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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HAROLD J. MCELHINNY (CA SBN 66781)
[e-mail]
MICHAEL A. JACOBS (CA SBN 111664)
[e-mail]
RICHARD S.J. HUNG (CA SBN 197425)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff and
Counterclaim-Defendant APPLE INC.

WILLIAM F. LEE
[e-mail]
WILMER CUTLER PICKERING
HALE AND DORR LLP
60 State Street
Boston, MA 02109
Telephone: [phone]
Facsimile: [phone]
MARK D. SELWYN (SBN 244180)
[e-mail]
WILMER CUTLER PICKERING
HALE AND DORR LLP
950 Page Mill Road
Palo Alto, California 94304
Telephone: [phone]
Facsimile: [phone]

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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,
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

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AHN DECLARATION IN SUPPORT OF APPLE’S OPENING CLAIM CONSTRUCTION BRIEF
CASE NO. 11-CV-01846-LHK
sf-3080799

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I, Deok Keun Matthew Ahn, declare as follows:

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1.

I am an associate at the law firm of Morrison & Foerster LLP, attorneys of record

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in this action for plaintiff Apple Inc. (“Apple”). I submit this declaration in support of Apple’s

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Opening Claim Construction Brief Pursuant to Patent L.R. 4-5. Unless otherwise indicated, I

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have personal knowledge of the matters set forth below. If called as a witness I could and would

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testify competently as follows:

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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

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Amendment and Response to Office Action bearing Bates Numbers APLNDC00028053-28060,

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excerpted from the produced file history of U.S. Patent No. 6,493,002.

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9.

Attached hereto as Exhibit H to this Declaration is a true and correct copy of a

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Response to Final Office Action bearing Bates Numbers APLNDC00028082-28085, excerpted

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from the produced file history of U.S. Patent No. 6,493,002.

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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

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12.

Attached hereto as Exhibit K to this Declaration is a true and correct copy of an

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excerpt from the Reply Declaration of Ravin Balakrishnan, Ph.D. in Support of Apple’s Motion

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for a Preliminary Injunction (Dkt. No. 278-0).

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13.

Attached hereto as Exhibit L to this Declaration is a true and correct copy of an

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excerpt from the book E.R. Davies, Machine Vision: Theory, Algorithms, Practicalities (2d Ed.)

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(Nov. 1996), produced in this action bearing Bates numbers SAMNDCA00031977-31979;

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31991-32001.

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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.

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15.

Attached hereto as Exhibit N to this Declaration is a true and correct copy of U.S.

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Patent No. 5,734,751, produced in this action bearing Bates numbers SAMNDCA00032707-

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32717.

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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.
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Attached hereto as Exhibit P to this Declaration is a true and correct copy of an

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Interview Summary, Statement of Substance of Interview, Request for Corrected Office Action,

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and Amendment in Response to Non-Final Office Action bearing Bates Numbers

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APLNDC00021674-21692, excerpted from the produced file history of U.S. Patent No.

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7,812,828.

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18.

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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.

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/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

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ATTESTATION OF E-FILED SIGNATURE
I, Michael A. Jacobs, am the ECF User whose ID and password are being used to file this

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Declaration. In compliance with General Order 45, X.B., I hereby attest that Deok Keun

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Matthew Ahn has concurred in this filing.

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Dated: December 8, 2011

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/s/ Michael A. Jacobs
Michael A. Jacobs

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AHN DECLARATION IN SUPPORT OF APPLE’S OPENING CLAIM CONSTRUCTION BRIEF
CASE NO. 11-CV-01846-LHK
sf-3080799

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