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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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
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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,
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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.

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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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