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

Page 1
1
2
3
4

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION
APPLE INC., a California
corporation,

5

Plaintiff,

Case No.

6

vs.

11-CV-01846-LHK

7

8

9

10

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,

11

Defendants.
12
13
14
15
16

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
PURSUANT TO THE PROTECTIVE ORDER

17
18
19
20

VIDEOTAPED DEPOSITION OF CHRISTOPHER D. PREST
Redwood Shores, California
Thursday, March 8, 2012

21
22
23
24
25

REPORTED BY:
CYNTHIA MANNING, CSR No. 7645, CLR, CCRR
JOB NO. 46063
TSG Reporting - Worldwide

877-702-9580

Highly Confidential - Attorneys' Eyes Only

Page 5
1

Foerster for Apple.

09:07

2

THE VIDEOGRAPHER:

3

reporter please swear in the witness.

Will the court

4
5

CHRISTOPHER PREST,

09:07

6

having first been duly sworn, testified

7

as follows:

8
9
10

EXAMINATION
BY MR. KIDMAN:

10:09

11

Q.

Good morning.

12

A.

Good morning.

13

Q.

Could you state your name for the

14

record, please.

15

A.

My name is Christopher Prest.

16

Q.

And what's your home address?

17

A.

My home address is 522 Ashbury Street,

18

09:07

San Francisco.

19

Q.

And by whom are you employed?

20

A.

I'm employed by Apple.

21

Q.

And how long have you been employed by

22

09:07

Apple?

23

A.

24

August 2005.

25

Q.

I started work -- working for Apple in

And what's your current position at

TSG Reporting - Worldwide

877-702-9580

09:08

Highly Confidential - Attorneys' Eyes Only

Page 6
1
2
3
4
5

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?

6

A.

Product design engineer.

7

Q.

09:08

And when you first started at Apple in

8

August of 2005 as a design engineer, were you in

9

the Product Design Group?

10

A.

Yes.

11

Q.

Have you held any other positions at

12

09:08

Apple other than the two you've told me about?

13

A.

No.

14

Q.

When did you become a manager in the

15

iPod/iPhone Product Design Team?

09:09

16

A.

Approximately one year ago.

17

Q.

And when you -- strike that.

18

As a design engineer in the Product

19

Design Group, what were your -- your general

20

duties and responsibilities?

09:09

21

A.

Mechanical design of Apple products.

22

Q.

And when you say "mechanical design of

23
24
25

Apple products," what do you mean by that?
A.

Design of components within Apple

products, and also general architecture and

TSG Reporting - Worldwide

877-702-9580

09:09

Highly Confidential - Attorneys' Eyes Only

Page 25
1

Q.

Do you recall any work that you did in

2

terms of evaluating and developing materials for

3

manufacturing techniques with respect to

4

09:43

iPhone 3G?

5

A.

I would have conducted some glass

6

material investigations, but they may have

7

been -- they may have been tied to N82 as opposed

8

to N88.

9

Q.

09:43

10

The glass component was very similar.
Anything else that you recall with

respect to iPhone 3G?

09:44

11

A.

No.

12

Q.

And what work did you do in terms of

13

evaluating and developing materials and

14

manufacturing techniques on iPhone 4?

15
16

A.

I was involved in evaluating the glass

09:44

material.

17

Q.

Anything else?

18

A.

And coatings applied to the glass.

19

Q.

Anything else?

20

A.

Not that I recall.

21

Q.

What evaluation of the cover glass

22

material for iPhone 3D did you perform?

23

MR. DANIS:

24

MR. KIDMAN:

25

09:44

Did you say 3D?
I'm sorry.

Yeah.

//

TSG Reporting - Worldwide

877-702-9580

Highly Confidential - Attorneys' Eyes Only

Page 98
1
2
3

STATE OF CALIFORNIA

)

:ss
COUNTY OF SAN MATEO

4

)

I, CYNTHIA MANNING, a Certified Shorthand

5

Reporter of the State of California, do hereby

6

certify:

7

That the foregoing proceedings were taken

8

before me at the time and place herein set forth;

9

that any witnesses in the foregoing proceedings,

10

prior to testifying, were placed under oath; that

11

a verbatim record of the proceedings was made by

12

me using machine shorthand which was thereafter

13

transcribed under my direction; further, that the

14

foregoing is an accurate transcription thereof.

15

I further certify that I am neither

16

financially interested in the action, nor a

17

relative or employee of any attorney of any of

18

the parties.

19
20
21

IN WITNESS WHEREOF, I have subscribed
my name this 8th day of March 2012.

22
23
24

CYNTHIA MANNING, CSR No. 7645, CCRR, CLR

25

TSG Reporting - Worldwide

877-702-9580