Apple Inc. v. Samsung Electronics Co. Ltd. et al

Filing 179

Declaration of SARA JENKINS IN SUPPORT OF SAMSUNG'S OPPOSITION TO APPLE'S MOTION FOR PRELIMINARY INJUNCTION filed bySamsung Electronics America, Inc., Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Exhibit J, #11 Exhibit K, #12 Exhibit L, #13 Exhibit M, #14 Exhibit N, #15 Exhibit O, #16 Exhibit P, #17 Exhibit Q, #18 Exhibit R, #19 Exhibit S, #20 Exhibit T, #21 Exhibit U, #22 Exhibit V, #23 Exhibit W, #24 Exhibit X, #25 Exhibit Y, #26 Exhibit Z, #27 Exhibit AA, #28 Exhibit BB, #29 Exhibit CC, #30 Exhibit DD, #31 Exhibit EE, #32 Exhibit FF, #33 Exhibit GG, #34 Exhibit HH, #35 Exhibit II, #36 Exhibit JJ, #37 Exhibit KK, #38 Exhibit LL, #39 Exhibit MM, #40 Exhibit NN, #41 Exhibit OO, #42 Exhibit PP, #43 Exhibit QQ, #44 Exhibit RR, #45 Exhibit SS, #46 Exhibit TT)(Maroulis, Victoria) (Filed on 8/23/2011) Modified on 8/29/2011 cannot link entry-opposition has not been efiled (dhm, COURT STAFF).

EXHIBIT SS

Claim Chart of
Dr. Balakrishnan’s Deposition Testimony
Regarding LaunchTile

‘381 Patent

Dr. Balakrishnan’s Testimony

Claim 1
A computer-implemented method, comprising:

2x2 Grid:
Q. . . . So the question is: In the 2x2 grid that -that we have in LaunchTiles in front of you,
does the -- running on the iPAQ device, does
that perform on a computer-implemented
method?
MR. MONACH: Object to the form of the
question. I'll object to this whole line of
questioning as calling for a legal conclusion;
asking the witness to form an -- a new opinion
on a topic he has not opined upon at the
deposition with incomplete information or
opportunity to examine the device of a product,
but you can answer.
MR. JOHNSON: You can have a running
objection on that, just to try and cut though
this.
THE WITNESS: So I haven't examined this in
any great detail, but just looking at this right
now, it's -- certainly is an application that's
running on a computer-implemented -- or a
computer -- so it is a computer-implemented
method.
278:16-279:8.
2x4 Grid:
MR. JOHNSON: Q. Would you agree that
Exhibit 114 meets the limitations of Claim 1 of
the '381 patent?
MR. MONACH: Same objection.
THE WITNESS: All elements of the claim?
MR. JOHNSON: Yeah, under the scenario that
we just showed you.
THE WITNESS: So, again, back to my earlier
answers, first of all, I haven't had a chance to

02198.51855/4311400.2

1

study this, the representation you had of the
eight -- eight tiles being one document as a
whole, that's your representation. Given that
hypothetical, I would also say, as I said earlier,
the blue circle in the middle, which you
represented the whole thing was a document,
that does not appear to move when you -- when
you translate the document.
So, as a result, I would say, given those
qualifications, the -- the entirety of these
claims are not met. But if you assume, if those
things are not present, if the blue thing wasn't
there, and the -- or it moved along with it as a
document, it -- it appears to meet the claims.
317:6-318:2
Inbox:
THE WITNESS: Okay. So to the extent that
I'm seeing this for the first time, I haven't seen
that application at all before, so I'm -- I'm
giving this opinion on the fly here, I haven't
considered it, and it's not a detailed thing I've
considered, so I'm looking here. It appears to
meet the computer-implemented method
preamble.
326:7-328:1.
2x2 Grid:

at a device with a touch screen display:

Q And does LaunchTiles running on iPAQ,
does that meet the limitation of a device with a
touchscreen display?
MR. MONACH: Same objection.
THE WITNESS: It's not clear, to me, this is a
touchscreen display. I tried touching it a
minute ago, like when I was playing with it,
and it didn't react to me, but the -- the pen
seems to do the job.
Okay, so now it does react, so maybe I was
mistaken. Given what he just did, it appears to
react to touches, so, sure, it would be a device
with a touchscreen display.
278:10-21.
02198.51855/4311400.2

