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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That was all left
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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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TSG Reporting - Worldwide
(877)-702-9580
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