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 O Highly Confidential - Attorneys' Eyes Only Page 1 1 2 3 4 5 6 7 8 9 10 11 12 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION APPLE INC., a California ) corporation, ) ) Plaintiff, ) ) vs. ) No: 11 CV 01846 LHK ) 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. ) ________________________________) 13 14 **HIGHLY CONFIDENTIAL ATTORNEYS' EYES ONLY** 15 16 17 18 DEPOSITION OF WAYNE WESTERMAN Redwood Shores, California Monday, October 31, 2011 19 20 21 22 23 24 25 Reported By: LINDA VACCAREZZA, RPR, CLR, CRP, CSR. NO. 10201 JOB NO. 43058 TSG Reporting - Worldwide 877-702-9580 Highly Confidential - Attorneys' Eyes Only Page 2 1 2 3 4 5 October 31, 2011 9:11 a.m. 6 7 8 9 Videotaped deposition of WAYNE WESTERMAN, held at Quinn Emanuel 10 Urquhart & Sullivan, LLP, 555 Twin 11 Dolphin Drive, Suite 500, Redwood 12 Shores, California, pursuant to 13 Subpoena before Linda Vaccarezza, a 14 Certified Shorthand Reporter of the 15 State of California. 16 17 18 19 20 21 22 23 24 25 TSG Reporting - Worldwide 877-702-9580 Highly Confidential - Attorneys' Eyes Only Page 3 1 A P P E A R A N C E S: 2 QUINN EMANUEL URQUHART & SULLIVAN LLP 3 Attorneys for Defendants 4 555 Twin Dolphin Drive 5 Redwood Shores, California 94065 6 BY: 7 ALAN WHITEHURST, ESQ. KETAN PATEL, ESQ. 8 Alanwhitehurst@quinnemanual.com 9 10 11 MORRISON & FOERSTER, LLP 12 Attorneys for Plaintiff 13 425 Market Street 14 San Francisco, California 94105 15 BY: 16 MATTHEW I KREEGER, ESQ. mkreeger@mofo.com 17 18 19 20 ALSO PRESENT: Cindy Wheeler Videographer: Alexi dias 21 22 23 24 25 TSG Reporting - Worldwide 877-702-9580 Highly Confidential - Attorneys' Eyes Only Page 4 1 (Exhibit 1150, Notice of 2 Deposition of Wayne 3 westerman, marked for 4 identification.) 5 6 (Exhibit 1151, Condensed 7 Transcript of the Deposition of 8 Wayne Westerman dated October 12, 9 2011, Bates stamped APLNDC 10 X0000001512 through APLNDC 11 X0000001620, marked for 12 identification.) 13 14 (Exhibit 1152, Condensed 15 Transcript of the Deposition of 16 Wayne Westerman dated November 17, 17 2010, Bates stamped APLNDC 18 X0000001623 through APLNDC 19 X0000001680 marked for 20 identification.) 21 22 (Exhibit 1153, Exhibit 1153 23 Condensed Transcript of the 24 Deposition of Wayne Westerman 25 dated October 11, 2011, Bates TSG Reporting - Worldwide 877-702-9580 Highly Confidential - Attorneys' Eyes Only Page 5 1 stamped APLNDC X0000001746 through 2 APLNDC X0000001773, marked for 3 identification.) 4 5 (Exhibit 1154, Condensed 6 Transcript of the Deposition of 7 Wayne Westerman dated June 28, 8 2011, BAtes stamped APLNDC 9 X0000001775 through APLNDC 10 X0000001826, marked for 11 identification.) 12 13 (Exhibit 1155, "Prehearing and 14 Tutorial" dated September 23, 15 2011, Bates stamped 16 X0000004562 through APLNDC 17 X0000004274 through APLNDC 18 X0000004906, marked for 19 identification.) APLNDC 20 21 22 23 24 25 TSG Reporting - Worldwide 877-702-9580 Highly Confidential - Attorneys' Eyes Only Page 6 1 THE VIDEOGRAPHER: Good morning. This is 2 the beginning of Disk Number 1 of the videotaped 3 deposition of Mr. Wayne Westerman in the matter 4 Apple Inc. versus Samsung Electronic Company in 5 the United States District Court, Northern 6 District of California, San Jose division. 7 number 11 CV 01846 LHK. 8 held at Quinn Emanuel, 555 Twin Dolphin Drive, 9 Fifth Floor, in Redwood Shores, California, on Case This deposition is being 10 October 31st, 2011. 11 name is Alexi Dias from TSG Reporting, Inc. and 12 our court reporter is Linda Vaccarezza. 13 counsel please introduce yourself. 14 The time is 9:06 a.m. MR. WHITEHURST: My Will Good morning. My 15 name is Alan Whitehurst, and with me 16 today is my colleague, Ketan Patel. 17 are both at the law firm of Quinn Emanuel 18 and we represent Samsung. 19 MR. KREEGER: We Mathew Kreeger, 20 Morrison & Foerster representing Apple 21 and the witness. 22 Wheeler from Apple. 23 With me is Cindy Thank you. WAYNE WESTERMAN, 24 having been duly sworn by the Certified 25 Shorthand Reporter, was examined and testified as TSG Reporting - Worldwide 877-702-9580 Highly Confidential - Attorneys' Eyes Only Page 129 1 the fitting of ellipses to groups. 2 a unitary transformation or finding Eigen 3 values/vector angle of the covariance matrix of 4 electro coordinates as described below and in the 5 code excerpt." 6 7 8 9 Q. This required Dr. Westerman, why did the fitting of ellipses require a unitary transformation? A. It's just saying that the unitary transformation is just a rotation of a coordinate 10 system so that to align with the long angle of 11 the data, and that's 12 to finding the orientation of the major axis, you 13 rotate your 14 you can find the angle of the major axis. 15 what it does for you. 16 transformation just means rotating a coordinate 17 system, but in this case, you're doing it to 18 match the Eigen vector of the covariance matrix, 19 and that should match up with the long or major 20 axis of the data. and that's just the step rotating the coordinate system so 21 Q. A. 25 Q. Really, I think unitary REDACTED 24 That's REDA CTED REDACTED TSG Reporting - Worldwide 877-702-9580 Highly Confidential - Attorneys' Eyes Only Page 190 1 2 C E R T I F I C A T E STATE OF CALIFORNIA ) 3 ) 4 COUNTY OF SAN FRANCISCO ) 5 I, LINDA VACCAREZZA, a Certified 6 Shorthand Reporter for the State of 7 California, do hereby certify: 8 9 That WAYNE WESTERMAN, the witness whose deposition is herein before set 10 forth, was duly sworn by me and that such 11 deposition is a true record of the 12 testimony given by such witness. 13 I further certify that I am not 14 related to any of the parties to this 15 action by blood or marriage; and that I 16 am in no way interested in the outcome of 17 this matter. 18 IN WITNESS WHEREOF, I have hereunto 19 set my hand this 31st day of October 20 2011. 21 22 ________________________________ 23 LINDA VACCAREZZA, CSR. NO. 10201 24 25 I N D E X TSG Reporting - Worldwide 877-702-9580 Highly Confidential - Attorneys' Eyes Only Page 189 2 (Time noted: 3:35 p.m.) 3 _____________________ 4 WAYNE WESTERMAN 5 6 7 Subscribed and sworn to before me 8 This 9 ______________________________________ day of , 2011. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 TSG Reporting - Worldwide 877-702-9580

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