2

2x4 Grid:
317:6-318:2
Inbox:
THE WITNESS: Okay. So to the extent that
I'm seeing this for the first time, I haven't seen
that application at all before, so I'm -- I'm
giving this opinion on the fly here, I haven't
considered it, and it's not a detailed thing I've
considered, so I'm looking here. It appears to
meet the computer-implemented method
preamble.
326:7-328:1.
displaying a first portion of an electronic
document;

2x2 Grid:
Q. So when – when he slides it slightly to the
left, does that display a first portion of an
electronic document if you assume that that
2x2 grid is an electronic document?
MR. MONACH: Same objection.
THE WITNESS: So if we make that
assumption that that 2x2 grid in its entirety is
an electronic document and after he slid it, that
could be a first portion.
287:9-17.
2x4 Grid:
317:6-318:2
Inbox:
It appears, giving your representation, that
that's a list, and it displays the first portion. It
meets the first element.
326:7-328:1.
2x2 Grid:

detecting a movement of an object on or near
the touch screen display;

Q. Does LaunchTiles, with this 2x2 grid
02198.51855/4311400.2

3

operated on an iPAQ, detect a movement of an
object on or near the touchscreen display?
A. Yes, it does.
289:2-5.
2x4 Grid:
317:6-318:2
Inbox:
To the extent that it detects a movement, it may
meet the second element.
326:7-328:1.
2x2 Grid:

in response to detecting the movement,
translating the electronic document displayed
on the touch screen display in a first direction
to display a second portion of the electronic
document, wherein the second portion is
different from the first portion;

Q So does the 2x2 LaunchTiles grid operating
on the iPAQ describe the next limitation in the
claims, which is numbered as three?
A So this one's saying in response to detecting
the movement translating electronic document
displayed in the touchscreen in the first
direction to display the second portion?
MR. MONACH: Same objection.
MR. JOHNSON: Correct.
THE WITNESS: So you want me to assume
the first portion was after he had moved to the
left, and now you move it back, and you're
saying that's the second portion of the
document?
MR. JOHNSON: Right.
THE WITNESS: With -- with the same caveats
I said earlier about the blue thing moving and
whether that's part of the document or not, I'll
repeat that as part of my current answer, and,
again, I haven't had a chance to explore this in
great detail, but given those, the qualifications,
I would say it appears to be -- it could be
meeting that claim -- claim element.
289:20-290:16
2x4 Grid:

02198.51855/4311400.2

4

317:6-318:2
Inbox:
With the third element, it appears to meet that.
326:7-328:1.
2x2 Grid:

in response to an edge of the electronic
document being reached while translating the
electronic document in the first direction while
the object is still detected on or near the touch
screen display:

MR. JOHNSON: Q. So, again, the question is:
Does the movement that Mr. Lien just did meet
the fourth limitation of the claim?
MR. MONACH: Same objection as previously
stated.
THE WITNESS: Again, with the same
qualifications about the blue circle in the
middle not moving, and if that was part of the
document, then it doesn't move appropriately.
And, again, with the same qualifications I
made earlier, that I haven't had a chance to
look at this in detail. Just sitting here right
now, an off-the-cuff view of this, I would say it
appears to meet -- meet the fourth limitation.
290:17-292:3.
2x4 Grid:
317:6-318:2
Inbox:
326:7-330:18.
2x2 Grid:

displaying an area beyond the edge of the
document, and

Q Does LaunchTiles in the 2x2 grid operating
on the iPAQ meet the fifth limitation of Claim
1?
MR. MONACH: Same objection as previously
stated; assumes facts not in evidence, as well.
THE WITNESS: Can you do that again,
please?
Again, given -- well, something else happened.
So, again, given the qualifications I did earlier
-- I said earlier about the circle in the middle,
the blue circle, and also the fact that I haven't
02198.51855/4311400.2

5

looked at this in any detail, in this quick view
of this -- of this application running here, I
would say it appears to meet the -- the fifth
element.
292:5-16.
2x4 Grid:
317:6-318:2
Inbox:
326:7-330:18.
2x2 Grid:

displaying a third portion of the electronic
document, wherein the third portion is smaller
than the first portion; and

