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

Filing 2126

Declaration of Susan Estrich in Support of 2013 MOTION for Judgment as a Matter of Law, New Trial and/or Remittitur Pursuant to Federal Rules of Civil Procedure 50 and 59, 2054 Brief, 2053 Opposition/Response to Motion, filed bySamsung Electronics America, Inc.(a New York corporation), Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC. (Attachments: # 1 Exhibit 1 to the Estrich Declaration, # 2 Exhibit 2 to the Estrich Declaration, # 3 Exhibit 3 to the Estrich Declaration, # 4 Exhibit 4 to the Estrich Declaration, # 5 Exhibit 5 to the Estrich Declaration, # 6 Exhibit 6 to the Estrich Declaration, # 7 Exhibit 7 to the Estrich Declaration, # 8 Exhibit 8 to the Estrich Declaration, # 9 Exhibit 9 to the Estrich Declaration, # 10 Exhibit 10 to the Estrich Declaration, # 11 Exhibit 11 to the Estrich Declaration, # 12 Exhibit 12 to the Estrich Declaration, # 13 Exhibit 13 to the Estrich Declaration, # 14 Exhibit 14 to the Estrich Declaration, # 15 Exhibit 15 to the Estrich Declaration, # 16 Exhibit 16 to the Estrich Declaration, # 17 Exhibit 17 to the Estrich Declaration, # 18 Exhibit 18 to the Estrich Declaration, # 19 Exhibit 19 to the Estrich Declaration, # 20 Exhibit 20 to the Estrich Declaration, # 21 Exhibit 21 to the Estrich Declaration, # 22 Exhibit 22 to the Estrich Declaration, # 23 Exhibit 23 to the Estrich Declaration, # 24 Exhibit 24 to the Estrich Declaration, # 25 Exhibit 25 to the Estrich Declaration, # 26 Exhibit 26 to the Estrich Declaration, # 27 Exhibit 27 to the Estrich Declaration, # 28 Exhibit 28 to the Estrich Declaration, # 29 Exhibit 29 to the Estrich Declaration, # 30 Exhibit 30 to the Estrich Declaration, # 31 Exhibit 31 to the Estrich Declaration)(Related document(s) 2013 , 2054 , 2053 ) (Maroulis, Victoria) (Filed on 11/9/2012)

Estrich Declaration
Exhibit 1

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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APPLE INC., A CALIFORNIA
CORPORATION,

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PLAINTIFF,
VS.
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,

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DEFENDANTS.

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C-11-01846 LHK
SAN JOSE, CALIFORNIA
JULY 30, 2012
VOLUME 1
PAGES 1-282

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TRANSCRIPT OF PROCEEDINGS
BEFORE THE HONORABLE LUCY H. KOH
UNITED STATES DISTRICT JUDGE

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APPEARANCES ON NEXT PAGE

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OFFICIAL COURT REPORTER: LEE-ANNE SHORTRIDGE, CSR, CRR
CERTIFICATE NUMBER 9595

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A P P E A R A N C E S:

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FOR PLAINTIFF
APPLE:

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MORRISON & FOERSTER
BY: HAROLD J. MCELHINNY
MICHAEL A. JACOBS
RACHEL KREVANS
425 MARKET STREET
SAN FRANCISCO, CALIFORNIA

94105

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FOR COUNTERCLAIMANT WILMER, CUTLER, PICKERING,
APPLE:
HALE AND DORR
BY: WILLIAM F. LEE
60 STATE STREET
BOSTON, MASSACHUSETTS 02109

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BY: MARK D. SELWYN
950 PAGE MILL ROAD
PALO ALTO, CALIFORNIA

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QUINN, EMANUEL, URQUHART,
OLIVER & HEDGES
BY: CHARLES K. VERHOEVEN
50 CALIFORNIA STREET, 22ND FLOOR
SAN FRANCISCO, CALIFORNIA 94111

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BY:

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FOR THE DEFENDANT:

94304

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VICTORIA F. MAROULIS
KEVIN P.B. JOHNSON
555 TWIN DOLPHIN DRIVE
SUITE 560
REDWOOD SHORES, CALIFORNIA

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BY:

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94065

MICHAEL T. ZELLER
WILLIAM C. PRICE
865 SOUTH FIGUEROA STREET
10TH FLOOR
LOS ANGELES, CALIFORNIA 90017

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AFTERNOON SESSION

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(WHEREUPON, THE FOLLOWING PROCEEDINGS

3

WERE HELD OUT OF THE PRESENCE OF THE PROSPECTIVE

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JURORS.)

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THE COURT:

OKAY.

ONE QUESTION THAT I

6

HAVE -- WELCOME BACK, EVERYBODY -- IS WHAT WE

7

SHOULD DO TODAY AFTER THE JURY IS SELECTED.

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9
10

I COULD SHOW THEM THE VIDEO AND READ THE
STATEMENT REGARDING THE FEDERAL JUDICIAL CENTER
VIDEO.

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I'M RELUCTANT TO START WITH THE JURY

12

INSTRUCTIONS IF WE DON'T HAVE THE LIMITING

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INSTRUCTION AS TO MR. NISHIBORI COMPLETELY

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RESOLVED, AND I DON'T WANT TO SORT OF READ IT

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SEPARATELY AS AN ADD-ON TOMORROW.

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DOES THAT MAKE ANY SENSE?

BECAUSE THEN

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IT JUST MAKES IT SEEM LIKE THAT'S NOT PART OF THE

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PACK.

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MR. VERHOEVEN:

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THE COURT:

YES, YOUR HONOR.

SO SHOULD WE AT LEAST SHOW

21

THE VIDEO?

I DON'T WANT TO ALSO LOSE A GOOD CHUNK

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OF TIME THIS AFTERNOON, EITHER.

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SO WE COULD SHOW THE VIDEO AND JUST READ

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THE FJC STATEMENT AND JUST SAVE THE READING OF ALL

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THE JURY INSTRUCTIONS UNTIL TOMORROW, OR I COULD AT

147

1

LEAST READ THE PRELIMINARY ONES AND GIVE THEM THE

2

BOOKS TOMORROW FOR ALL OF THEM.

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DO HAVE ANY THOUGHTS ON THIS?

