Apple Inc. v. Samsung Electronics Co. Ltd. et al
Filing
1592
Declaration of Jason R. Bartlett in Support of 1591 Opposition/Response to Motion for Adverse Inference Jury Instruction filed byApple Inc.. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11)(Related document(s) 1591 ) (Bartlett, Jason) (Filed on 8/6/2012)
EXHIBIT 11
Highly Confidential - Attorneys' Eyes Only
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION
APPLE INC., a California
corporation,
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Plaintiff,
Case No.
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vs.
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,
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Defendants.
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HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
PURSUANT TO THE PROTECTIVE ORDER
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VIDEOTAPED DEPOSITION OF CHRISTOPHER D. PREST
Redwood Shores, California
Thursday, March 8, 2012
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REPORTED BY:
CYNTHIA MANNING, CSR No. 7645, CLR, CCRR
JOB NO. 46063
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877-702-9580
Highly Confidential - Attorneys' Eyes Only
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Foerster for Apple.
09:07
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THE VIDEOGRAPHER:
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reporter please swear in the witness.
Will the court
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CHRISTOPHER PREST,
09:07
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having first been duly sworn, testified
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as follows:
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EXAMINATION
BY MR. KIDMAN:
10:09
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Q.
Good morning.
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A.
Good morning.
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Q.
Could you state your name for the
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record, please.
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A.
My name is Christopher Prest.
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Q.
And what's your home address?
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A.
My home address is 522 Ashbury Street,
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09:07
San Francisco.
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Q.
And by whom are you employed?
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A.
I'm employed by Apple.
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Q.
And how long have you been employed by
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09:07
Apple?
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A.
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August 2005.
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Q.
I started work -- working for Apple in
And what's your current position at
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09:08
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Apple?
A.
09:08
I am a manager within the iPod/iPhone
Product Design Team.
Q.
What was your position when you first
started at Apple in August of 2005?
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A.
Product design engineer.
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Q.
09:08
And when you first started at Apple in
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August of 2005 as a design engineer, were you in
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the Product Design Group?
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A.
Yes.
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Q.
Have you held any other positions at
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09:08
Apple other than the two you've told me about?
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A.
No.
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Q.
When did you become a manager in the
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iPod/iPhone Product Design Team?
09:09
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A.
Approximately one year ago.
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Q.
And when you -- strike that.
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As a design engineer in the Product
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Design Group, what were your -- your general
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duties and responsibilities?
09:09
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A.
Mechanical design of Apple products.
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Q.
And when you say "mechanical design of
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Apple products," what do you mean by that?
A.
Design of components within Apple
products, and also general architecture and
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877-702-9580
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Highly Confidential - Attorneys' Eyes Only
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Q.
Do you recall any work that you did in
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terms of evaluating and developing materials for
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manufacturing techniques with respect to
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09:43
iPhone 3G?
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A.
I would have conducted some glass
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material investigations, but they may have
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been -- they may have been tied to N82 as opposed
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to N88.
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Q.
09:43
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The glass component was very similar.
Anything else that you recall with
respect to iPhone 3G?
09:44
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A.
No.
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Q.
And what work did you do in terms of
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evaluating and developing materials and
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manufacturing techniques on iPhone 4?
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A.
I was involved in evaluating the glass
09:44
material.
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Q.
Anything else?
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A.
And coatings applied to the glass.
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Q.
Anything else?
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A.
Not that I recall.
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Q.
What evaluation of the cover glass
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material for iPhone 3D did you perform?
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MR. DANIS:
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MR. KIDMAN:
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09:44
Did you say 3D?
I'm sorry.
Yeah.
//
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Highly Confidential - Attorneys' Eyes Only
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STATE OF CALIFORNIA
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:ss
COUNTY OF SAN MATEO
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)
I, CYNTHIA MANNING, a Certified Shorthand
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Reporter of the State of California, do hereby
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certify:
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That the foregoing proceedings were taken
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before me at the time and place herein set forth;
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that any witnesses in the foregoing proceedings,
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prior to testifying, were placed under oath; that
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a verbatim record of the proceedings was made by
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me using machine shorthand which was thereafter
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transcribed under my direction; further, that the
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foregoing is an accurate transcription thereof.
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I further certify that I am neither
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financially interested in the action, nor a
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relative or employee of any attorney of any of
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the parties.
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IN WITNESS WHEREOF, I have subscribed
my name this 8th day of March 2012.
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CYNTHIA MANNING, CSR No. 7645, CCRR, CLR
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TSG Reporting - Worldwide
877-702-9580
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