02198.51855/4311400.2

MR. JOHNSON: Q. And meet that -- meets the
sixth claim limitation; right?
A Well, maybe -- maybe he can show me that.
Q Sure.
A Show me your first portion. Let's see your
first portion. Okay. Second portion. Okay.
Third portion. It's very hard to tell. It's
bouncing around. I'd have to measure it. It
could be. It -- it may not be. It's clearly smaller
necessarily, because the other one is also not
full screen. It moved off to the other side -MR. JOHNSON: And can you do -THE WITNESS: -- so there was -MR. JOHNSON: -- it again that's more
pronounced.
Q So let's -- let's look at the first, second, third
portions again.
A Okay. That's your first portion. So second
portion is in the center. It appears, in this case,
he's moved it a bit more, and it -MR. MONACH: Same objection.
THE WITNESS: -- it potentially could -- could
infringe -- sorry -- it could not infringe –
MR. JOHNSON: Meet the limitation.
THE WITNESS: -- meet the limitation of
Claim 6, again with the qualifications that I -- I
just went through with the circle in the middle
and the fact that I haven't studied this in any
great detail.
MR. JOHNSON: Q. It would meet the sixth
6

limitation of Claim 1; right?
MR. MONACH: Same objection; asked and
answered.
MR. JOHNSON: Q. You said Claim 6, and I
think you misspoke.
A I meant to say the sixth limitation.
292:17-295:2.
2x4 Grid:
317:6-318:2
Inbox:
326:7-330:18.
2x2 Grid:

in response to detecting that the object is no
longer on or near the touch screen display,
translating the electronic document in a second
direction until the area beyond the edge of the
electronic document is no longer displayed to
display a fourth portion of the electronic
document, wherein the fourth portion is
different from the first portion.

Q And when he lifts the stylus or his finger,
does it meet the seventh limitation of Claim 1?
MR. MONACH: Same objection.
THE WITNESS: In this case, it's back to the
original document, which was, and I would
say, to go back, when you -- when you
displayed the first portion of the electronic
document, that already included a movement,
which the claims doesn't talk about. So you
already had a movement there. Given that, and
given all the caveats -- sorry -- the
qualifications that I have made with regards to
this -- this demonstration, the circle not
moving, the fact that I have not looked at this
in any great detail, it -- it appears that it could
meet that -- that -- that -- sorry -- element 7 of
Claim 1, again, with the qualification again
that -- that the first portion of this case already
included a movement, which this -- this claim
doesn't appear to talk about.
295:5-22.
2x4 Grid:
317:6-318:2
Inbox:

02198.51855/4311400.2

7

326:7:17-330:18.
Claim 2
The computer-implemented method of claim 1,
wherein the first portion of the electronic
document, the second portion of the electronic
document, the third portion of the electronic
document, and the fourth portion of the
electronic document are displayed at the same
magnification.

2x2 Grid:
Q Does the 2x2 grid in LaunchTile operating
on the iPAQ meet the limitation described in
Claim 2?
MR. MONACH: Same objection as previously
stated with the questions about 1; lacking in
foundation, given his prior testimony about
Claim 1.
MR. JOHNSON: Counsel, I really suggest you
just keep a running objection, but you're really
interfering with the examination, at this point.
THE WITNESS: So with regards to Claim 2,
I'm looking at this again, my qualifications of - of what is the electronic document here, from
my earlier answers, it's not clear that -- whether
that blue circle in the middle is part of the
document or not, or, again, I'm looking at this
on the flight here, haven't had the time to study
it. It is -- I haven't had time to determine if the
magnification changes, as he moves it around
or not. It might be. It might not be. At, you
know, first glance, it looks like it hasn't
changed, but I haven't had time to -- to study
this in detail, so I cannot give a definitive
answer as to whether the magnification of the
electronic document, to the extent that's even
an electronic document in this application,
remains the same.
299:16-300:14.
2x4 Grid:
THE WITNESS: So with regard to Claim 2, let
me quickly look at this again, first portion,
second portion. So Claim 2 was with regard to
the magnification. Again, similar to the same
answer I gave -- to the answer I gave earlier
when you went over to Claim 2, I would have
to determine for sure whether that was indeed
of the same magnification, but if it is, then it
would be met. Again, given all the caveats that

02198.51855/4311400.2

8

I -- sorry -- all of the qualifications that I just
made with regards to Claim 1 not being met,
and Claim 1 is incorporated in Claim 2.
319:17-320:8
Claim 3
The computer-implemented method of claim 1,
wherein the movement of the object is on the
touch screen display.

