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).

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EXHIBIT H Contains Highly Confidential - Attorneys' Eyes Only Portions Page 1 1 2 3 4 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA --o0o-APPLE INC., a California corporation, 5 Plaintiff, 6 Vs. Case No. 11-CV-01846-LHK 7 8 9 10 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, 11 12 Defendants. _____________________________/ 13 14 15 16 17 VIDEOTAPED DEPOSITION OF COOPER WOODRING Redwood Shores, California Friday, August 5, 2011 (HIGHLY CONFIDENTIAL ATTORNEYS' EYES ONLY PORTIONS BOUND SEPARATELY) 18 19 Reported By: CAROL S. NYGARD, CSR No. 4018 Registered Merit Reporter 20 21 22 23 24 25 TSG Reporting - Worldwide 877-702-9580 Contains Highly Confidential - Attorneys' Eyes Only Portions Page 2 1 2 August 5, 2011 9:46 a.m. 3 Videotaped Deposition of COOPER 4 WOODRING, held at the offices of 5 Quinn Emanuel Urquhart & Sullivan, 6 LLP, 555 Twin Dolphin Drive, Redwood Shores, 7 California, before Carol S. Nygard, 8 A Certified Shorthand Reporter, 9 Registered Merit Reporter. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 TSG Reporting - Worldwide 877-702-9580 Contains Highly Confidential - Attorneys' Eyes Only Portions Page 3 1 2 3 4 5 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 6 7 8 9 CYNDI WHEELER, Patent Counsel Apple 1 Infinite Loop, MS 40-PAT Cupertino, California 95014 10 11 FOR THE DEFENDANTS SAMSUNG: 12 13 14 15 QUINN EMANUEL URQUHART & SULLIVAN BY: MICHAEL T. ZELLER, ESQ. TAMAR BUCHAKJIAN ESQ, 856 South Figueroa Street 10th Floor Los Angeles, CA 90017 16 17 18 19 20 QUINN EMANUEL URQUHART & SULLIVAN BY: MARGARET CARUSO, ESQ. JOELLE PERRY, ESQ. 555 Twin Dolphin Drive 5th Floor Redwood Shores, California 94065 21 22 23 Also Present: 24 25 JAKE KROHN, Videographer NATE SUN TSG Reporting - Worldwide 877-702-9580 Contains Highly Confidential - Attorneys' Eyes Only Portions Page 90 1 MR. ZELLER: 2 VIDEOGRAPHER: 3 We are off the record at 11:53. 5 (Discussion off the record) 6 VIDEOGRAPHER: 10 This is the beginning of tape two for the deposition of Cooper Woodring. 8 9 This is the end of tape one for the deposition of Cooper Woodring. 4 7 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 11 phone that you have in front of you, in terms of the 12 overall impression of the surface of that phone that you 13 have in front of you, do you believe that it is 14 substantially the same as the design depicted in the 677 15 design patent? 16 MR. MONACH: Object to the form of the 17 question as asking this witness to form an opinion on 18 the fly here, but you can answer if you'd like. 19 20 21 THE WITNESS: With regard to its color, yes. BY MR. ZELLER: Q. I'm asking about it overall now. 22 MR. MONACH: Same objections. 23 MR. ZELLER: The overall surface. 24 THE WITNESS: 25 That's just not a -- an analysis that I've previously made and would be reluctant to -TSG Reporting - Worldwide 877-702-9580 Contains Highly Confidential - Attorneys' Eyes Only Portions Page 91 1 try to do that within 30 seconds when, you know, 2 substantially the same analysis is a fairly complex 3 analysis to make. 4 BY MR. ZELLER: 5 Q. So you can't offer an opinion on that? 6 A. I'd be reluctant to. 7 Q. I'm not asking if you're reluctant to. 8 Can you offer an opinion on that? 9 MR. MONACH: 10 13 14 THE WITNESS: Q. 19 Are you refusing to answer my question or are you saying you cannot answer it? MR. MONACH: Object to the form of the question. 17 18 I don't think I'm willing to. BY MR. ZELLER: 15 16 Asked and answered. Object to form. 11 12 Objection. THE WITNESS: I cannot answer it. BY MR. ZELLER: Q. So you have no opinion; correct? 20 MR. MONACH: 21 THE WITNESS: Object to form. I'm -- I'm unwilling to -- to 22 try to answer your question in, you know, 30 seconds or 23 not when I've spent hours and hours trying to arrive at 24 a -- a correct solution in other comparisons. 25 BY MR. ZELLER: TSG Reporting - Worldwide 877-702-9580 Contains Highly Confidential - Attorneys' Eyes Only Portions Page 304 1 Q. Anything else? 2 A. No, that's about it. 3 MR. ZELLER: All right. 4 MR. MONACH: All right. 5 Thank you. 6 VIDEOGRAPHER: 7 This is the end of the deposition of Cooper Woodring after four tapes. 8 And we're off the record at 7:33. 9 (Thereupon the deposition was adjourned at. 10 11 12 7:33 p.m.) --o0o-Signed under penalty of perjury: 13 ________________________________ 14 COOPER C. WOODRING 15 16 _________________________________ DATE 17 18 19 20 21 22 23 24 25 TSG Reporting - Worldwide 877-702-9580 Contains Highly Confidential - Attorneys' Eyes Only Portions Page 305 1 I, CAROL S. NYGARD, a Certified Shorthand 2 Reporter of the State of California, duly authorized to 3 administer oaths, do hereby certify: 4 That the foregoing proceedings were taken 5 before me at the time and place herein set forth; that 6 any witnesses in the foregoing proceedings, prior to 7 testifying, were duly sworn; that a record of the 8 proceedings was made by me using machine shorthand which 9 was thereafter transcribed under my direction; that the 10 foregoing transcript is a true record of the testimony 11 given. 12 Further, that if the foregoing pertains to the 13 original transcript of a deposition in a Federal Case, 14 before completion of the proceedings review of the 15 transcript was not requested. 16 I further certify I am neither financially 17 interested in the action nor a relative or employee of 18 any attorney or party to this action. 19 20 21 IN WITNESS WHEREOF, I have this date subscribed my name: Dated: August 6th, 2011 22 23 _______________________________ 24 CAROL S. NYGARD, CSR #4018 25 TSG Reporting - Worldwide 877-702-9580

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