, CALIFORNIA

09:29

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WEDNESDAY, FEBRUARY 1, 2012

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9:30 A.M.

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THE VIDEOGRAPHER:

Good morning.

This is the

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start of Disc labeled No. 1 in the videotaped

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deposition of Qi Ling, in the matter of Apple, Inc.,

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versus Samsung Electronics Company, Limited, et al.

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In the United States District Court, Northern

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District of California, San Jose Division, case

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No. 11-cv-01846 LHK.

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This deposition is being held at 425 Market

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Street in San Francisco, California, on February 1st,

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2012, at approximately 9:31 a.m.

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My name is Pete Sais, and I'm the legal video

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specialist from TSG Reporting, Inc., headquartered at

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747 Third Avenue, New York, New York.

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The court reporter is Andrea Ignacio, in
association with TSG Reporting.

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Will counsel please introduce yourselves, and
the court reporter can swear in the witness.

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MR. KREEGER:

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Foerster, for Apple.

Matthew Kreeger, Morrison &

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MR. TUNG:

Mark Tung from Quinn Emanuel for

Samsung.

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MS. YANG:

Michelle Yang for Samsung.

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QI LING,

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having been sworn as a witness

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by the Certified Shorthand Reporter,

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testified as follows:

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09:40

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EXAMINATION BY MR. KREEGER

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MR. KREEGER:

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Good morning, Mr. Ling.

My

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name is Matthew Kreeger, and I'm an attorney for

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Apple, and I'm here to take your deposition today.

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Q

Have you ever been deposed before?

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A

No.

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Q

Why don't we start by -- if you could give us

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your full name.
A

Sure.

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09:32
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My last name is L-I-N-G, Ling.

First name is

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Q-I, Qi.

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Q

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And where do you live, Mr. Ling, your home

address?

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A

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Home address is 1235 Wildwood Avenue,

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Apartment 190, Sunnyvale.

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sorry -- 94089.

ZIP code is 4 -- I'm

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Q

And where do you work?

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A

I work at San Jose Mobile Communications Lab,

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Samsung Telecommunications of America.

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Q

Okay.

And what's the address there?

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A

I believe it's 2820 Orchard Parkway,

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San Jose.

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Q

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If at any point today you don't understand

one of my questions --

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A

Sure.

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Q

-- please let me know, and I'll do my best to

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rephrase the question.

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you understand.

Otherwise, I'm going to assume

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Sure.

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Q

Is there any reason why you can't give full

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and accurate testimony today?

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A

No.

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Q

You're not taking any medication or otherwise

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impaired?

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A

No.

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Q

Okay.

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A

My title is senior engineer.

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Q

And could you briefly describe your

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What is your title -- your work title?

educational background after high school.

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A

After high school?

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Q

Uh-huh.

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A

I got my bachelor's degree at the University

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of Science and Technology of China, in China.

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then I went to U.S. for the Ph.D. degree, and I got my

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Ph.D. from Michigan State University.

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I joined Samsung.

And

And after that

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Q

Is your Ph.D. in computer science?

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A

No.

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It's in electrical and computer

engineering.
Q

Okay.

09:34
You mentioned you work at the San Jose

Mobile Communications Lab.

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Yes.

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Q

Is there a particular group that you're a

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part of within that lab?
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There's been a couple of reorganizations, so

I was in different groups.

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All right.

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Maybe we should go through the history of it.

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Where -- when you started at Samsung, did you

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Q

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start at the San Jose Mobile Communications Lab?

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A

Yes, as a contractor.

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Q

And when was that?

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A

It's January 2008.

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Q

And which group were you a part of at that

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point?
A

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I don't really remember the name of the

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