2x2 Grid:
Q Does Exhibit 114 meet the limitations of
Claim 3?
MR. MONACH: Same objection as stated in
response to the previous question.
THE WITNESS: To the extent that -- my
understanding is Claim 3 is a dependent claim
on Claim 1, so to the extent that Claim 1 is
met, which I'm not agreeing whether it does or
not, based on my earlier testimony. That said,
the -- the portion of the Claim 3, which says
the movement of the objects on a touchscreen
display, that would be met, yes.
300:19-301:4.
2x4 Grid:
Claim 3 is -- the movement is on the
touchscreen display, but since it's incorporated
in Claim 1, if Claim 1 has -- is not met, for the
reasons I just gave you, then it would not be
met. But if Claim 1 is met, Claim 3 would be
met.
320:9-13.

Claim 4
The computer-implemented method of claim 1,
wherein the object is a finger.

2x2 Grid:
MR. JOHNSON: Q. And the limitation of
Claim 4 would also be met; right?
A With regards to whether the object being a
finger, if you can do that again, just so I can
see it.
Yes, it appears that a finger would affect that
kind of movement.
301:5-11.

02198.51855/4311400.2

9

2x4 Grid:
Q How about Claim 4?
A Claim 4 -MR. MONACH: Same objection.
THE WITNESS: -- is the same. I have the
same answer as Claim 3, really. If Claim 1 is
met, which, as I've said earlier, it may or may
not be met, the object could be a finger, and
your colleague has demonstrated that. So I
think that would be met, if Claim 1 is met.
320:14-22.
Claim 5
The computer-implemented method of claim 1,
wherein the first direction is a vertical
direction, a horizontal direction, or a diagonal
direction.

2x2 Grid:
Q And does Exhibit 114 meet the limitations of
Claim 5?
MR. MONACH: Same objection.
THE WITNESS: When you say "Exhibit 114,"
you mean the device with the application
running on it?
MR. JOHNSON: That's correct.
THE WITNESS: Okay.
Again, given the -- the same qualifications I've
given with my earlier answers with regards to
whether it meets Claim 1, and Claim 5 is a
dependent claim in Claim 1.
Given those qualifications, which I'd like to
incorporate in this current answer, I would say,
given those qualifications, yes, his first
direction is one of a vertical/horizontal or
diagonal, so it would meet -- would meet the
limitations of Claim 5.
301:12-302:2
2x4 Grid:
What is the next claim? Five?
MR. JOHNSON: Five.
THE WITNESS: Again, as in my previous
answers, Claim 5 is dependent on Claim 1, and
given all of the qualifications I've made with
regards to whether Claim 1 is met, if Claim 1 is
met, then Claim 5 would be met as the first

02198.51855/4311400.2

10

direction, is one of these three vertical,
horizontal, or diagonal directions.
320:23-321:6.
Claim 7
The computer-implemented method of claim 1,
wherein the electronic document is a digital
image.

2x2 Grid:
302:3-306:5
2x4 Grid:
MR. JOHNSON: Q. How about Claim 7?
A Claim 7, I'm gonna give the same answer I
gave earlier when you went over this. It's not
clear to me that -- whether that electronic
document consisting of, as you, yourself, said,
2x4 grid of -- of images is whether that
concatenation of imagines is a digital image or
not, or whether that's eight different images or
something else. So I can't say for sure until I've
studied this in more detail.
321:7-15

Claim 9
The computer-implemented method of claim 1,
wherein the electronic document includes a list
of items.

2x2 Grid:
MR. JOHNSON: Q. Does Exhibit 114 meet the
limitations of Claim 9?
MR. MONACH: Same objection.
THE WITNESS: To the extent that if you say
the whole of four images can constitute the
electronic document, I would say, given this
particular set of content there, there appears to
be a list of -- if you don't mind, phone list and
an inbox, which has a list of items there.
So that -MR. JOHNSON: Zoom in.
THE WITNESS: -- the electronic document
includes a list of items, which is what Claim 9
says. It doesn't necessarily mean the whole
document is a list.
306:6-20.

02198.51855/4311400.2

11

2x4 Grid:
Q How about Claim 9?
MR. MONACH: Same objection.
THE WITNESS: Claim 9, I would have to look
at that very quickly again, just to see. So this is
still part of the eight -- eight items, okay.
Claim 9, given the qualifications with regards
to Claim 1, and as I've said, Claim 1 may or
may not be met, depending on some of the
issues there that I've already discussed, and
since Claim 9 is dependent on Claim 1, if
Claim 1 is met, then, in this example, if that is
indeed the electronic document, it appears that
it has, at least in some -- some parts of that
document, has a list of documents that would
be met.
321:16-322:4
Claim 10
The computer-implemented method of claim 1,
wherein the second direction is opposite the
first direction.

