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

Filing 462

Declaration of DEOK KEUN Matthew Ahn IN SUPPORT OF 461 APPLES OPENING CLAIM CONSTRUCTION BRIEF PURSUANT TO PATENT L.R. 4-5 filed by Apple Inc.(a California corporation). (Attachments: # 1 Exhibit A, # 2 Exhibit B Part 1, # 3 Exhibit B Part 2, # 4 Exhibit C Part 1, # 5 Exhibit C Part 2, # 6 Exhibit D Part 1, # 7 Exhibit D Part 2, # 8 Exhibit D Part 3, # 9 Exhibit D Part 4, # 10 Exhibit E Part 1, # 11 Exhibit E Part 2, # 12 Exhibit F, # 13 Exhibit G, # 14 Exhibit H, # 15 Exhibit I, # 16 Exhibit J, # 17 Exhibit K, # 18 Exhibit L, # 19 Exhibit M Part 1, # 20 Exhibit M Part 2, # 21 Exhibit N, # 22 Exhibit O, # 23 Exhibit P, # 24 Exhibit Q)(Jacobs, Michael) (Filed on 12/8/2011) Modified on 12/9/2011 linking entry to document #461 (dhm, COURT STAFF).

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1 2 3 4 5 6 HAROLD J. MCELHINNY (CA SBN 66781) hmcelhinny@mofo.com MICHAEL A. JACOBS (CA SBN 111664) mjacobs@mofo.com RICHARD S.J. HUNG (CA SBN 197425) rhung@mofo.com MORRISON & FOERSTER LLP 425 Market Street San Francisco, California 94105-2482 Telephone: (415) 268-7000 Facsimile: (415) 268-7522 7 8 9 10 Attorneys for Plaintiff and Counterclaim-Defendant APPLE INC. WILLIAM F. LEE william.lee@wilmerhale.com WILMER CUTLER PICKERING HALE AND DORR LLP 60 State Street Boston, MA 02109 Telephone: (617) 526-6000 Facsimile: (617) 526-5000 MARK D. SELWYN (SBN 244180) mark.selwyn@wilmerhale.com WILMER CUTLER PICKERING HALE AND DORR LLP 950 Page Mill Road Palo Alto, California 94304 Telephone: (650) 858-6000 Facsimile: (650) 858-6100 11 UNITED STATES DISTRICT COURT 12 NORTHERN DISTRICT OF CALIFORNIA 13 SAN JOSE DIVISION 14 15 APPLE INC., a California corporation, 16 17 18 19 20 21 22 Plaintiff, v. 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., Defendants. Case No. 11-cv-01846-LHK DECLARATION OF DEOK KEUN MATTHEW AHN IN SUPPORT OF APPLE’S OPENING CLAIM CONSTRUCTION BRIEF PURSUANT TO PATENT L.R. 4-5 Claim Construction Hearing: Jan 20, 2012 Time: 10:00 a.m. Place: Courtroom 4, 5th Floor Judge: Honorable Lucy H. Koh 23 24 25 26 27 28 AHN DECLARATION IN SUPPORT OF APPLE’S OPENING CLAIM CONSTRUCTION BRIEF CASE NO. 11-CV-01846-LHK sf-3080799 1 I, Deok Keun Matthew Ahn, declare as follows: 2 1. I am an associate at the law firm of Morrison & Foerster LLP, attorneys of record 3 in this action for plaintiff Apple Inc. (“Apple”). I submit this declaration in support of Apple’s 4 Opening Claim Construction Brief Pursuant to Patent L.R. 4-5. Unless otherwise indicated, I 5 have personal knowledge of the matters set forth below. If called as a witness I could and would 6 testify competently as follows: 7 8 9 10 11 12 13 14 15 16 17 18 19 2. Attached hereto as Exhibit A to this Declaration is a true and correct copy of U.S. Patent No. 6,493,002. 3. Attached hereto as Exhibit B to this Declaration is a true and correct copy of U.S. Patent No. 7,469,381. 4. Attached hereto as Exhibit C to this Declaration is a true and correct copy of U.S. Patent No. 7,663,607. 5. Attached hereto as Exhibit D to this Declaration is a true and correct copy of U.S. Patent No. 7,812,828. 6. Attached hereto as Exhibit E to this Declaration is a true and correct copy of U.S. Patent No. 7,844,915. 7. Attached hereto as Exhibit F to this Declaration is a true and correct copy of U.S. Patent No. 7,853,891. 