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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I, Todd M. Briggs, declare as follows:

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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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99999.77769/4527099.1

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Case No. 11-cv-01846-LHK

DECLARATION OF TODD M. BRIGGS IN SUPPORT OF SAMSUNG'S REPLY CLAIM CONSTRUCTION BRIEF

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I hereby declare under penalty of perjury under the laws of the United States that the

2 foregoing is true and correct.
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4 DATED: December 29, 2011
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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

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99999.77769/4527099.1

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Case No. 11-cv-01846-LHK

DECLARATION OF TODD M. BRIGGS IN SUPPORT OF SAMSUNG'S REPLY CLAIM CONSTRUCTION BRIEF