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

Filing 310

Declaration of Grant L. Kim in Support of Apple's Objections to Samsung's Untimely New Evidence, filed by Apple Inc.. (Attachments: #1 Exhibit A, #2 Notice of Manual Filing Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Notice of Manual Filing Exhibit E, #6 Exhibit F, #7 Notice of Manual Filing Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Exhibit J)(Jacobs, Michael) (Filed on 10/17/2011) Modified on 10/18/2011. Cannot link entry. Ojections have not been efiled. NOTICES OF MANUAL FILING ARE NOT IN COMPLIANCE WITH GENERAL ORDER NO. 62 (dhm, COURT STAFF).

EXHIBIT H

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
--o0o-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,

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Defendants.
_____________________________/

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VIDEOTAPED DEPOSITION OF COOPER WOODRING
Redwood Shores, California
Friday, August 5, 2011
(HIGHLY CONFIDENTIAL ATTORNEYS' EYES
ONLY PORTIONS BOUND SEPARATELY)

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Reported By:

CAROL S. NYGARD, CSR No. 4018
Registered Merit Reporter

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August 5, 2011
9:46 a.m.

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Videotaped Deposition of COOPER

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WOODRING, held at the offices of

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Quinn Emanuel Urquhart & Sullivan,

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LLP, 555 Twin Dolphin Drive, Redwood Shores,

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California, before Carol S. Nygard,

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A Certified Shorthand Reporter,

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Registered Merit Reporter.

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A P P E A R A N C E S:
FOR THE PLAINTIFF APPLE, INC.:
MORRISON & FOERSTER
BY: ANDREW E. MONACH, ESQ.
PATRICK J. ZHANG, ESQ.
425 Market Street
San Francisco, California 94105

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CYNDI WHEELER, Patent Counsel
Apple
1 Infinite Loop, MS 40-PAT
Cupertino, California 95014

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FOR THE DEFENDANTS SAMSUNG:
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QUINN EMANUEL URQUHART & SULLIVAN
BY: MICHAEL T. ZELLER, ESQ.
TAMAR BUCHAKJIAN ESQ,
856 South Figueroa Street
10th Floor
Los Angeles, CA 90017

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QUINN EMANUEL URQUHART & SULLIVAN
BY: MARGARET CARUSO, ESQ.
JOELLE PERRY, ESQ.
555 Twin Dolphin Drive
5th Floor
Redwood Shores, California 94065

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Also Present:
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JAKE KROHN, Videographer
NATE SUN
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MR. ZELLER:

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VIDEOGRAPHER:

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We are off the record at 11:53.

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(Discussion off the record)

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VIDEOGRAPHER:

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This is the beginning of tape

two for the deposition of Cooper Woodring.

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This is the end of tape one for

the deposition of Cooper Woodring.

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We need to change tapes.

We are back on the record at 11:56.
BY MR. ZELLER:
Q.

Finishing up there then with Exhibit 63, the

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phone that you have in front of you, in terms of the

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overall impression of the surface of that phone that you

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have in front of you, do you believe that it is

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substantially the same as the design depicted in the 677

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design patent?

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MR. MONACH:

Object to the form of the

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question as asking this witness to form an opinion on

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the fly here, but you can answer if you'd like.

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THE WITNESS:

With regard to its color, yes.

BY MR. ZELLER:
Q.

I'm asking about it overall now.

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MR. MONACH:

Same objections.

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MR. ZELLER:

The overall surface.

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THE WITNESS:

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That's just not a -- an analysis

that I've previously made and would be reluctant to -TSG Reporting - Worldwide

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try to do that within 30 seconds when, you know,

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substantially the same analysis is a fairly complex

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analysis to make.

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BY MR. ZELLER:

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Q.

So you can't offer an opinion on that?

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A.

I'd be reluctant to.

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Q.

I'm not asking if you're reluctant to.

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Can you offer an opinion on that?

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MR. MONACH:

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THE WITNESS:

Q.

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Are you refusing to answer my question or are

you saying you cannot answer it?
MR. MONACH:

Object to the form of the

question.

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I don't think I'm willing to.

BY MR. ZELLER:

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Asked and answered.

Object to form.

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Objection.

THE WITNESS:

I cannot answer it.

BY MR. ZELLER:
Q.

So you have no opinion; correct?

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MR. MONACH:

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THE WITNESS:

Object to form.
I'm -- I'm unwilling to -- to

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try to answer your question in, you know, 30 seconds or

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not when I've spent hours and hours trying to arrive at

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a -- a correct solution in other comparisons.

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BY MR. ZELLER:
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Q.

Anything else?

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A.

No, that's about it.

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MR. ZELLER:

All right.

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MR. MONACH:

All right.

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Thank you.

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VIDEOGRAPHER:

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This is the end of the

deposition of Cooper Woodring after four tapes.

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And we're off the record at 7:33.

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(Thereupon the deposition was adjourned at.

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7:33 p.m.)
--o0o-Signed under penalty of perjury:

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________________________________

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COOPER C. WOODRING

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_________________________________
DATE

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I, CAROL S. NYGARD, a Certified Shorthand

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Reporter of the State of California, duly authorized to

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administer oaths, do hereby certify:

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That the foregoing proceedings were taken

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before me at the time and place herein set forth; that

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any witnesses in the foregoing proceedings, prior to

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testifying, were duly sworn; that a record of the

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proceedings was made by me using machine shorthand which

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was thereafter transcribed under my direction; that the

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foregoing transcript is a true record of the testimony

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given.

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Further, that if the foregoing pertains to the

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original transcript of a deposition in a Federal Case,

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before completion of the proceedings review of the

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transcript was not requested.

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I further certify I am neither financially

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interested in the action nor a relative or employee of

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any attorney or party to this action.

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IN WITNESS WHEREOF, I have this date
subscribed my name:
Dated: August 6th, 2011

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_______________________________

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CAROL S. NYGARD, CSR #4018

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