2x2 Grid:
MR. JOHNSON: Q. Does it meet the
limitations of Claim 10?
MR. MONACH: Same objection.
THE WITNESS: Based on what he showed me
earlier, and given the qualifications I've already
made regarding Claim 1, I would say it meets
Claim 10, yes.
306:6-307:2
2x4 Grid:
MR. JOHNSON: Q. How about Claim 10?
MR. MONACH: Same objection.
THE WITNESS: Claim 10, again, I would say
it depends on Claim 1, as is clear there, and
given all the qualifications I've made with
regards to whether Claim 1 is met, would apply
here, and if Claim 1 is met, there -- the second
direction of movement could be -- I mean, it's
possible that it's often the first direction.
MR. JOHNSON: Q. So it would be met?
MR. MONACH: Same objection.
THE WITNESS: It would be met if Claim 1 is

02198.51855/4311400.2

12

met with all my qualifications I've already
discussed.
322:5-17.
Claim 13
The computer-implemented method of claim 1,
wherein the area beyond the edge of the
document is black, gray, a solid color, or
white.

2x2 Grid:
307:3-308:19
2x4 Grid:
322:18-323:11

Claim 14
The computer-implemented method of claim 1,
wherein the area beyond the edge of the
document is visually distinct from the
document.

2x2 Grid:
MR. JOHNSON: Q. Does Exhibit 114 meet the
limitations in Claim 14?
MR. MONACH: Same objection as previously
stated to this line of questioning.
THE WITNESS: And that's an even trickier
one, because I'd have to look very carefully at
the content of this stuff that's bouncing around
on the edge there and -- to determine if that
actually is. So, for example, the bottom here -whether -- whether that content is actually
different, I'd have to study it carefully. To the
extent that it is different, then I would say, yes,
it meets it. It would really depend on what that
content is.
308: 20-309:7
2x4 Grid:
Q How about Claim 14?
MR. MONACH: Same objection.
THE WITNESS: To the extent that the area
beyond the edge is some other content that one
could -- could determine to be visually distinct,
it would be met if Claim 1 is met, which it's
not clear, given all of the qualifications I've
already -- I've already -MR. JOHNSON: Q. How about -A -- discussed in this deposition.
323:13-22.

02198.51855/4311400.2

13

Claim 16
The computer-implemented method of claim 1,
wherein changing from translating in the first
direction to translating in the second direction
until the area beyond the edge of the document
is no longer displayed makes the edge of the
electronic document appear to be elastically
attached to an edge of the touch screen display
or to an edge displayed on the touch screen
display.

2x2 Grid:
MR. JOHNSON: Q. Does claim -- does
Exhibit 114 meet the limitations in Claim 16?
MR. MONACH: Same objections.
THE WITNESS: Can you do that first
direction, second direction, and lift it up again,
please. If you don't mind, I'll look at it.
Whoops.
MR. LIEN: Sorry.
THE WITNESS: Or maybe I can play with it,
if you don't mind. I'm having trouble looking at
this thing. Yeah, okay.
Do that again. It would appear to be, again,
with all the caveats of -- all of the
qualifications I've already made with regards to
Claim 1, I would say it appears to be, this
particular example, there might be an elastic
connection there or elastic look to that.
309:8-23.
2x4 Grid:
How about Claim 16?
MR. MONACH: Same objection.
THE WITNESS: Can you do that for me again,
please.
So Claim 16, again, it depends on Claim 1. So
to the extent that Claim 1 is or isn't met would
-- would impact Claim 16, but the portion of
Claim 16 that talks about the elastically
attached, that -- that appears to be
demonstrated in this application. As to whether
the whole claim is met would depend on Claim
1, as I've discussed.
323:24-324:9.

