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 Q
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION
APPLE INC., a California
corporation,
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Plaintiff,
vs.
Case 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.
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CONFIDENTIAL
ATTORNEYS' EYES ONLY
OUTSIDE COUNSEL
VIDEOTAPED DEPOSITION OF IMRAN CHAUDHRI
Redwood Shores, California
Friday, October 14, 2011
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Reported by:
LORRIE L. MARCHANT, CSR No. 10523, RPR, CRR, CCRR, CLR
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JOB NO. 42879
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TSG Reporting - Worldwide
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October 14, 2011
9:35 a.m.
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Videotaped Deposition of IMRAN
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CHAUDHRI, held at the offices of Quinn
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Emanuel Urquhart & Sullivan, LLP, 555
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Twin Dolphin Drive, 5th Floor, Redwood
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Shores, California, before Lorrie L.
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Marchant, a Certified Shorthand
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Reporter, Registered Professional
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Reporter, Certified Realtime Reporter,
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California Certified Realtime Reporter
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and Certified LiveNote Reporter.
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A P P E A R A N C E S:
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FOR THE PLAINTIFF APPLE INC.:
MORRISON & FOERSTER
BY: MATTHEW KREEGER, ESQ.
425 Market Street
San Francisco, California 94105
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FOR THE DEFENDANTS SAMSUNG:
QUINN EMANUEL URQUHART & SULLIVAN
BY: ALAN WHITEHURST, ESQ.
1101 Pennsylvania Avenue NW
Washington, D.C. 20004
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and
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BY:
ALEX BAXTER, ESQ
MARGRET CARUSO, ESQ.
BRETT ARNOLD, ESQ.
555 Twin Dolphin Drive
Redwood Shores, California 94065
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and
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BY: MICHAEL ZELLER, ESQ.
865 South Figueroa Street
Los Angeles, California 90017
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ALSO PRESENT:
Cyndi Wheeler, Apple IP Litigation Counsel
Alan Dias, Videographer
---oOo--TSG Reporting - Worldwide
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(Marked for identification purposes,
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Exhibit 570 through 572.)
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THE VIDEOGRAPHER:
We are on the video
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record at 9:34 a.m.
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versus Samsung, in the United States District Court,
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Northern District of California.
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11-CV-01846-LHK.
In the matter of Apple Inc.,
Case No.
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We are located today at 555 Twin Dolphin
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Drive, in the City of Redwood Shores, California.
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Today is October 14, 2011, and the time is 9:35 a.m.
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My name is Alan Dias from TSG Reporting.
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Counsel, would you please identify yourself
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for the record.
MR. WHITEHURST:
Good morning.
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Alan Whitehurst.
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Alex Baxter.
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My name
Emanuel, and we represent Samsung.
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And with me today is my colleague,
We are with the law firm Quinn
MR. KREEGER:
Matthew Kreeger, Morrison &
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Foerster, representing Apple.
With me is
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Cyndi Wheeler from Apple.
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THE VIDEOGRAPHER:
Will the court reporter
please swear in the witness.
THE REPORTER:
Do you solemnly swear or
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affirm under the penalties of perjury that the
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testimony you are about to offer will be the truth,
TSG Reporting - Worldwide
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Q.
Would you agree, then, that more than one
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year before the filing date of your patent
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application that it was known to have user
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interfaces with more than one window?
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A.
Yes.
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Q.
If you would please read aloud line 12 of
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Column 10.
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A.
Starting a timer and -- shall I continue
Q.
What is a timer?
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on?
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MR. KREEGER:
Objection.
Calls for a legal
conclusion.
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Go ahead.
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THE WITNESS:
A timer, as I understand it,
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is -- is something that counts down from a -- from a
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starting value to zero, typically.
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BY MR. WHITEHURST:
Q.
If you would please read lines 13 and 14 of
Column 10, please.
A.
Closing the first window in response to a
determination that the timer expired.
Q.
What does it mean when it says "closing the
first window"?
MR. KREEGER:
Objection.
Calls for a legal
conclusion.
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THE WITNESS:
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BY MR. WHITEHURST:
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Q.
I don't really know.
In line 14, what it does it mean when it
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says "timer expired"?
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MR. KREEGER:
Same objection.
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THE WITNESS:
I don't know.
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BY MR. WHITEHURST:
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Q.
Is it unclear in line 14 what it means when
it says "timer expired"?
A.
I just don't know what it's referencing.
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understand the timer.
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expired.
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I
I take to it mean that it's gone to zero.
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Q.
I understand that the timer
By taking you back to my earlier example,
And would the timer expire when it reaches
zero?
A.
A timer, like my understanding of timers,
would end at that point.
Q.
If you would please read lines 15 through
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17 of Column 10, starting with the word "wherein"
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and ending with the word "system."
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A.
Wherein the first window does not close in
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response to any input from a user input device of
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the digital processing system.
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Q.
And what does this mean?
MR. KREEGER:
Objection.
TSG Reporting - Worldwide
Calls for a legal
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Page 254
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CERTIFICATE
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STATE OF CALIFORNIA )
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)
COUNTY OF SONOMA
:
ss
)
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I, Lorrie L. Marchant, a Certified Shorthand
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Reporter, a Registered Professional Reporter, a
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Certified Realtime Reporter, and a Certified
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Realtime Professional within and for the State of
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California, do hereby certify:
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That IMRAN CHAUDHRI, the witness whose
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deposition is herein set forth, was duly
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sworn/affirmed by me and that such deposition is a
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true record of the testimony given by such witness.
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I further certify that I am not related to any
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of the parties to this action by blood or marriage
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and that I am in no way interested in the outcome of
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this matter.
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In witness whereof, I have hereunto set my hand
this 15th day of October, 2011.
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--------------------------------------------LORRIE L. MARCHANT, CSR, RPR, CRR, CLR, CCRR
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CSR No. 10523
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today's deposition.
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6:53 p.m.
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Reporting.
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We are off the record at
The master disk will be held by TSG
(Time noted:
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6:53 p.m.)
---oOo---
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____________________
IMRAN CHAUDHRI
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Subscribed and sworn to
before me this
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of
day
2011.
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_______________________
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TSG Reporting - Worldwide
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