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

Filing 595

CLAIM CONSTRUCTION STATEMENT Samsung's Reply Claim Construction Brief filed by Samsung Electronics America, Inc.. (Attachments: # 1 Declaration Briggs Declaration in Support of Samsung's Reply Claim Construction Brief, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, # 10 Exhibit I, # 11 Exhibit J)(Maroulis, Victoria) (Filed on 1/9/2012)

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1 I, Todd M. Briggs, declare as follows: 2 1. I am a partner with the law firm of Quinn Emanuel Urquhart & Sullivan LLP and 3 counsel for defendants and counter-claimants Samsung Electronics Co. Ltd., Samsung Electronics 4 America, Inc., and Samsung Telecommunications America, LLC (collectively, “Samsung”). I 5 submit this declaration in support of Samsung’s Reply Claim Construction Brief. I am personally 6 familiar with and knowledgeable about the facts stated in this declaration and if called upon could 7 and would testify competently as to the statements made herein. 8 2. Attached hereto as Exhibit A is a true and correct copy of certain excerpts from the 9 Deposition of Tony Givargis, Ph.D., including lines 81:8-13. 10 3. Attached hereto as Exhibit B is a true and correct copy of certain excerpts from the 11 Deposition of Tony Givargis, Ph.D., including lines 36:15-23 and 39:17-40:1. 12 4. Attached hereto as Exhibit C is a true and correct copy certain excerpts from the 13 Deposition of Tony Givargis, Ph.D., including lines 35:25-36:4. 14 5. Attached hereto as Exhibit D is a true and correct copy of certain excerpts from the 15 Deposition of Tony Givargis, Ph.D., including lines 40:13-23 and 41:17-19. 16 6. Attached hereto as Exhibit E is a true and correct copy of certain excerpts from the 17 Deposition of Tony Givargis, Ph.D., including lines 41:25-42:8. 18 7. Attached hereto as Exhibit F is a true and correct copy of certain excerpts from the 19 Deposition of Tony Givargis, Ph.D., including lines 40:6-9. 20 8. Attached hereto as Exhibit G is a true and correct copy of certain excerpts from the 21 Deposition of Tony Givargis, Ph.D., including lines 70:24-71:6 and 73:1-11. 22 9. Attached hereto as Exhibit H is a true and correct copy of certain excerpts from the 23 Deposition of Tony Givargis, Ph.D., including lines 53:10-11 and 94:3-4. 24 10. Attached hereto as Exhibit I is a true and correct copy of certain excerpts from the 25 Deposition of Tony Givargis, Ph.D., including lines 86:12-25 and 87:21-88:2. 26 11. Attached hereto as Exhibit J is a true and correct copy of certain excerpts from the 27 Deposition of Tony Givargis, Ph.D., including lines 86:4-17. 28 99999.77769/4527099.1 -2- Case No. 11-cv-01846-LHK DECLARATION OF TODD M. BRIGGS IN SUPPORT OF SAMSUNG'S REPLY CLAIM CONSTRUCTION BRIEF 1 I hereby declare under penalty of perjury under the laws of the United States that the 2 foregoing is true and correct. 3 4 DATED: December 29, 2011 5 6 7 8 9 10 QUINN EMANUEL URQUHART & SULLIVAN, LLP By /s/ Todd M. Briggs Todd M. Briggs Attorneys for Defendants/Counter-Claimants SAMSUNG ELECTRONICS CO., LTD., SAMSUNG ELECTRONICS AMERICA, INC. and SAMSUNG TELECOMMUNICATIONS AMERICA, LLC 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 99999.77769/4527099.1 -3- Case No. 11-cv-01846-LHK DECLARATION OF TODD M. BRIGGS IN SUPPORT OF SAMSUNG'S REPLY CLAIM CONSTRUCTION BRIEF

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