Apple Inc. v. Samsung Electronics Co. Ltd. et al

Filing 558

REPLY CLAIM CONSTRUCTION BRIEF to re #461 Claim Construction Statement Pursuant to Patent L.R. 4-5 by Apple Inc.. (Attachments: #1 Declaration, #2 Exhibit R, #3 Exhibit S, #4 Exhibit T, #5 Exhibit U, #6 Exhibit V)(Jacobs, Michael) (Filed on 12/29/2011) Modified text on 12/30/2011 (dhm, COURT STAFF).

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HAROLD J. MCELHINNY (CA SBN 66781)
[e-mail]
MICHAEL A. JACOBS (CA SBN 111664)
[e-mail]
RICHARD S.J. HUNG (CA SBN 197425)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff and
Counterclaim-Defendant APPLE INC.

WILLIAM F. LEE
[e-mail]
WILMER CUTLER PICKERING
HALE AND DORR LLP
60 State Street
Boston, MA 02109
Telephone: [phone]
Facsimile: [phone]
MARK D. SELWYN (SBN 244180)
[e-mail]
WILMER CUTLER PICKERING
HALE AND DORR LLP
950 Page Mill Road
Palo Alto, California 94304
Telephone: [phone]
Facsimile: [phone]

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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APPLE INC., a California corporation,

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Plaintiff,
v.
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.,

Case No.

11-cv-01846-LHK

REPLY DECLARATION OF DEOK
KEUN MATTHEW AHN IN
SUPPORT OF APPLE’S REPLY
CLAIM CONSTRUCTION BRIEF
PURSUANT TO PATENT L.R. 4-5
Claim Construction
Hearing: Jan 20, 2012
Time: 10:00 a.m.
Place: Courtroom 4, 5th Floor
Judge: Honorable Lucy H. Koh

Defendants.

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AHN REPLY DECLARATION IN SUPPORT OF APPLE’S REPLY CLAIM CONSTRUCTION BRIEF
CASE NO. 11-CV-01846-LHK
sf-3080799

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I, Deok Keun Matthew Ahn, declare as follows:

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1.

I am an associate at the law firm of Morrison & Foerster LLP, attorneys of record

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in this action for plaintiff Apple Inc. (“Apple”). I submit this declaration in support of Apple’s

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Reply Claim Construction Brief Pursuant to Patent L.R. 4-5. Unless otherwise indicated, I have

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personal knowledge of the matters set forth below. If called as a witness I could and would

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testify competently as follows:

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2.

Attached hereto as Exhibit R to this Declaration is a true and correct copy of an

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Appeal Brief in Support of Appellants’ Appeal to the Board of Patent Appeals and Interferences

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bearing Bates Numbers APLNDC00028960-28993, excerpted from the produced file history of

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U.S. Patent No. 6,493,002.
3.

Attached hereto as Exhibit S to this Declaration is a true and correct copy of an

excerpt from the transcript of the August 16, 2011 deposition of Ravin Balakrishnan.
4.

Attached hereto as Exhibit T to this Declaration is a true and correct copy of a

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redacted excerpt from the transcript of the September 23, 2011 Prehearing and Tutorial before the

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United States International Trade Commission in Investigation No. 337-TA-750 reflecting the

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testimony of Wayne Carl Westerman, Ph.D., regarding ellipse fitting.

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5.

Attached hereto as Exhibit U to this Declaration is a true and correct copy of an

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excerpt from the Corrected Witness Statement of Dr. Ravin Balakrishnan submitted to the United

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States International Trade Commission in Investigation No. 337-TA-750.

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6.

Attached hereto as Exhibit V to this Declaration is a true and correct copy of an

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excerpt from the September 9, 2011 Pre-trial Statement and Brief of the Commission

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Investigative Staff submitted to the United States International Trade Commission in

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Investigation No. 337-TA-750.

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I declare under the penalty of perjury that the forgoing is true and correct. Executed this
29th day of December, 2011, at San Francisco, California.

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/s/ Deok Keun Matthew Ahn
Deok Keun Matthew Ahn
AHN REPLY DECLARATION IN SUPPORT OF APPLE’S REPLY CLAIM CONSTRUCTION BRIEF
CASE NO. 11-CV-01846-LHK
sf-3080799

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ATTESTATION OF E-FILED SIGNATURE
I, Michael A. Jacobs, am the ECF User whose ID and password are being used to file this

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Declaration. In compliance with General Order 45, X.B., I hereby attest that Deok Keun

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Matthew Ahn has concurred in this filing.

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Dated: December 29, 2011

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/s/ Michael A. Jacobs
Michael A. Jacobs