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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A

Like this?

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Q

Yeah.

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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.
Q

"Beyond."

Speaking of which, let me just mark the --

the grid as Exhibit 104.

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A

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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