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)

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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 BRIAN Q. HUPPI
REDWOOD SHORES, CALIFORNIA
TUESDAY, OCTOBER 18, 2011

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BY: ANDREA M. IGNACIO HOWARD, CSR, RPR, CCRR, CLR.
CSR LICENSE NO. 9830
JOB NO. 42679
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Foerster, representing Apple.

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BRIAN Q. HUPPI,

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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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EXAMINATION BY MR. MACK

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MR. MACK:

Q.

Mr. Huppi, could you please

state your name and address for the record.
A

Sure.

It's Brian Quentin Huppi.

My address

is 262 Rutledge Street in San Francisco, California.

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Q

Have you been deposed before?

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A

Yes.

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Q

How many times?

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A

Once.

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Q

And do you remember what case that was in?

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A

It was a case involving Motorola.

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I don't

remember the case number.
Q

Okay.

And was -- were you deposed as your

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role as an inventor on any patent asserted -- asserted

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in that case?

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A

Yes.

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Q

Okay.

Do you remember which patent it was?
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MR. MACK:

Q.

Do you recognize this -- this

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document?

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A

Yes.

I believe I received an e-mail copy of

Q

Okay.

And is this subpoena the reason why

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it.

you are testifying here today?

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MR. BARTLETT:

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THE WITNESS:

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MR. MACK:

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Q

Objection; vague.
I believe that's why I'm here.

Okay.

Do you see that the subpoena also asks you to

produce documents in connection with this case?

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A

Yes.

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Q

And did you perform a search for documents in

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connection with this case?

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A

Yes, but I didn't find any.

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Q

Okay.

Did you perform a search for documents

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in connection with the previous case that you were

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deposed in?

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A

Yes.

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Q

Okay.

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I didn't find any.
Do you maintain a computer at your

house with work relating to Apple?

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MR. BARTLETT:

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THE WITNESS:

Objection; vague.
I have a home computer, but it

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doesn't have any Apple materials.

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behind at Apple.
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MR. MACK:
Q

Okay.

How about e-mail correspondence with Apple?

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Do you have any e-mail correspondence on your home

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computer?

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MR. BARTLETT:

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THE WITNESS:

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MR. BARTLETT:

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THE WITNESS:

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with -- with folks at Apple.

Same objection.
I have -And compound.
-- I do have some e-mails
Some are friends or

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colleagues.

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contracting work I did with Apple since I left Apple.

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Some are with -- associated with some

MR. MACK:
Q

Okay.

And have you retained any documents relating

to your work at Apple after you left Apple?

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MR. BARTLETT:

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THE WITNESS:

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They would only be documents

related to work I did after I left Apple.

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Objection; vague.

MR. MACK:
Q

Okay.

Did you personally conduct the search for

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documents, or did someone else conduct the search on

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your behalf?

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A

I searched for any documents that I might

have personally.

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Q

Okay.

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A

Correct.

And you found none; correct?

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CERTIFICATE OF REPORTER

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I, ANDREA M. IGNACIO HOWARD, hereby certify

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that the witness in the foregoing deposition was by me

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duly sworn to tell the truth, the whole truth, and

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nothing but the truth in the within-entitled cause;

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That said deposition was taken in shorthand

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by me, a Certified Shorthand Reporter of the State of

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California, and was thereafter transcribed into

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typewriting, and that the foregoing transcript

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constitutes a full, true and correct report of said

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deposition and of the proceedings which took place;

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That I am a disinterested person to the said
action.

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IN WITNESS WHEREOF, I have hereunto set my
hand this 19th day of October, 2011.

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_______________________________________
ANDREA M. IGNACIO HOWARD, RPR, CCRR, CLR, CSR No. 9830

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