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).
EXHIBIT S
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION
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APPLE INC., a California
corporation,
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Plaintiff,
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vs.
CASE NO. 11-CV-01846-LHK
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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,
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Defendants.
_____________________________/
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C O N F I D E N T I A L
A T T O R N E Y S' E Y E S O N L Y
O U T S I D E
C O U N S E L
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VIDEOTAPED DEPOSITION OF RAVIN BALAKRISHNAN, Ph.D.
SAN FRANCISCO, CALIFORNIA
TUESDAY, AUGUST 16, 2011
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BY: ANDREA M. IGNACIO HOWARD, CSR, RPR, CCRR, CLR
CSR LICENSE NO. 9830
JOB NO. 41176
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TUESDAY, AUGUST 16, 2011
9:10 a.m.
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VIDEOTAPED DEPOSITION OF RAVIN BALAKRISHNAN,
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Ph.D., taken at QUINN EMANUEL URQUHART &
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SULLIVAN, 50 California Street, 22nd Floor,
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San Francisco, California, pursuant to
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Notice, before me, ANDREA M. IGNACIO HOWARD,
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CLR, CCRR, RPR, CSR License No. 9830.
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A P P E A R A N C E S:
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FOR APPLE INC.:
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MORRISON & FOERSTER
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By:
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ANDREW E. MONACH, Esq.
DEOK KEUN AHN, Esq.
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425 Market Street
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San Francisco, California 94105
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FOR SAMSUNG ELECTRONICS CO. LTD:
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QUINN EMANUEL URQUHART & SULLIVAN
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By:
KEVIN JOHNSON, Esq.
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HENRY LIEN, Esq.
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TODD BRIGGS, Esq.
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MARK TUNG, Ph.D., Esq.
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555 Twin Dolphin Drive
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Redwood Shores, California 94065
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ALSO PRESENT:
Alan Dias, Videographer
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SAN FRANCISCO, CALIFORNIA
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TUESDAY, AUGUST 16, 2011
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9:10 a.m.
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THE VIDEOGRAPHER:
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This is the beginning of Disk No. 1, of the
Good morning.
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videotaped deposition of Dr. Balakrishnan, in the
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matter of Apple versus Samsung, et al., in the United
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States District Court, Northern District of
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California, San Jose Division.
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We are located today at 50 California Street,
in the City of San Francisco, California.
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Today's August 16, 2011, and the time is
9:10 a.m.
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My name is Alan Dias from TSG Reporting.
Here with me is Andrea Ignacio.
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Counsel, would you please identify yourself
for the record.
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MR. JOHNSON:
of Samsung.
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MR. MONACH:
Andrew Monach, representing
Apple and the witness.
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This is Kevin Johnson on behalf
MR. TUNG:
I'm Mark Tung, representing
Samsung.
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application and what a document means in that context.
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MR. JOHNSON:
Q.
If -- going back to the
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original two-by-four rectangle of 15, 16, 17, 18, 21,
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22, 23, 24, if you look at that, is it fair to say
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that this line right here is an edge of the electronic
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document?
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A
The line --
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MR. MONACH:
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Hang on a second.
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THE WITNESS:
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MR. MONACH:
Object.
I'm sorry.
Objection; vague and ambiguous;
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incomplete hypothetical; calling for a legal
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conclusion and a new opinion.
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THE WITNESS:
this prior to this, you putting this in front of me.
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So, again, I haven't considered
Thinking on the fly here, so you're saying
this line -- the vertical line between --
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MR. JOHNSON:
Since the witness is pointing,
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I just want to make sure you get what he's pointing
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to.
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Yeah.
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THE WITNESS:
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The vertical line between 14
and 15, and 20 and 21, here, this --
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Q
That -- that's right, yeah.
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A
-- line.
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Given this hypothetical scenario, where
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you're saying the -- this two -- I'm sorry --
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two-by-four grid of elements -- rectangle is an
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electronic document in this hypothetical scenario,
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that would be indeed, I guess, one boundary one
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edge --
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Q
Okay.
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A
-- of that.
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Q
So let's just label that "edge" for me, just
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so I can keep track of it after the deposition.
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Just --
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A
What do you want me to call it?
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Q
Just call it "edge," and then maybe put it
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down at the bottom and draw an arrow down to the line,
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or something.
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Like this?
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Q
Yeah.
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A
Okay.
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Q
Okay.
And then, is it fair to say that
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the -- the -- the Blocks 14 and 20 are an area beyond
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the edge --
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MR. MONACH:
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MR. JOHNSON:
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Same -Q.
-- of the electronic
document?
MR. MONACH:
Same objection.
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THE WITNESS:
So, again, considering this for
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the first time here, I haven't thought this in detail,
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if, in this hypothetical scenario, the document is
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this two-by-four grid, labelled 15, 16, 17, 18, 21,
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22, 23, 24, if that is the document, then anything
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beyond that edge would be an area outside the document
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beyond the edge of the document.
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So given those hypotheticals, area 14 and 20
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would be beyond the edge of the document, given that
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scenario.
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MR. JOHNSON:
Okay.
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Q
So can you just label that "beyond the edge"?
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A
How -- just label each one of these?
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Q
Yeah, or just draw -- however you want.
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A
Well, we're getting a lot of drawings on this
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thing, so I don't know.
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"Beyond."
Speaking of which, let me just mark the --
the grid as Exhibit 104.
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Put it on the bottom?
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Q
Thanks.
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(Phone marked Balakrishnan Exhibit 104
for identification.)
MR. JOHNSON:
Q.
Can you look at the Galaxy
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Tab, which is Exhibit 101, and pull up for me the
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contacts application.
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J U R A T
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I, RAVIN BALAKRISHNAN, Ph.D., do hereby
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certify under penalty of perjury that, I have read the
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foregoing transcript of my deposition taken on
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August 16, 2011; that I have made such corrections as
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appear noted herein in ink, initialed by me; that my
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testimony as contained herein, as corrected, is true
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and correct.
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DATED this ____ day of _____________, 2011,
at _____________________________.
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__________________________________
SIGNATURE OF WITNESS
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TSG Reporting - Worldwide
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