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).

Exhibit J

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION

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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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C O N F I D E N T I A L
A T T O R N E Y S' E Y E S O N L Y
O U T S I D E
C O U N S E L

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VIDEOTAPED DEPOSITION OF RAVIN BALAKRISHNAN, Ph.D.
SAN FRANCISCO, CALIFORNIA
TUESDAY, AUGUST 16, 2011

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BY: ANDREA M. IGNACIO HOWARD, CSR, RPR, CCRR, CLR
CSR LICENSE NO. 9830
JOB NO. 41176
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TUESDAY, AUGUST 16, 2011
9:10 a.m.

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VIDEOTAPED DEPOSITION OF RAVIN BALAKRISHNAN,

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Ph.D., taken at QUINN EMANUEL URQUHART &

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SULLIVAN, 50 California Street, 22nd Floor,

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San Francisco, California, pursuant to

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Notice, before me, ANDREA M. IGNACIO HOWARD,

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CLR, CCRR, RPR, CSR License No. 9830.

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SAN FRANCISCO, CALIFORNIA

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TUESDAY, AUGUST 16, 2011

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9:10 a.m.

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THE VIDEOGRAPHER:

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This is the beginning of Disk No. 1, of the

Good morning.

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videotaped deposition of Dr. Balakrishnan, in the

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matter of Apple versus Samsung, et al., in the United

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States District Court, Northern District of

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California, San Jose Division.

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We are located today at 50 California Street,
in the City of San Francisco, California.

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Today's August 16, 2011, and the time is
9:10 a.m.

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My name is Alan Dias from TSG Reporting.
Here with me is Andrea Ignacio.

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Counsel, would you please identify yourself
for the record.

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MR. JOHNSON:
of Samsung.

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MR. MONACH:

Andrew Monach, representing

Apple and the witness.

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This is Kevin Johnson on behalf

MR. TUNG:

I'm Mark Tung, representing

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

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FOR APPLE INC.:

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MORRISON & FOERSTER

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By:

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ANDREW E. MONACH, Esq.
DEOK KEUN AHN, Esq.

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425 Market Street

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San Francisco, California 94105

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FOR SAMSUNG ELECTRONICS CO. LTD:

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QUINN EMANUEL URQUHART & SULLIVAN

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By:

KEVIN JOHNSON, Esq.

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HENRY LIEN, Esq.

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TODD BRIGGS, Esq.

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MARK TUNG, Ph.D., Esq.

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555 Twin Dolphin Drive

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Redwood Shores, California 94065

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ALSO PRESENT:

Alan Dias, Videographer

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did zoom in.

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in, I need to spend a bit more time making sure

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whether it has to or not.

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now on this device.

But whether or not it has to be zoomed

I have not done that right

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MR. JOHNSON:

Okay.

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THE WITNESS:

So, on this device, I went

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through the -- the preamble.

It's clearly a

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computer-implemented method.

It has a device with a

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touchscreen display.

It is displaying right now a

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first portion of an electronic document.

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electronic document here happens to be a photograph or

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an image, some kind of a picture of something.

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MR. JOHNSON:

Q.

The

Is the electronic doc --

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what -- what does an "electronic document" mean in the

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context of this patent?

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MR. MONACH:

Object to form to the extent

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it's calling for a legal conclusion, but you can give

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your views on that.

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THE WITNESS:

In the context of this patent,

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my understanding, having read the patent and the

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claims, is the electronic document is some visual

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representation on the screen that has a defined length

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and a width, as an example, or defined set of

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boundaries, because they may not have to be a

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rectangular set of boundaries.
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MR. JOHNSON:

Q.

So can it -- it can be

anything with a defined length and width?
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It could be any visually represented thing

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with a defined boundary.

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"boundaries," because length and width may connote a

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rectangular thing.

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necessarily.

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Q

It may not be a rectangle,

So an electronic document is anything

that can be visually represented with a defined
boundary?

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Okay.

I'd rather use the word

MR. MONACH:

Object to the form of the

question; object as calling for a legal conclusion.

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THE WITNESS:

In the context of this patent

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and the claims, reading the patent and the claims, I

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would say that would be a -- my definition of an

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electronic document would be something visually

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representable on the screen that -- that has a defined

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set of boundaries.

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MR. JOHNSON:

Okay.

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Q

How about the next limitation?

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A

Okay.

So, as I said earlier, it's got a

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first portion of an electronic document.

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went through that.

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Q

And -- and -- I'm sorry.

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A

I'm sorry.
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CERTIFICATE OF REPORTER

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I, ANDREA M. IGNACIO HOWARD, hereby certify

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that the witness in the foregoing deposition was by me

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duly sworn to tell the truth, the whole truth, and

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nothing but the truth in the within-entitled cause;

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That said deposition was taken in shorthand

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by me, a Certified Shorthand Reporter of the State of

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California, and was thereafter transcribed into

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typewriting, and that the foregoing transcript

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constitutes a full, true and correct report of said

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deposition and of the proceedings which took place;

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That I am a disinterested person to the said
action.

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IN WITNESS WHEREOF, I have hereunto set my
hand this 17th day of August, 2011.

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___________________________________________
ANDREA M. IGNACIO HOWARD, RPR, CCRR, CLR, CSR No. 9830

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JURAT

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I I RAVIN BALAKRTSHNAN, Ph. D. , do hereby

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B

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certify under penalty of perjury that., I have read t,he
foregoing transcript of my deposition taken on
August 16, 2071,; that I have made such correctíons as
appear noted herein in ink, ínitialed by me; that my
test.imony as contained hereinr âs corrected, is true
and correct.

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DATED

r

r
dL

¡¡1s

day of

20th

SePtember

Toronto, Ontario, Canada

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SIGNA

OF hI]TNESS

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207r,