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 3

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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.
) No: 11-CV-01846-LHK
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SAMSUNG ELECTRONICS CO., LTD,
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a Korean business entity;
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SAMSUNG ELECTRONICS AMERICA,
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INC., a New York corporation;
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SAMSUNG TELECOMMUNICATIONS
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AMERICA, LLC, a Delaware
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limited liability company
)
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Defendants.
)
________________________________)

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**HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY**

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DEPOSITION OF JAEGWAN SHIN
San Francisco, California
Friday, January 27, 2012

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Reported By:
LINDA VACCAREZZA, RPR, CLR, CRP, CSR. NO. 10201
JOB NO. 44993
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January 27, 2012
9:31 a.m.

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Videotaped deposition of Jaegwan

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Shin, held at Morrison Foerster, LLP,

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425 Market Street, San Francisco,

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California, pursuant to Subpoena before

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Linda Vaccarezza, a Certified Shorthand

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Reporter of the State of California.

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

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QUINN EMANUEL URQUHART & SULLIVAN

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Attorneys for Defendants

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555 Twin Dolphin Drive

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Redwood Shores, California 94065

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BY:

MARK TUNG, ESQ.

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MORRISON & FOERSTER

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Attorneys for Plaintiff

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425 Market Street

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San Francisco, California 94105

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BY:

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MATTHEW I KREEGER, ESQ.
MINN CHUNG, ESQ

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ALSO PRESENT:

Michelle Yang

VIDEOGRAPHER:

Jason Corona

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THE VIDEOGRAPHER:

This is the

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start of tape labeled Number 1 of the

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videotaped deposition of Jaegwan Shin in

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the matter of Apple Inc. versus Samsung

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Electronics Company, et. al, in the

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United States District Court, Northern

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District of California, San Jose

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Division, number 11-CV-01846-LH.

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09:31

This deposition is being held

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at 425 Market Street, San Francisco,

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California, on January 27th, 2012, at

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approximately 9:31 a.m.

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My name is Jake Corona.

09:31

I'm

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the legal video specialist from TSG

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Reporting, Inc., headquartered at 747

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Third Avenue, New York, New York.

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09:31

The court reporter is Linda

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Vaccarezza in association with TSG

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Reporting.

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Would counsel please introduce

09:31

yourselves.
MR. KREEGER:

Matthew Kreeger,

Morrison Foerster, for Apple.
MR. CHUNG:

Minn Chung of Morrison

Foerster representing Apple.

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MS. KIM:

Foerster for Apple.

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MS. YANG:

MR. TUNG:

Mark Tung from Quinn

09:32

Emanuel for Samsung.

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Michelle Yang from

Samsung.

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Samantha Kim, Morrison

THE VIDEOGRAPHER:

Will the court

reporter please swear in the witness.

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(Korean Interpreters sworn.)

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JAEGWAN SHIN,

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09:32

Having been duly sworn, by the

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Certified Shorthand Reporter, was

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examined and testified as follows:

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EXAMINATION
BY MR. KREEGER:

09:32

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Q.

Good morning.

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A.

Good morning.

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Q.

We met off the record, but my name

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is Matthew Kreeger, and I'm an attorney at

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Morrison Foerster.

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deposition.

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full name, please?

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A.

Yes.

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Q.

Mr. Shin, do you understand that

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We are here to take your

09:32

Could you begin by giving us your

My name is Jaegwan Shin.

I'm going to ask you a series of questions and

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you're to answer the questions?

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A.

Yes.

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Q.

Have you ever given a deposition

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A.

No, I have not.

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Q.

If at any point, my questions are

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before?
09:33

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unclear, please let me know, and I will do my

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best to rephrase them.

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A.

I understand.

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Q.

Do you understand that you've

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taken an oath that's enforceable under law for

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09:34

you to tell the truth today?

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A.

Yes.

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Q.

Do you speak English, Mr. Shin?

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A.

A little, when it comes to the

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09:34

business matters.

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Q.

Can you read English?

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A.

Yes, I can, when it comes to

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e-mails.

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Q.

What is your current home address?

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235 Green Meadow Way, Palo Alto.

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Q.

How long have you lived in the

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09:34

United States?

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A.

It's been less than three years.

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Q.

Can you briefly describe your

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educational background after high school?
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I graduated from a university in

Korea, and my major was electronic engineering.
Q.

Did you attend school in the

United States at all?

09:35

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A.

No.

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Q.

What is the name of your employer?

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A.

It is Samsung Electronics.

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Q.

Where do you work?

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Where is your

office located?

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A.

It's in San Jose.

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Q.

What's the address?

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A.

2280 Orchard Parkway, San Jose.

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Q.

Do you work within a particular

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division or part of Samsung Electronics?
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09:36

Currently, I belong to the Mobile

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Communications Lab located in San Jose of Samsung

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Electronics, and I'm an expat from Korea.

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Q.

What is the San Jose Mobile

Communications Lab?

09:37

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MR. TUNG:

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THE WITNESS:

Objection.

Vague.

Are you asking me as

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to the roles of mobile communications?

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Q.

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No.

I'm interested in how would

you describe this unit of Samsung that you refer

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THE WITNESS:

There are many R&D

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centers, but the R&D center I was

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referring to here was Samsung Mobile --

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was the one that belongs to Samsung

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mobile division.

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Q.

Do you have a title?

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A.

My current title is senior

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09:46

director.
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How long have you had that

position?

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A.

Since 2009.

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Q.

What was your position before you

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were senior director?
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I was principal engineer when I

was in Korea.

09:47

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Q.

When did you first join Samsung?

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A.

It was 1993.

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Q.

Were you working in Korea from

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1993 all the way until 2009?

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A.

Yes, correct.

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Q.

For Samsung that entire time?

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A.

Yes.

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Q.

Are there other senior directors

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09:47

in the San Jose Mobile Communications Lab?
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No.

09:47

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Q.

What are your responsibilities as

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senior director at the San Jose Mobile

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Communications Lab?

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A.

There is no determined role,

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identified role, but currently, I'm working --

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I'm -- that.

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09:48

I'm assisting technical

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communications between our headquarters, R&D

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center and local engineers.

I'm also assisting

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with matters related to Google approval which is

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incorporated into the Android terminals or

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devices.

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with Google when it comes to technical issues

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related to Android devices.

09:49

I'm also responsible for communications

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Q.

Anything else?

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A.

Besides those, I'm also

09:49

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responsible for handling the matters requested by

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the headquarters from Korea as an expat.

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once in a while, there are guests from Korea;

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then I would be responsible for making

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arrangements for meetings or for other matters.

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Q.

And

09:50

You mentioned that one of your

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roles is to facilitate technical communication

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between the R&D at headquarters and local

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engineers.

With whom do you communicate at the

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R&D headquarters in order to facilitate this

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communication with the local engineer?

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A.

There is no person in particular;

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it depends on cases.

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R&D center.

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Q.

It could be anybody at the
09:52

What did you mean by Google

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approval which is incorporated into the Android

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devices?

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A.

All the devices that use Google's

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Android need to get approval from Google before

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they are launched into the market.

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Q.

With whom do you communicate at

A.

09:52

There is no person in particular,

Google?

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but mostly, I talk to the manager who is

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responsible for Samsung matters at Google.

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Q.

Who is that?

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A.

09:53

Jong Yung Lee, spelling by the

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interpreter, J-O-N-G -Q.

Actually, let's get the spelling

09:53

from the witness.

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A.

J-O-N-G, Y-U-N-G, space, L-E-E.

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Q.

Is that a man or a woman?

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A.

Man.

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Q.

Is Mr. -- do you communicate with

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