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MR. VERHOEVEN:

I THINK WE AGREE THAT IT

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WOULDN'T MAKE SENSE TO SEPARATE THE NISHIBORI

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INSTRUCTION SEPARATE FROM THE OTHERS AND THE

7

INITIAL INCLINATION WOULD BE CORRECT.

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9

MR. MCELHINNY:

I ACTUALLY DON'T -- I

THINK THE PROPER TIME FOR A LIMITING INSTRUCTION IS

10

WHEN THE EVIDENCE -- I BELIEVE THAT THE TIME FOR

11

THE LIMITING INSTRUCTION IS WHEN THE EVIDENCE COMES

12

INTO EVIDENCE.

13

BUT IF YOUR HONOR IS GOING TO ALLOW IT IN

14

THE OPENING, THEN I THINK THAT'S THE FIRST TIME

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THEY'LL HEAR IT AND THAT'S IT.
I THINK A LIMITING INSTRUCTION THAT

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17

POINTS TO SPECIFIC EVIDENCE AND SAYS "THIS IS THE

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REASON I'M LETTING THIS IN," TO FOLD THAT IN A

19

PACKAGE OF FOUR MINUTES OF PRELIMINARY -- I THINK

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IT OBVIATES THE PURPOSE OF IT BECAUSE IT'S SUPPOSED

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TO BE TYING THE JURY'S MIND TO WHEN THEY FIRST HEAR

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THE EVIDENCE SO THEY KNOW WHAT YOU'RE TALKING

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ABOUT.

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25

THE COURT:
JURY UP --

ALL RIGHT.

LET'S BRING OUR

148

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2

THE CLERK:

I'M WAITING TO HEAR FROM

MR. YOUNGER IF THEY'RE ALL DOWN THERE.

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THE COURT:

I'M SORRY?

4

THE CLERK:

I'M WAITING TO HEAR FROM J

5

WHETHER THEY'RE ALL DOWN THERE.

6

HE WAS GOING TO DO

ANOTHER ROLE CALL.

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THE COURT:

8

(DISCUSSION OFF THE RECORD BETWEEN THE

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OH, ON ALL OF THEM?

OKAY.

COURT AND THE CLERK.)

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(PAUSE IN PROCEEDINGS.)

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(WHEREUPON, THE FOLLOWING PROCEEDINGS

12

WERE HELD IN OF THE PRESENCE OF THE PROSPECTIVE

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JURORS.)

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THE COURT:

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TAKE A SEAT.

16

OKAY.

WELCOME BACK.

PLEASE

WE HAD A FEW MORE DEPARTURES IN YOUR

ABSENCE.

17

LET'S CONTINUE WITH THE QUESTIONS.

18

THE NEXT QUESTION IS, HAVE YOU OR A

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FAMILY MEMBER OR SOMEONE VERY CLOSE TO YOU EVER

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BEEN INVOLVED IN A LAWSUIT, EITHER AS A PLAINTIFF,

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A DEFENDANT, OR AS A WITNESS?

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LET'S SEE.

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ON THE FIRST ROW, WHO WOULD

RAISE THEIR HAND TO THAT QUESTION?

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ALL RIGHT.

LET'S GO TO MR. HOGAN.

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PROSPECTIVE JUROR:

IN 2008, AFTER MY

149

1

COMPANY WENT BELLY UP, THE PROGRAMMER THAT WORKED

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FOR ME FILED A LAWSUIT AGAINST ME AND ULTIMATELY,

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ACROSS THE NEXT FEW MONTHS, IT WAS DISMISSED AND IN

4

SUCH A FASHION THAT NEITHER ONE OF US COULD SUE THE

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OTHER ONE FOR THAT MATTER.

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7
8
9

THE COURT:

WHAT WAS HIS -- WHAT WAS THE

EMPLOYEE'S CLAIM?
PROSPECTIVE JUROR:

IT WAS A DISPUTE OVER

THE SOFTWARE THAT WE HAD DEVELOPED, WHETHER IT

10

BELONGED TO THE COMPANY OR TO HIM, AND I HAD

11

DOCUMENTS THAT SHOWED IT BELONGED TO THE COMPANY.

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13
14

ULTIMATELY, AS I SAID, IT WOULD -- WE
SETTLED OUT OF COURT AND IT WAS DISMISSED.
THE COURT:

ALL RIGHT.

ANYTHING ABOUT

15

THAT EXPERIENCE THAT WOULD AFFECT YOUR ABILITY TO

16

BE FAIR AND IMPARTIAL TO BOTH SIDES IN THIS CASE?

17

PROSPECTIVE JUROR:

18

THE COURT:

OKAY.

I DON'T BELIEVE SO.
WAS THERE ANY

19

DISPUTE -- WAS THERE ANY DISPUTE AS TO WHO HAD

20

CREATED AND INVENTED THE TECHNOLOGY, OR WAS IT

21

LARGELY WHO HAD OWNERSHIP OF IT?

22

PROSPECTIVE JUROR:

IT WAS STRICTLY WHO

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HAD OWNERSHIP OF IT, AND ULTIMATELY IT WAS

24

ESTABLISHED THAT THE COMPANY DID HAVE OWNERSHIP OF

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IT, ALTHOUGH -- AND I STILL DO -- ALTHOUGH THE

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1

COMPANY IS NOT IN BUSINESS ANY LONGER.

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THE COURT:

I SEE.

BUT WAS THERE A SORT

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OF DISPUTE AS TO WHO HAD CREATED OR INVENTED THE

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TECHNOLOGY AS PART OF THAT OWNERSHIP QUESTION?

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PROSPECTIVE JUROR:

6

THE COURT:

7

PROSPECTIVE JUROR:

YES, THERE WAS.

UM-HUM.
BUT LIKE I SAID, WE

8

SETTLED THAT -- BECAUSE OF DOCUMENTATION I HAD, WE

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WERE ABLE TO SETTLE IT OUT OF COURT AND THEN WE

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WENT BACK TO COURT ONE LAST TIME FOR THE DISMISSAL

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PAPERWORK.

12

THE COURT:

13

MS. ROUGIERI, I THINK YOU RAISED YOUR

14

OKAY.

PROSPECTIVE JUROR:

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THE COURT:

17

PROSPECTIVE JUROR:

19

THANK YOU.

CARD?

15

18

ALL RIGHT.

AGAINST A DENTIST.
THE COURT:

YES, I DID.

