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)

Highly Confidential - Attorneys' Eyes Only

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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 CHRISTOPHER HARRIS
Redwood Shores, California
Tuesday, March 6, 2012

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Reported By:
LINDA VACCAREZZA, RPR, CLR, CRP, CSR. NO. 10201
JOB NO. 46059
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877-702-9580

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reporter please swear in the witness.

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CHRIS HARRIS,

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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. ARNOLD:

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Q.

Good morning, Mr. Harris.

you for coming.

Thank

Would you please state your name

and spell it for the record?

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10:07

A.

10:08

Christopher Harris.

C-H-R-I-S-T-O-P-H-E-R, H-A-R-R-I-S.

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Q.

And is this your first deposition?

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A.

Yes.

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Q.

Well, let me -- I'll just go over

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a few important things that -- you to be aware

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of.

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10:08

these, but I'll mention them nonetheless.

I'm sure your counsel has probably told you

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So you understand that you were

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just sworn in to tell the truth under penalty of

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perjury.

10:08

Do you understand that?

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A.

Yes.

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Q.

And so your testimony today should

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be given as if a judge were present.

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understand that?

Do you
10:08

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industrial design model shop ever give feedback to the

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designers about designs?

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MR. DANIS:

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THE WITNESS:

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Q.

Can you repeat that,

please?

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I'm sorry.

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you.

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10:56

Sure.

Do you -- let's start just with

the designs?

Do you ever give feedback to the designers about

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A.

No.

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Q.

Does anyone in the model shop do that?

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MR. DANIS:

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MR. ARNOLD:

That you know of?

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THE WITNESS:

10:56

I do not know.

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Q.

Speculation.

So more or less, you receive the model

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request, you build the model and you deliver it to the

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designers without comment on the design?

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A.

Approximately, correct.

Yes.

10:56

I hand

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the model off to Zack who gives it to the finishing

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department.

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Q.

Okay.

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A.

And then it goes from there to the

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10:57

designer.
Q.

Okay.

So you don't have direct contact

with the designers?
A.

Unless I need to clarify a detail or

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something that have nature.

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Q.

And do you do that from time to time?

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A.

Rarely, rarely.

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MR. ARNOLD:

All right.

Well, I have

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nothing further for you, so I will let you go.

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so much for coming.

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MR. DANIS:

Thanks

10:57

We'll designate the

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transcript as highly confidential, attorneys'

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eyes only under the protective order, and

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request that Mr. Harris be given an

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opportunity to review the draft

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for review and signature.

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THE VIDEOGRAPHER:

10:57

transcript

This marks the end

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of Disk Number 1 and concludes today's

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deposition.

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TSG Reporting.

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record.

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The original DVDs will be held by
We are now going off the

The time is 10:57 a.m.

(Time noted:

10:57 a.m.)

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___________________

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CHRISTOPHER HARRIS

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Subscribed and sworn to before me
This

day of

, 2012.

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______________________________________

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C E R T I F I C A T E
STATE OF CALIFORNIA

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COUNTY OF SAN FRANCISCO )

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I, LINDA VACCAREZZA, a Certified

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Shorthand Reporter for the State of

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California, do hereby certify:

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That CHRISTOPHER HARRIS, the witness
whose deposition is hereinbefore set forth,

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was duly sworn by me and that such deposition

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is a true record of the testimony given by

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such witness.

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I further certify that I am not related

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to any of the parties to this action by blood

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or marriage; and that I am in no way

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interested in the outcome of this matter.

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IN WITNESS WHEREOF, I have hereunto set
my hand this 6th day of March, 2012.

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________________________________

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LINDA VACCAREZZA, CSR. NO. 10201

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877-702-9580