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
TSG Reporting - Worldwide
(877)-702-9580
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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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TSG Reporting - Worldwide
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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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TSG Reporting - Worldwide
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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?
A
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.
TSG Reporting - Worldwide
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We already
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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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TSG Reporting - Worldwide
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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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L6
I1
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I9
SIGNA
OF hI]TNESS
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2L
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z5
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TSG Reporting -
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207r,
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