GO AHEAD.
I BROUGHT A LAWSUIT

THAT WAS IN 2005, 2006.
OH, CAN WE HAVE THE

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MICROPHONE?

APPARENTLY IN THE OVERFLOW ROOM, THEY

21

CAN'T HEAR THE JURORS WITHOUT THE MICROPHONE.

22

THANK YOU.

23

PROSPECTIVE JUROR:

I HAD A SMALL CLAIM

24

AGAINST A DENTIST THAT WAS IN 2005.

IT WORKED OUT

25

THAT WHEN WE DID THE SMALL CLAIM, I WON THE FIRST

151

1

TIME, AND HE HAD AN APPEAL AND HE BROUGHT HIS

2

LAWYER AND I LOST.

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THE COURT:

4

REPRESENTED YOURSELF?

5

ALL RIGHT.

SO YOU

COURT?

6
7
8
9
10

WAS THAT IN SMALL CLAIMS

PROSPECTIVE JUROR:

IT WAS IN SMALL

CLAIMS COURT.
THE COURT:

OKAY.

ANYTHING ABOUT THAT

EXPERIENCE THAT WOULD AFFECT YOUR ABILITY TO BE
FAIR AND IMPARTIAL IN THIS CASE?

11

PROSPECTIVE JUROR:

WELL, NO.

12

BUT IT AFFECTED ME BECAUSE THE LAWYER

13

KNOWS THE JUDGE.

14

KNOWS THE JUDGE, SO THEY WERE TALKING FRIENDLY

15

TERMS IN A WAY THAT THE CHILDREN, THEY PLAYED EACH

16

OTHER TOGETHER IN SCHOOL.

17

THE LAWYER THAT WAS AGAINST ME

AND THAT REALLY I THINK -- MY BELIEF IS

18

THAT THAT'S HOW I LOST THE CASE, BECAUSE THE LAWYER

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KNOWS THE JUDGE.

20

THE COURT:

WAS THAT AFTER IT WAS

21

APPEALED TO THE SUPERIOR COURT JUDGE?

22

PROSPECTIVE JUROR:

23

THE COURT:

YES.

AND YOU'RE SAYING THAT THE

24

LAWYER KNEW THE SUPERIOR COURT JUDGE?

25

PROSPECTIVE JUROR:

CORRECT, YES.

152

1
2

THE COURT:

AND YOU THOUGHT THAT

THERE WAS SOME UNFAIRNESS?

3
4

I SEE.

PROSPECTIVE JUROR:

UNFAIRNESS TO THAT,

YES.

5

THE COURT:

OKAY.

WOULD YOUR NEGATIVE

6

IMPRESSION FROM THAT EXPERIENCE SPILL OVER INTO

7

THIS CASE AT ALL?

8

PROSPECTIVE JUROR:

9

THE COURT:

OKAY.

10

PROSPECTIVE JUROR:

11

THE COURT:

12

NO, NO, YOUR HONOR.

I -- NO, YOUR HONOR.

ALL RIGHT.

AND THIS IS FOR

EVERYONE.

13

WE'LL TALK FURTHER ABOUT WHO'S BEEN ON

14

JURY DUTY, BUT THERE ARE DEFINITELY DIFFERENT, YOU

15

KNOW, STANDARDS OF PROOF IN DIFFERENT CASES, AND I

16

JUST WANTED TO MAKE SURE -- YOU ALL HAD CIVIL

17

CASES, SO I WOULD ASSUME THAT YOU ALSO HAD, YOU

18

KNOW, PREPONDERANCE OF THE EVIDENCE.

19

SOUND FAMILIAR?

DOES THAT

20

AND WE'LL TALK ABOUT THIS A LITTLE BIT

21

LATER ON, BUT IN DIFFERENT TYPES OF CASES, THERE

22

MAY BE DIFFERENT STANDARDS OF PROOF, AND ALSO THE

23

LAW MAY HAVE CHANGED SINCE WHENEVER YOU WERE A

24

LITIGANT.

25

SO I WANT TO MAKE SURE THAT BOTH

153

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MR. HOGAN, AND MS. ROUGIERI, THAT YOU WOULD APPLY

2

THE LAW AS I INSTRUCT YOU AND NOT BASED ON YOUR

3

UNDERSTANDING OF THE LAW BASED ON YOUR OWN CASES.

4

IS THAT CORRECT, MR. HOGAN?

5

PROSPECTIVE JUROR:

6

THE COURT:

7

PROSPECTIVE JUROR:

8

THE COURT:

9

AND MS. ROUGIERI?

OKAY.

YES.
ANYONE ELSE IN THE

FIRST ROW?

10

PROSPECTIVE JUROR:

11

THE COURT:

12

YES.

MICROPHONE?

YES, SMALL CLAIMS --

WOULD YOU PLEASE USE THE

THANK YOU.

13

PROSPECTIVE JUROR:

14

AND I THINK IT WAS AT THE END OF 2011.
THE COURT:

15
16
17
18
19
20

CLAIM?

WHAT WAS THE BASIS OF THE

WERE YOU A DEFENDANT OR A CLAIMANT?
PROSPECTIVE JUROR:

I BROUGHT SOMEONE TO

COURT WHO OWED ME MONEY.
THE COURT:

AND WHAT WAS THE -- HOW DID

THAT RESOLVE?

21

PROSPECTIVE JUROR:

22

THE COURT:

23

PROSPECTIVE JUROR:

24

THE COURT:

25

SMALL CLAIMS COURT,

IT WAS IN MY FAVOR.

DID YOU REPRESENT YOURSELF?
YES.

ALL RIGHT.

ANYTHING BASED ON

THAT EXPERIENCE THAT LEAVES YOU WITH A LASTING

154

1

IMPRESSION ABOUT THE JUSTICE SYSTEM, ABOUT THE

2

COURTS, ABOUT --

3

PROSPECTIVE JUROR:

4

THE COURT:

5

NO, NO.

-- THE JUDICIARY THAT WOULD

AFFECT YOUR ABILITY TO BE FAIR HERE?

6

PROSPECTIVE JUROR:

7

THE COURT:

8

ANYONE ELSE ON ROW 2?

9

ALL RIGHT.

10

NO, NO PROBLEM.

ALL RIGHT.

THANK YOU.

LET'S GO TO MS. FRIESEN.

