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 Q Confidential Attorneys' Eyes Only Page 1 1 2 3 4 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION APPLE INC., a California corporation, 5 6 7 8 9 10 11 12 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. ---------------------------------/ 13 14 15 16 17 18 19 20 CONFIDENTIAL ATTORNEYS' EYES ONLY OUTSIDE COUNSEL VIDEOTAPED DEPOSITION OF IMRAN CHAUDHRI Redwood Shores, California Friday, October 14, 2011 21 22 23 Reported by: LORRIE L. MARCHANT, CSR No. 10523, RPR, CRR, CCRR, CLR 24 JOB NO. 42879 25 TSG Reporting - Worldwide (877)-702-9580 Confidential Attorneys' Eyes Only Page 2 1 2 October 14, 2011 9:35 a.m. 3 4 Videotaped Deposition of IMRAN 5 CHAUDHRI, held at the offices of Quinn 6 Emanuel Urquhart & Sullivan, LLP, 555 7 Twin Dolphin Drive, 5th Floor, Redwood 8 Shores, California, before Lorrie L. 9 Marchant, a Certified Shorthand 10 Reporter, Registered Professional 11 Reporter, Certified Realtime Reporter, 12 California Certified Realtime Reporter 13 and Certified LiveNote Reporter. 14 15 16 17 18 19 20 21 22 23 24 25 TSG Reporting - Worldwide (877)-702-9580 Confidential Attorneys' Eyes Only Page 3 1 A P P E A R A N C E S: 2 3 4 5 FOR THE PLAINTIFF APPLE INC.: MORRISON & FOERSTER BY: MATTHEW KREEGER, ESQ. 425 Market Street San Francisco, California 94105 6 7 8 9 10 FOR THE DEFENDANTS SAMSUNG: QUINN EMANUEL URQUHART & SULLIVAN BY: ALAN WHITEHURST, ESQ. 1101 Pennsylvania Avenue NW Washington, D.C. 20004 11 12 and 13 BY: ALEX BAXTER, ESQ MARGRET CARUSO, ESQ. BRETT ARNOLD, ESQ. 555 Twin Dolphin Drive Redwood Shores, California 94065 14 15 16 17 and 18 19 BY: MICHAEL ZELLER, ESQ. 865 South Figueroa Street Los Angeles, California 90017 20 21 22 23 24 25 ALSO PRESENT: Cyndi Wheeler, Apple IP Litigation Counsel Alan Dias, Videographer ---oOo--TSG Reporting - Worldwide (877)-702-9580 Confidential Attorneys' Eyes Only Page 4 1 (Marked for identification purposes, 2 Exhibit 570 through 572.) 3 THE VIDEOGRAPHER: We are on the video 4 record at 9:34 a.m. 5 versus Samsung, in the United States District Court, 6 Northern District of California. 7 11-CV-01846-LHK. In the matter of Apple Inc., Case No. 8 We are located today at 555 Twin Dolphin 9 Drive, in the City of Redwood Shores, California. 10 Today is October 14, 2011, and the time is 9:35 a.m. 11 My name is Alan Dias from TSG Reporting. 12 Counsel, would you please identify yourself 13 14 for the record. MR. WHITEHURST: Good morning. 15 Alan Whitehurst. 16 Alex Baxter. 17 My name Emanuel, and we represent Samsung. 18 And with me today is my colleague, We are with the law firm Quinn MR. KREEGER: Matthew Kreeger, Morrison & 19 Foerster, representing Apple. With me is 20 Cyndi Wheeler from Apple. 21 22 23 THE VIDEOGRAPHER: Will the court reporter please swear in the witness. THE REPORTER: Do you solemnly swear or 24 affirm under the penalties of perjury that the 25 testimony you are about to offer will be the truth, TSG Reporting - Worldwide (877)-702-9580 Confidential Attorneys' Eyes Only Page 70 1 Q. Would you agree, then, that more than one 2 year before the filing date of your patent 3 application that it was known to have user 4 interfaces with more than one window? 5 A. Yes. 6 Q. If you would please read aloud line 12 of 7 Column 10. 8 A. Starting a timer and -- shall I continue Q. What is a timer? 9 10 on? 11 12 MR. KREEGER: Objection. Calls for a legal conclusion. 13 Go ahead. 14 THE WITNESS: A timer, as I understand it, 15 is -- is something that counts down from a -- from a 16 starting value to zero, typically. 17 18 19 20 21 22 23 24 25 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. TSG Reporting - Worldwide (877)-702-9580 Confidential Attorneys' Eyes Only Page 71 1 THE WITNESS: 2 BY MR. WHITEHURST: 3 Q. I don't really know. In line 14, what it does it mean when it 4 says "timer expired"? 5 MR. KREEGER: Same objection. 6 THE WITNESS: I don't know. 7 BY MR. WHITEHURST: 8 9 10 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. 11 understand the timer. 12 expired. 13 I I take to it mean that it's gone to zero. 14 15 16 17 18 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 19 17 of Column 10, starting with the word "wherein" 20 and ending with the word "system." 21 A. Wherein the first window does not close in 22 response to any input from a user input device of 23 the digital processing system. 24 25 Q. And what does this mean? MR. KREEGER: Objection. TSG Reporting - Worldwide Calls for a legal (877)-702-9580 Confidential Attorneys' Eyes Only Page 254 1 CERTIFICATE 2 STATE OF CALIFORNIA ) 3 ) COUNTY OF SONOMA : ss ) 4 5 I, Lorrie L. Marchant, a Certified Shorthand 6 Reporter, a Registered Professional Reporter, a 7 Certified Realtime Reporter, and a Certified 8 Realtime Professional within and for the State of 9 California, do hereby certify: 10 That IMRAN CHAUDHRI, the witness whose 11 deposition is herein set forth, was duly 12 sworn/affirmed by me and that such deposition is a 13 true record of the testimony given by such witness. 14 I further certify that I am not related to any 15 of the parties to this action by blood or marriage 16 and that I am in no way interested in the outcome of 17 this matter. 18 19 In witness whereof, I have hereunto set my hand this 15th day of October, 2011. 20 21 22 23 --------------------------------------------LORRIE L. MARCHANT, CSR, RPR, CRR, CLR, CCRR 24 CSR No. 10523 25 TSG Reporting - Worldwide (877)-702-9580 Confidential Attorneys' Eyes Only Page 253 1 today's deposition. 2 6:53 p.m. 3 Reporting. 4 We are off the record at The master disk will be held by TSG (Time noted: 5 6:53 p.m.) ---oOo--- 6 7 8 ____________________ IMRAN CHAUDHRI 9 10 Subscribed and sworn to before me this 11 of day 2011. 12 _______________________ 13 14 15 16 17 18 19 20 21 22 23 24 25 TSG Reporting - Worldwide (877)-702-9580

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