Claim 19
A device, comprising: a touch screen display;
one or more processors; memory; and one or
more programs, wherein the one or more
programs are stored in the memory and
configured to be executed by the one or more
processors, the programs including:
02198.51855/4311400.2

2x2 Grid:
MR. JOHNSON: Q. Does Exhibit 114 meet the
claim limitations described in Claim 19 of the
'381 patent?
MR. MONACH: Same objection as previously
14

instructions for displaying a first portion of an
electronic document; instructions for detecting
a movement of an object on or near the touch
screen display; instructions for translating the
electronic document displayed on the touch
screen display in a first direction to display a
second portion of the electronic document,
wherein the second portion is different from
the first portion, in response to detecting the
movement; instructions for displaying an area
beyond an edge of the electronic document and
displaying a third portion of the electronic
document, wherein the third portion is smaller
than the first portion, in response to the edge of
the electronic document being reached while
translating the electronic document in the first
direction while the object is still detected on or
near the touch screen display; and instructions
for translating the electronic document in a
second direction until the area beyond the edge
of the electronic document is no longer
displayed to display a fourth portion of the
electronic document, wherein the fourth
portion is different from the first portion, in
response to detecting that the object is no
longer on or near the touch screen display.

3 stated.
THE WITNESS: Again, the same
qualifications with regards to Claim 1 in
whether this device meets that or not. To the
extent that this is running a computer program,
like in the Samsung phones, it clearly has one
or more programs running, and then, therefore,
it would meet Claim 19, again given my
qualifications of Claim 1.
309:24-310:10.
2x4 Grid:
MR. JOHNSON: Q. Are the limitations in
Claim 19 met by Exhibit 114 running
LaunchTiles on the iPAQ?
MR. MONACH: Same objection.
THE WITNESS: I haven't had a chance to
study this in great detail, but given that it -given the functionality I've seen here with the
same set of qualifications I've already done
with Claim 1, where the language is repeated,
just the instructions and the number of the -the one or more programs stored and executed,
that would have to -- that would be met, but the
-- the other portions that correspond to a
language in Claim 1 may or may not be met,
depending on my -- depending on the
qualifications I just talked about.
324:10-24
Inbox:
Q Can you tell me if this meets the limitations
of Claims 19 and 20?
MR. MONACH: Same objection.
THE WITNESS: So to the extent that if it
meets the elements of Claim 1, which I've just
discussed it may not, if it didn't meet Claim 1,
then a lot of the language in Claim 19 is not
met or the portion that talks about one or more
programs with instructions in Claim 19, that, I
think, would be met.

02198.51855/4311400.2

15

330:23-331:6.
Claim 20
A computer readable storage medium having
stored therein instructions, which when
executed by a device with a touch screen
display, cause the device to: display a first
portion of an electronic document; detect a
movement of an object on or near the touch
screen display; translate the electronic
document displayed on the touch screen
display in a first direction to display a second
portion of the electronic document, wherein the
second portion is different from the first
portion, in response to detecting the movement
display an area beyond an edge of the
electronic document and display a third portion
of the electronic document, wherein the third
portion is smaller than the first portion, if the
edge of the electronic document is reached
while translating the electronic document in the
first direction while the object is still detected
on or near the touch screen display; and
translate the electronic document in a second
direction until the area beyond the edge of the
electronic document is no longer displayed to
display a fourth portion of the electronic
document, wherein the fourth portion is
different from the first portion, in response to
detecting that the object is no longer on or near
the touch screen display.

2x2 Grid:
MR. JOHNSON: Q. And does Exhibit 114
meet Claim 1?
MR. MONACH: Same objection.
THE WITNESS: And my, kind of, similar
answer, taking all my -- my qualifications with
regards to Claim 1, you would have to have
some kind of storage media, so it would meet
Claim 20, with the same set of qualifications
for all of the different elements.
310:11-19.
2x4 Grid:
MR. JOHNSON: Q. And how about Claim 20?
Would that be met by Exhibit 114?
MR. MONACH: Same objection.
THE WITNESS: Claim 20, again, similar to
my answer for Claim 19, it has all the language
of Claim 1, and that would have the same
qualifications that I've already discussed, or the
portion about the instructions being stored in a
computer storage medium, I think that would
have to -- that would be present on that device.
324:35-325:9.
Inbox:
MR. JOHNSON: Q. And what about Claim
20?
MR. MONACH: Same objection.
THE WITNESS: Same kind of answer with
Claim 20. To the extent that the elements of
Claim 20 that regard -- relate to Claim 1, they
may not be met, as I've just discussed with
Claim 1, but the portion about a readable
storage medium having stored their
instructions, which executed that portion,
would be met.
331:7-15.

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*To the right is an excerpt taken
from Exhibit 115 from the
Deposition of Dr. Ravin
Balakrishnan. This excerpt
identifies the numbered elements
or limitations that Dr. Balakrishnan
refers to within the testimony cited
in the chart above. For ease of
reference, this excerpt has been
provided here.

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17