PROSPECTIVE JUROR:

THERE WAS A SMALL

11

CLAIMS COURT CASE IN REGARDS TO THE BUSINESS I HAD,

12

IT WAS AN ADVERTISING CASE, AND THE OTHER COMPANY

13

WON THE SUIT.

14
15

THE COURT:

WERE YOU THE PLAINTIFF OR THE

DEFENDANT?

16

PROSPECTIVE JUROR:

17

THE COURT:

18

AND THIS WAS WITH REGARD TO

YOUR FRANCHISE INSURANCE AGENCY?

19

PROSPECTIVE JUROR:

20

THE COURT:

21

PROSPECTIVE JUROR:

22

THE COURT:

23

DEFENDANT.

OKAY.

CORRECT.
WHEN WAS THIS LAWSUIT?
I THINK IT WAS 2008.

I THOUGHT YOUR BUSINESS ENDED

IN 2006.

24

PROSPECTIVE JUROR:

25

THE COURT:

OH.

CORRECT.

THIS WAS AFTER THE

155

1

BUSINESS HAD ALREADY RESOLVED?

2

PROSPECTIVE JUROR:

3

THE COURT:

4

OKAY.

CORRECT.
AND YOU REPRESENTED

YOURSELF; RIGHT?

5

PROSPECTIVE JUROR:

6

THE COURT:

OKAY.

YES.
ANYTHING FROM THAT

7

EXPERIENCE THAT LEFT YOU WITH A, EITHER A BAD TASTE

8

IN YOUR MOUTH OR A GOOD TASTE IN YOUR MOUTH ABOUT

9

THE SYSTEM, ABOUT JUDGES, LAWYERS THAT WOULD AFFECT

10

YOUR ABILITY TO BE FAIR HERE?

11

PROSPECTIVE JUROR:

12

THE COURT:

13

WHAT ABOUT ROW 3?

14
15
16

HAND?

OKAY.

NOT THAT I KNOW OF.
ALL RIGHT.

THANK YOU.

ANYONE RAISE THEIR

NO?
THE RECORD SHOULD REFLECT NO HANDS HAVE

BEEN RAISED.

17

WHAT ABOUT ROW 4, ROW 5?

18

OH, I'M SORRY.

19
20
21
22
23
24
25

MS. HOLLOWAY, DID YOU

HAVE YOUR HAND RAISED?
IF YOU COULD PASS THE MICROPHONE, PLEASE,
TO MS. HOLLOWAY.
PROSPECTIVE JUROR:

WORK-RELATED LAWSUIT

BACK IN 1986.
THE COURT:
THE DEFENDANT?

AND WERE YOU THE PLAINTIFF OR

156

1

PROSPECTIVE JUROR:

2

THE COURT:

3

PROSPECTIVE JUROR:

DEFENDANT.

AND WHAT WAS THE CLAIM?
AT THE TIME I WAS

4

WORKING FOR INTEL, AND SO ONE OF MY STAFF MEMBERS

5

BROUGHT A LAWSUIT AGAINST INTEL.

6

A DEPOSITION AND THEN HE DROPPED THE CASE.

7
8

THE COURT:

WAS IT SOME TYPE OF

EMPLOYMENT CASE?

9

PROSPECTIVE JUROR:

YES, IT WAS.

THE COURT:

10
11

OKAY.

WE WENT AS FAR AS

SO WERE YOU ACTUALLY

I SEE.

DEPOSED?

12

PROSPECTIVE JUROR:

I WAS THE MANAGER.

13

THE COURT:

BUT YOU WERE DEPOSED,

14

OR NOT?

I SEE.

DID THEY TAKE YOUR DEPOSITION?

15

PROSPECTIVE JUROR:

OH, ABSOLUTELY, YES.

16

THE COURT:

ALL RIGHT.

I SEE.

AND YOU

17

SAID THAT CASE RESOLVED HOW?

IT WAS --

18

PROSPECTIVE JUROR:

19

THE COURT:

20

ANYTHING FROM YOUR EXPERIENCE IN THAT

HE DROPPED THE CASE.

HE DROPPED THE CASE.

OKAY.

21

CASE THAT WOULD AFFECT YOUR ABILITY TO BE FAIR AND

22

IMPARTIAL HERE?

23

PROSPECTIVE JUROR:

24

THE COURT:

25

ANYONE ON ROWS -- I KNOW MR. SINA, YOU

OKAY.

NONE WHATSOEVER.
ALL RIGHT.

THANK YOU.

157

1

RAISED YOUR HAND.

2

GO AHEAD.

PROSPECTIVE JUROR:

YES.

BACK IN 1998, I

3

HAD A SURGERY.

4

PURSUED BY THE DOCTOR AND I WENT TO THE JUDGE AND

5

WE AGREED TO -- I AGREED TO PAY THE FEES IN

6

INSTALLMENTS.

7
8

PROSPECTIVE JUROR:

15
16

I'M SORRY.

AT THAT

TIME, MY ENGLISH WAS NOT VERY GOOD, SO -THE COURT:

ALL RIGHT.

WAS THAT HERE IN

SANTA CLARA COUNTY?

13
14

WAS THAT IN SMALL CLAIMS

COURT?

11
12

I WAS

THAT'S ALL I HAVE.

THE COURT:

9
10

I DIDN'T HAVE INSURANCE.

PROSPECTIVE JUROR:

NO, NO.

IT WAS IN

THE COURT:

AND IT WAS -- WERE

INDIANA.
I SEE.

YOU REPRESENTING YOURSELF?

17

PROSPECTIVE JUROR:

18

THE COURT:

OKAY.

I BELIEVE SO.
ANYTHING FROM THAT

19

EXPERIENCE THAT WOULD IMPACT YOUR ABILITY TO BE

20

FAIR AND IMPARTIAL IN ANY WAY?

21

PROSPECTIVE JUROR:

22

THE COURT:

23

PROSPECTIVE JUROR:

24

THE COURT:

25

ANYONE ON ROW 5?

I HOPE NOT.

NO?

OKAY.

NO.
ALL RIGHT.
OR ROW 6?

THANK YOU.
I'M SORRY.

158

1
2

OKAY.

THE RECORD SHOULD REFLECT NO HANDS

HAVE BEEN RAISED.

3

OKAY.