8. Attached hereto as Exhibit G to this Declaration is a true and correct copy of an 20 Amendment and Response to Office Action bearing Bates Numbers APLNDC00028053-28060, 21 excerpted from the produced file history of U.S. Patent No. 6,493,002. 22 9. Attached hereto as Exhibit H to this Declaration is a true and correct copy of a 23 Response to Final Office Action bearing Bates Numbers APLNDC00028082-28085, excerpted 24 from the produced file history of U.S. Patent No. 6,493,002. 25 26 27 28 10. Attached hereto as Exhibit I to this Declaration is a true and correct copy of an excerpt from the transcript of the September 14, 2011 deposition of Andries van Dam. 11. Attached hereto as Exhibit J to this Declaration is a true and correct copy of an excerpt from the transcript of the August 16, 2011 deposition of Ravin Balakrishnan. AHN DECLARATION IN SUPPORT OF APPLE’S OPENING CLAIM CONSTRUCTION BRIEF CASE NO. 11-CV-01846-LHK sf-3080799 1 1 12. Attached hereto as Exhibit K to this Declaration is a true and correct copy of an 2 excerpt from the Reply Declaration of Ravin Balakrishnan, Ph.D. in Support of Apple’s Motion 3 for a Preliminary Injunction (Dkt. No. 278-0). 4 13. Attached hereto as Exhibit L to this Declaration is a true and correct copy of an 5 excerpt from the book E.R. Davies, Machine Vision: Theory, Algorithms, Practicalities (2d Ed.) 6 (Nov. 1996), produced in this action bearing Bates numbers SAMNDCA00031977-31979; 7 31991-32001. 8 9 10 14. Attached hereto as Exhibit M to this Declaration is a true and correct copy of U.S. Patent No. 4,618,989, produced in this action bearing Bates numbers SAMNDCA0003278232804. 11 15. Attached hereto as Exhibit N to this Declaration is a true and correct copy of U.S. 12 Patent No. 5,734,751, produced in this action bearing Bates numbers SAMNDCA00032707- 13 32717. 14 15 16 16. Attached hereto as Exhibit O to this Declaration is a true and correct copy of an excerpt from the transcript of the October 31, 2011 deposition of Wayne Westerman. 17. Attached hereto as Exhibit P to this Declaration is a true and correct copy of an 17 Interview Summary, Statement of Substance of Interview, Request for Corrected Office Action, 18 and Amendment in Response to Non-Final Office Action bearing Bates Numbers 19 APLNDC00021674-21692, excerpted from the produced file history of U.S. Patent No. 20 7,812,828. 21 18. 22 23 24 Attached hereto as Exhibit Q to this Declaration is a true and correct copy of an excerpt from the transcript of the October 14, 2011 deposition of Imran Chaudhri. I declare under the penalty of perjury that the forgoing is true and correct. Executed this 8th day of December, 2011, at San Francisco, California. 25 26 27 28 /s/ Deok Keun Matthew Ahn Deok Keun Matthew Ahn AHN DECLARATION IN SUPPORT OF APPLE’S OPENING CLAIM CONSTRUCTION BRIEF CASE NO. 11-CV-01846-LHK sf-3080799 2 1 2 ATTESTATION OF E-FILED SIGNATURE I, Michael A. Jacobs, am the ECF User whose ID and password are being used to file this 3 Declaration. In compliance with General Order 45, X.B., I hereby attest that Deok Keun 4 Matthew Ahn has concurred in this filing. 5 Dated: December 8, 2011 6 /s/ Michael A. Jacobs Michael A. Jacobs 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 AHN DECLARATION IN SUPPORT OF APPLE’S OPENING CLAIM CONSTRUCTION BRIEF CASE NO. 11-CV-01846-LHK sf-3080799 3

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