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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Exhibit J Confidential Attorneys' Eyes Only Outside Counsel Page 1 1 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION 2 3 4 5 APPLE INC., a California corporation, 6 Plaintiff, 7 vs. CASE NO. 11-CV-01846-LHK 8 9 10 11 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, 12 13 Defendants. _____________________________/ 14 15 16 17 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 18 19 20 21 VIDEOTAPED DEPOSITION OF RAVIN BALAKRISHNAN, Ph.D. SAN FRANCISCO, CALIFORNIA TUESDAY, AUGUST 16, 2011 22 23 24 25 BY: ANDREA M. IGNACIO HOWARD, CSR, RPR, CCRR, CLR CSR LICENSE NO. 9830 JOB NO. 41176 TSG Reporting - Worldwide (877)-702-9580 Confidential Attorneys' Eyes Only Outside Counsel Page 2 1 2 TUESDAY, AUGUST 16, 2011 9:10 a.m. 3 4 5 6 VIDEOTAPED DEPOSITION OF RAVIN BALAKRISHNAN, 7 Ph.D., taken at QUINN EMANUEL URQUHART & 8 SULLIVAN, 50 California Street, 22nd Floor, 9 San Francisco, California, pursuant to 10 Notice, before me, ANDREA M. IGNACIO HOWARD, 11 CLR, CCRR, RPR, CSR License No. 9830. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 TSG Reporting - Worldwide (877)-702-9580 Confidential Attorneys' Eyes Only Outside Counsel Page 4 1 SAN FRANCISCO, CALIFORNIA 2 TUESDAY, AUGUST 16, 2011 3 9:10 a.m. 4 5 6 THE VIDEOGRAPHER: 7 This is the beginning of Disk No. 1, of the Good morning. 8 videotaped deposition of Dr. Balakrishnan, in the 9 matter of Apple versus Samsung, et al., in the United 10 States District Court, Northern District of 11 California, San Jose Division. 12 13 We are located today at 50 California Street, in the City of San Francisco, California. 14 15 Today's August 16, 2011, and the time is 9:10 a.m. 16 17 My name is Alan Dias from TSG Reporting. Here with me is Andrea Ignacio. 18 19 Counsel, would you please identify yourself for the record. 20 21 MR. JOHNSON: of Samsung. 22 23 MR. MONACH: Andrew Monach, representing Apple and the witness. 24 25 This is Kevin Johnson on behalf MR. TUNG: I'm Mark Tung, representing Samsung. TSG Reporting - Worldwide (877)-702-9580 Confidential Attorneys' Eyes Only Outside Counsel Page 3 1 A P P E A R A N C E S: 2 3 FOR APPLE INC.: 4 MORRISON & FOERSTER 5 By: 6 ANDREW E. MONACH, Esq. DEOK KEUN AHN, Esq. 7 425 Market Street 8 San Francisco, California 94105 9 10 11 12 FOR SAMSUNG ELECTRONICS CO. LTD: 13 QUINN EMANUEL URQUHART & SULLIVAN 14 By: KEVIN JOHNSON, Esq. 15 HENRY LIEN, Esq. 16 TODD BRIGGS, Esq. 17 MARK TUNG, Ph.D., Esq. 18 555 Twin Dolphin Drive 19 Redwood Shores, California 94065 20 21 22 23 ALSO PRESENT: Alan Dias, Videographer 24 25 TSG Reporting - Worldwide (877)-702-9580 Confidential Attorneys' Eyes Only Outside Counsel Page 27 1 did zoom in. 2 in, I need to spend a bit more time making sure 3 whether it has to or not. 4 now on this device. But whether or not it has to be zoomed I have not done that right 5 MR. JOHNSON: Okay. 6 THE WITNESS: So, on this device, I went 7 through the -- the preamble. It's clearly a 8 computer-implemented method. It has a device with a 9 touchscreen display. It is displaying right now a 10 first portion of an electronic document. 11 electronic document here happens to be a photograph or 12 an image, some kind of a picture of something. 13 MR. JOHNSON: Q. The Is the electronic doc -- 14 what -- what does an "electronic document" mean in the 15 context of this patent? 16 MR. MONACH: Object to form to the extent 17 it's calling for a legal conclusion, but you can give 18 your views on that. 19 THE WITNESS: In the context of this patent, 20 my understanding, having read the patent and the 21 claims, is the electronic document is some visual 22 representation on the screen that has a defined length 23 and a width, as an example, or defined set of 24 boundaries, because they may not have to be a 25 rectangular set of boundaries. TSG Reporting - Worldwide (877)-702-9580 Confidential Attorneys' Eyes Only Outside Counsel Page 28 1 2 3 MR. JOHNSON: Q. So can it -- it can be anything with a defined length and width? A It could be any visually represented thing 4 with a defined boundary. 5 "boundaries," because length and width may connote a 6 rectangular thing. 7 necessarily. 8 9 10 Q It may not be a rectangle, So an electronic document is anything that can be visually represented with a defined boundary? 11 12 Okay. I'd rather use the word MR. MONACH: Object to the form of the question; object as calling for a legal conclusion. 13 THE WITNESS: In the context of this patent 14 and the claims, reading the patent and the claims, I 15 would say that would be a -- my definition of an 16 electronic document would be something visually 17 representable on the screen that -- that has a defined 18 set of boundaries. 19 MR. JOHNSON: Okay. 20 Q How about the next limitation? 21 A Okay. So, as I said earlier, it's got a 22 first portion of an electronic document. 23 went through that. 24 Q And -- and -- I'm sorry. 25 A I'm sorry. TSG Reporting - Worldwide (877)-702-9580 We already Confidential Attorneys' Eyes Only Outside Counsel Page 337 1 CERTIFICATE OF REPORTER 2 3 4 5 I, ANDREA M. IGNACIO HOWARD, hereby certify 6 that the witness in the foregoing deposition was by me 7 duly sworn to tell the truth, the whole truth, and 8 nothing but the truth in the within-entitled cause; 9 10 That said deposition was taken in shorthand 11 by me, a Certified Shorthand Reporter of the State of 12 California, and was thereafter transcribed into 13 typewriting, and that the foregoing transcript 14 constitutes a full, true and correct report of said 15 deposition and of the proceedings which took place; 16 17 18 That I am a disinterested person to the said action. 19 20 21 IN WITNESS WHEREOF, I have hereunto set my hand this 17th day of August, 2011. 22 23 24 ___________________________________________ ANDREA M. IGNACIO HOWARD, RPR, CCRR, CLR, CSR No. 9830 25 TSG Reporting - Worldwide (877)-702-9580 Confidential Attorneys' Eyes Only Outside Counsel Page 336 JURAT 1 2 I I RAVIN BALAKRTSHNAN, Ph. D. , do hereby 3 4 5 6 '7 B 9 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. 10 11 12 DATED r r dL ¡¡1s day of 20th SePtember Toronto, Ontario, Canada 13 I4 15 L6 I1 18 I9 SIGNA OF hI]TNESS 20 2L 22 z5 24 25 TSG Reporting - Worldwide (877)-702-9580 I 207r,

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