NOW, RAISE YOUR HAND, PLEASE, IF

4

YOU HAVE EVER APPLIED FOR A PATENT, A COPYRIGHT, A

5

TRADEMARK OR TRADE DRESS REGISTRATION.

6
7

ALL RIGHT.
RAISED.

8
9
10
11

SO WE HAVE THREE HANDS

IF YOU WOULD -- OH, FOUR.

ALL RIGHT.

WELL, SINCE THE MICROPHONE IS DOWN THERE,
WHY DON'T YOU GO AHEAD PLEASE AND GIVE THAT TO
MR. CHIU.
PROSPECTIVE JUROR:

I WORK FOR -- I WORK

12

FOR THE NATIONAL SEMICONDUCTOR BEFORE AND THEY WERE

13

ACQUIRED BY TEXAS INSTRUMENTS, AND I FILED PATENTS

14

FOR THE COMPANY.

15
16

THE COURT:

OKAY.

INVENTOR ON THAT PATENT?

17

PROSPECTIVE JUROR:

18

THE COURT:

19

PROSPECTIVE JUROR:

20

THE COURT:

21
22
23

AND WERE YOU AN

YES.

WAS A PATENT ISSUED?
YES.

AND WITHOUT SPECIFICS, WHAT

WAS THE GENERAL TECHNOLOGY?
PROSPECTIVE JUROR:

IT IS THE INTEGRATED

CIRCUIT RELATED.

24

THE COURT:

INTEGRATED CIRCUIT DESIGN?

25

PROSPECTIVE JUROR:

YES.

159

1

THE COURT:

2

PROSPECTIVE JUROR:

3

YEARS.

4

OKAY.

HOW LONG AGO WAS THAT?
I THINK FROM 3 TO 15

I HAVE SEVERAL PATENTS.
THE COURT:

YOU HAVE SEVERAL.

AND WERE

5

THEY ALL WHILE YOU WERE EMPLOYED AT NATIONAL

6

SEMICONDUCTOR?

7

PROSPECTIVE JUROR:

8

THE COURT:

9

AND ARE THEY ALL RELATED TO

INTEGRATED CIRCUIT DESIGN?

10

PROSPECTIVE JUROR:

11

THE COURT:

12

RIGHT.

13
14

AND -- OKAY.

ALL

AND THEY WERE ROUGHLY 15 YEARS AGO?
YES, FROM 3 TO 15

YEARS.
THE COURT:

3 TO 15 YEARS.

OKAY.

SO

VERY RECENTLY.

17
18

YES.

ALL RIGHT.

PROSPECTIVE JUROR:

15
16

YES.

DO YOU HAVE PATENT APPLICATIONS PENDING
NOW?

19

PROSPECTIVE JUROR:

20

THE COURT:

YES.

YOU DO.

21

PROSPECTIVE JUROR:

23

THE COURT:

24

PROSPECTIVE JUROR:

25

THE COURT:

ALL WITHIN

INTEGRATED CIRCUIT DESIGN --

22

OKAY.

YES.

-- FIELD?

OKAY.

RIGHT.
ALL RIGHT.

WOULD THAT

160

1

IN ANY WAY -- YOU'LL BE INSTRUCTED ON WHAT THE LAW

2

IS AND WOULD YOU BE ABLE TO FOLLOW THE INSTRUCTIONS

3

I GIVE YOU ON THE LAW, EVEN IF IT MAY NOT

4

COMPLETELY CORRESPOND TO WHAT YOU MAY KNOW ABOUT

5

THE PATENT SYSTEM OR THE INTELLECTUAL PROPERTY

6

LAWS?

7
8

PROSPECTIVE JUROR:
INSTRUCTIONS.

9

THE COURT:

10
11

YES, I FOLLOW YOUR

OKAY.

ALL RIGHT.

THANK YOU.

LET'S GO, I THINK, TO MS. HALIM,
MR. OKAMOTO, AND MR. HOGAN.

12

OKAY.

13

PROSPECTIVE JUROR:

14

PATENTS.

15

YOU RAISED YOUR HANDS.

LET'S PLEASE START WITH MS. HALIM.
OKAY.

I HAVE TWO

I.C. DESIGN.

ONE IS ISSUED WHEN I WAS AT WEITEK, ALSO

16

ANOTHER ONE WAS AT SILICON GRAPHICS.

17

THE COURT:

18

AND IT WAS ALSO ON I.C.

DESIGN?

19

PROSPECTIVE JUROR:

20

THE COURT:

21

PROSPECTIVE JUROR:

22

THE COURT:

23

OKAY.

YES, RIGHT.
WERE PATENTS ISSUED?
YES.

AND YOU WERE THE INVENTOR ON

BOTH?

24

PROSPECTIVE JUROR:

25

THE COURT:

OKAY.

YES.
ALL RIGHT.

ANYTHING

188

1

ABOUT PREVIOUSLY?

WHAT WERE HIS EMPLOYERS?

2

PROSPECTIVE JUROR:

CISCO SYSTEMS.

3

THE COURT:

OKAY.

I SEE.

4

YOUR CHILDREN CURRENTLY WORKING?

5

AND ARE ANY OF

STUDENTS?

6
7

PROSPECTIVE JUROR:

THEY ARE STUDENT.

ONE IS WORKING ON INTERNSHIP AT FACEBOOK.

8

THE COURT:

9

PROSPECTIVE JUROR:

OKAY.

10

THE COURT:

11

PROSPECTIVE JUROR:

12

THE COURT:

13

PROSPECTIVE JUROR:

14

THE COURT:

15

ARE THEY

YEAH.

AND THE OTHERS ARE STUDENTS?

OKAY.

YES.
THANK YOU.
THANK YOU.

WOULD YOU PLEASE PASS THE

MICROPHONE TO MR. OKAMOTO PLEASE?
PROSPECTIVE JUROR:

16

MY NAME IS STEVE

17

OKAMOTO.

I WAS BORN IN LAGUNA BEACH, CALIFORNIA.

18

I CURRENTLY RESIDE IN SAN JOSE.
I HAVE A MASTER'S DEGREE IN INDUSTRIAL

19
20

PSYCHOLOGY FROM CAL STATE LONG BEACH.

21

U.C. IRVINE IN PSYCHOLOGY.

22

UNDERGRAD AT

CURRENT JOB TITLE, I'M A DESIGNER FOR

23

GOOGLE.

RESPONSIBILITIES INCLUDE DESIGNING

24

INTERFACES -- RESPONSIBILITIES INCLUDE DESIGNING

25

THE USER INTERFACE, RUNNING TESTS ON THOSE, AND

189

1

ITERATIONS, WORKING WITH ENGINEERING TO GET THOSE

2

CODED.

3

PREVIOUS JOBS, I'VE BEEN AT EBAY, I'VE

4

BEEN AT IBM, I'VE BEEN AT CADENCE DESIGN SYSTEMS

5

AND PROPEL, WHICH WAS A START-UP.

6
7

FAVORITE HOBBY, I KIND OF LIKE GADGETS,
ELECTRONICS.

8
9

WE HAVE TWO KIDS, SO I LIKE TO DO A LOT
OF SPORTS WITH THE KIDS, SO SPORTS.

10

I'M CURRENTLY MARRIED.

11

THE COUNTY AS A COURT OFFICER.

12

MY WIFE WORKS FOR

THAT FOR SEVERAL YEARS NOW.

13

SHE'S BEEN DOING

PRIOR TO THAT, THAT WOULD BE IN '98 SHE

14

BECAME A COURT OFFICER, OR SHE WORKED FOR THE

15

COUNTY.

16

RESEARCH.

17
18

PRIOR TO THAT, SHE WAS DOING CANCER

MY CHILDREN, I HAVE A SON WHO'S 8 AND MY
DAUGHTER IS 11, AND THEY'RE BOTH GOING TO SCHOOL.

19

AND I HAVE HAD NO PRIOR JURY EXPERIENCE.

20

THE COURT:

21
22
23

THANK YOU.

CAN YOU TELL ME A

LITTLE BIT MORE WHAT YOUR WIFE DOES FOR THE COURT?
PROSPECTIVE JUROR:

SO SHE WAS A

PROBATION OFFICER.

24

THE COURT:

UM-HUM.

25

PROSPECTIVE JUROR:

AND NOW SHE'S A COURT

190

1

OFFICER, SO I GUESS SHE JUST REPRESENTS THE COUNTY

2

IN COURT.

3

THE COURT:

AS A PROBATION OFFICER?

4

PROSPECTIVE JUROR:

YEAH.

WELL, I GUESS

5

SHE'S A COURT OFFICER, BUT SHE REPRESENTS THE

6

PROBATION DEPARTMENT.

7
8

THE COURT:

RIGHT.

OKAY.

AND THAT'S FOR

SANTA CLARA COUNTY?

9

PROSPECTIVE JUROR:

10

THE COURT:

OKAY.

11

MR. HOGAN?

12

PROSPECTIVE JUROR:

YES.

13

MY NAME IS VELVIN HOGAN.

14

TEXAS.

ALL RIGHT.

THANK YOU.

MY NAME -- EXCUSE ME,

I WAS BORN IN GREENVILLE,

I RESIDE IN SAN JOSE, CALIFORNIA.
I HAVE AN A.A. DEGREE FROM SAN JOSE CITY

15
16

COLLEGE AND I ATTENDED SAN JOSE STATE IN THE

17

ELECTRICAL ENGINEERING DEPARTMENT, THOUGH I DID NOT

18

GRADUATE.
I HAVE BEEN IN -- I WAS IN THE HARD DRIVE

19
20

INDUSTRY FOR 35-PLUS YEARS AS AN ELECTRICAL

21

ENGINEER.

22

DIGITAL EQUIPMENT CORPORATION TO NAME A FEW, SEVEN

23

ALTOGETHER.

24
25

I WORKED FOR COMPANIES LIKE MEMOREX,

AND MY HOBBIES ARE WHAT I WAS DOING IN
THE REALM OF VIDEO COMPRESSION.

191

1

AND I AM MARRIED.

2

AND MY -- I HAVE TWO CHILDREN, A SON 43

3
4
5
6

AND A DAUGHTER 42.
MY DAUGHTER WORKS FOR THE COUNTY AND MY
SON WORKS IN PRIVATE INDUSTRY.
AND I HAVE BEEN A JUROR IN THE PAST ON

7

THREE DIFFERENT OCCASIONS, BUT THEY WERE ALL THREE

8

CIVIL CASES.

9

THE COURT:

CAN YOU TELL US -- LET ME

10

BACK UP A SECOND.

11

DOES SHE DO OR DID SHE WORK OUTSIDE THE HOUSE?

12

WHAT ABOUT YOUR SPOUSE?

PROSPECTIVE JUROR:

WHAT

SHE'S RETIRED

13

CURRENTLY, BUT BEFORE SHE RETIRED, SHE WORKED FOR

14

THE SAN JOSE UNIFIED SCHOOL DISTRICT.

15

SPECIAL EDUCATION -- NOT A CREDENTIALED TEACHER,

16

BUT A CERTIFIED ASSISTANT.

17

THE COURT:

ALL RIGHT.

SHE WAS A

AND CAN YOU TELL

18

US THE SEVEN COMPANIES YOU WORKED FOR?

19

EQUIPMENT, MEMOREX?

20

PROSPECTIVE JUROR:

OKAY.

DIGITAL

TO BEGIN WITH,

21

I WORKED FOR A COMPANY THAT NO LONGER EXISTS CALLED

22

CAYLIS MEMORIES; THEN MEMOREX CORPORATION; THEN

23

STORAGE TECHNOLOGY CORPORATION IN COLORADO; DIGITAL

24

EQUIPMENT CORPORATION IN COLORADO SPRINGS; I WORKED

25

FOR SEAGATE TECHNOLOGY; AND THE LAST COMPANY WAS --

192

1

AND THEN MICROPOLIS CORPORATION, WHICH NO LONGER

2

EXISTS; AND QUANTUM.

3

THE COURT:

ALL RIGHT.

AND YOUR DAUGHTER

4

THAT WORKS FOR THE COUNTY, IS THAT IN ANY WAY FOR

5

THE COURT SYSTEM?

6

PROSPECTIVE JUROR:

NO, NO.

SHE IS A --

7

A DIRECTOR'S ASSISTANT.

8

TO THE CENSUS FOR THE CENSUS, PUTTING EVERYTHING

9

TOGETHER TO GET THAT GOING.

10

SHE WAS DOING WORK PRIOR

AND CURRENTLY I'M NOT 100 PERCENT SURE

11

WHAT SHE'S DOING.

12

A NEW POSITION.

13

SHE JUST RECENTLY TRANSFERRED TO

THE COURT:

OKAY.

AND YOUR SON WHO'S IN

14

PRIVATE INDUSTRY, IS THAT IN ANY WAY RELATED CELL

15

PHONES, COMPUTERS, TABLETS, NOTHING IN THE TECH

16

INDUSTRY?

17
18

PROSPECTIVE JUROR:

NO.

IT'S IN OPTICS,

BASICALLY, FIBER OPTICS.

19

THE COURT:

ALL RIGHT.

20

MR. BELLA?

21

PROSPECTIVE JUROR:

22

BELLA.

23

THANK YOU.

MY NAME IS TERRY

RESIDENT OF MOUNTAIN VIEW.

24
25

MY BIRTH PLACE IS PALO ALTO AND I'M A

MY EDUCATION BACKGROUND, A.A. DEGREE IN
AUTOMATIC TECHNOLOGY AND AN A.A. AGREE IN

193

1

ELECTRONICS, TECHNICIAN, COLLEGE OF SAN MATEO.

2

PAST JOBS, I WAS PART OWNER IN

3

COMMUNICATIONS RESEARCH FOR MANY YEARS, A TWO-WAY

4

RADIO COMPANY.

5

POLICE DEPARTMENT AS LOGISTICS.

AND I CURRENTLY WORK AT STANFORD

6

HOBBIES, I LIKE TO DO REMODELS ON MY

7

HOUSE AND CAMPING AND WORK ON CARS AS HOBBIES.

8

I'M CURRENTLY MARRIED, 41 YEARS NEXT

9

WEEK.

10

THE COURT:

CONGRATULATIONS.

11

PROSPECTIVE JUROR:

12

AND MY WIFE WORKS CURRENTLY WITH TRADER

THANK YOU.

13

JOE'S IN PALO ALTO, AND DURING THE SCHOOL TIME

14

SHE'S AN ART TEACHER AT SPRINGER SCHOOL IN

15

LOS ALTOS.
I HAVE A SON WHO'S 25.

16

HE'S MARRIED AND

17

THEY JUST MOVED BACK FROM MARYLAND AND THEY'RE

18

LIVING WITH US NOW UNTIL THEY CAN FIND A JOB, BOTH

19

OF THEM CAN FIND A JOB.

20
21
22
23
24
25

PAST JURY, I REMEMBER TWO JURY SERVICES I
DID.

BOTH WERE GUILTY.
ONE HAD TO DO WITH DRUGS AND I DON'T

REMEMBER WHAT THE OTHER ONE WAS.
THE COURT:
BOTH CRIMINAL?

ALL RIGHT.

BUT THEY WERE

194

1

PROSPECTIVE JUROR:

2

THE COURT:

3

PROSPECTIVE JUROR:

4

THE COURT:

5

AND WERE THEY IN THIS COUNTY?

FEDERAL COURT, IF YOU REMEMBER?
PROSPECTIVE JUROR:

7

THE COURT:

I DON'T KNOW.

THAT'S FINE.

HOW LONG AGO

WERE THESE?

9
10

YES.

AND WERE THEY STATE COURT OR

6

8

YES.

PROSPECTIVE JUROR:

OH, JEEZ.

PROBABLY

20-SOME YEARS AGO.

11

THE COURT:

20-SOME ODD YEARS AGO.

OKAY.

12

AND YOU UNDERSTAND THAT THE STANDARD IN A

13

CRIMINAL CASE IS BEYOND A REASONABLE DOUBT, WHICH

14

IS HIGHER THAN THE STANDARDS THAT WOULD APPLY IN

15

THIS CASE?

16

PROSPECTIVE JUROR:

17

THE COURT:

YES.

ALL RIGHT.

I FORGOT TO ASK

18

MR. HOGAN, THE THREE CIVIL LAWSUITS FOR WHICH YOU

19

WERE A JUROR, DO YOU REMEMBER WHAT THE CAUSES OF

20

ACTION WERE?

21

PROSPECTIVE JUROR:

ONE OF THEM WAS AN

22

ACCIDENT THAT OCCURRED THAT WAS BACK IN 1973 AND

23

WE, THE JURY, DID NOT RULE IN FAVOR OF THE

24

DEFENDANT IN THAT CASE.

25

THE COURT:

OH.

AND I'M NOT ASKING

195

1

ANYONE TO REVEAL THE VERDICT.

I JUST WANT TO KNOW

2

WHETHER YOU REACHED A VERDICT.

3

PERSONAL INJURY, CAR ACCIDENT?

4

PROSPECTIVE JUROR:

5

A VERDICT.

ALL THREE WE REACHED

THAT ONE WAS PERSONAL INJURY.

6

THE COURT:

OKAY.

7

PROSPECTIVE JUROR:

THE NEXT ONE WAS

8

SPOUSAL ABUSE, BUT NOT CRIMINAL, SO IT WAS DONE IN

9

SUPERIOR COURT.

10

THE COURT:

OKAY.

11

PROSPECTIVE JUROR:

THE OTHER ONE WAS A

12

LITTLE BIT OLDER AND RIGHT NOW I CAN'T REMEMBER THE

13

DETAILS.

14

I REMEMBER WE REACHED A VERDICT.
THE COURT:

DO YOU REMEMBER ROUGHLY, WHAT

15

WAS THE ONE TWO DECADES AGO?

16

PROSPECTIVE JUROR:

WELL, ONE WAS IN '73;

17

ONE WAS IN THE MID '80S, '87, I THINK IT WAS; AND

18

THE OTHER ONE THAT WAS MORE RECENT WAS 1990.
THE COURT:

19
20

SO YOU'RE DUE FOR ANOTHER

ONE.

21

PROSPECTIVE JUROR:

22

THE COURT:

23

OKAY.

YEAH.
ALL RIGHT.

OKAY.

THANK YOU.

24

LET'S GO TO MS. ROUGIERI.

25

PROSPECTIVE JUROR:

MY NAME IS LUZVIMINDA

196

1

ROUGIERI.

2

GREW UP IN THE UNITED STATES.

3

EVERGREEN IN SAN JOSE.

4
5

CITY OF RESIDENCE,

EDUCATIONAL BACKGROUND, I HAVE A
BACHELOR'S DEGREE IN FOREIGN LANGUAGE.

6
7

MY PLACE OF BIRTH IS PHILIPPINES, BUT I

PAST AND CURRENT JOB, I HAVE NOT WORKED
FOR 23 YEARS.

8

I'VE BEEN RAISING OUR SON.

I WORKED AT NATIONAL SEMICONDUCTOR AND

9

THAT WAS WHEN WE WERE LIVING IN -- I MOVED TO

10

MASSACHUSETTS AND CHANGED CAREER AND GET INTO

11

RETAIL.

12
13
14

FAVORITE HOBBY WOULD BE PAINTING,
COOKING, AND GARDENING.
I AM CURRENTLY MARRIED.

15

YEARS BY NEXT MONTH.

16

THE COURT:

17

PROSPECTIVE JUROR:

IT'LL BE 25

CONGRATULATIONS.
CURRENT JOB, MY

18

HUSBAND, HE WORKED FOR APPLIED MATERIALS.

19

WORKED FOR K.L.A.

20

NOW HE WORKS FOR A MEDICAL START-UP COMPANY WORKING

21

WITH -- TEAM UP WITH LAWRENCE LIVERMORE.

22
23
24
25

HE

HE WORKED FOR HARRIS, ETON, AND

WE HAVE ONE CHILD WHO IS NOW IN COLLEGE,
A 21 YEAR OLD.
PRIOR JURY SERVICE, THIS IS THE FIRST
TIME, SO I'M OVERWHELMED AND A JURY, IT'S -- THIS

197

1

IS THE FIRST TIME.

2

THE COURT:

3

LET ME ASK, WITH YOUR RETAIL NOW, IS THAT

4

THANK YOU.

IN ANY WAY RELATED TO PHONES, TABLETS, COMPUTERS?

5
6

OKAY.

PROSPECTIVE JUROR:

NO, IT HAD NOTHING TO

DO WITH THAT.

7

THE COURT:

8

MS. FLAVIN?

9

PROSPECTIVE JUROR:

10

OKAY.

ALL RIGHT.

THANK YOU.

MY NAME IS NICOLE

FLAVIN.

11

THE COURT:

FLAVIN, EXCUSE ME.

12

PROSPECTIVE JUROR:

13

PLACE OF BIRTH, LOS GATOS, CALIFORNIA.

14

LIVE IN SUNNYVALE.

IT'S ALL RIGHT.
I CURRENTLY

15

EDUCATIONAL BACKGROUND, SOME COLLEGE.

16

I CURRENTLY WORK AT UPS.

17

SUPERVISOR.

18

I'M A

AND DISPATCH.
I'M NOT MARRIED.

19
20

I'M RESPONSIBLE FOR PACKAGE PLANNING

CHILDREN.

I DON'T HAVE ANY

AND I'VE NEVER SERVED ON A JURY BEFORE.

21

THE COURT:

22

MS. LEROSE, IF YOU WOULD PLEASE PASS THE

23

MICROPHONE OVER.

24
25

OKAY.

THANK YOU.

PROSPECTIVE JUROR:
LEROSE.

THANK YOU.

MY NAME IS LYNN

PLACE OF BIRTH IS EASTON, PENNSYLVANIA.

I

198

1

RESIDE IN RIO DEL MAR IN SANTA CRUZ COUNTY.

2

I HAVE MY MASTER'S IN EARLY CHILDHOOD

3

EDUCATION AND SPEECH PATHOLOGY -- MY MASTER'S IS

4

NOT IN SPEECH PATHOLOGY.

5

PATHOLOGY.

IT'S A B.S. IN SPEECH

6

I'VE OWNED MY OWN BUSINESS, A NATIONALLY

7

ACCREDITED PRESCHOOL FOR 20 YEARS, CLOSED, WHICH I

8

HAVE ALREADY DISCLOSED, IN 2005.

9

AND PREVIOUS TO THAT, THEY WERE JUST

10

PART-TIME JOBS TO GET ME THROUGH SCHOOL TO GET TO

11

WHERE I WAS GOING, AND I CAN'T REMEMBER THOSE

12

LITTLE JOBS, BUT I HAVE BEEN GRATEFUL FOR THEM.

13

FAVORITE HOBBIES, I LOVE READING AND

14

GARDENING AND PLANTING MY -- THE RECREATIONAL

15

ACTIVITIES, PLANTING MY FEET ON ANY BEACH THAT I

16

CAN WALK ON FOR AT LEAST A COUPLE OF HOURS.

17

I AM MARRIED.

MY PARTNER'S CURRENT

18

OCCUPATION IS IN INFORMATION TECHNOLOGY WITH

19

SANTA CLARA MEDICAL.

20

MY CHILDREN, I HAVE TWO, A 29 YEAR OLD

21

AND A 34 YEAR OLD.

ONE IS IN RETAIL, COMPUTERS,

22

AND MY OTHER ONE OWNS HIS OWN CONSTRUCTION

23

BUSINESS.

24

AND NO, NO PRIOR SERVICE.

25

THE COURT:

ALL RIGHT.

THANK YOU.

1
2
3
CERTIFICATE OF REPORTER

4
5
6
7
8
9

I, THE UNDERSIGNED OFFICIAL COURT
REPORTER OF THE UNITED STATES DISTRICT COURT FOR

10

THE NORTHERN DISTRICT OF CALIFORNIA, 280 SOUTH

11

FIRST STREET, SAN JOSE, CALIFORNIA, DO HEREBY

12

CERTIFY:

13

THAT THE FOREGOING TRANSCRIPT,

14

CERTIFICATE INCLUSIVE, CONSTITUTES A TRUE, FULL AND

15

CORRECT TRANSCRIPT OF MY SHORTHAND NOTES TAKEN AS

16

SUCH OFFICIAL COURT REPORTER OF THE PROCEEDINGS

17

HEREINBEFORE ENTITLED AND REDUCED BY COMPUTER-AIDED

18

TRANSCRIPTION TO THE BEST OF MY ABILITY.

19
20
21

/S/
_____________________________
LEE-ANNE SHORTRIDGE, CSR, CRR
CERTIFICATE NUMBER 9595

22
23
24
25

DATED:

JULY 30, 2012