Apple Inc. v. Samsung Electronics Co. Ltd. et al
Filing
619
Administrative Motion to File Under Seal (Renewed) filed by Apple Inc.. (Attachments: #1 Declaration Declaration of Cyndi Wheeler In Support of Apple's Renewed Administrative Motion to File Documents Under Seal, #2 Exhibit B to T. Briggs In Support of Samsung's Response to Apple's Opening Claim Construction, #3 Exhibit I to T. Briggs In Support of Samsung's Response to Apple's Opening Claim Construction, #4 Exhibit J to T. Briggs In Support of Samsung's Response to Apple's Opening Claim Construction, #5 Samsung's Response to Apple's Opening Claim Construction, #6 Proposed Order [Proposed] Order Granting Apple's Renewed Administrative Motion to File Documents Under Seal)(Hung, Richard) (Filed on 1/12/2012)
EXHIBIT B
FILED UNDER SEAL
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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
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corporation,
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Plaintiff,
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vs.
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SAMSUNG ELECTRONICS CO., LTD.,
NO. 11 CV 01846 LHK
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a Korean business entity;
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SAMSUNG ELECTRONICS AMERICA,
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INC., a New York corporation;
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SAMSUNG TELECOMMUNICATIONS
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AMERICA, LLC, a Delaware
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limited liability company,
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Defendants.
______________________________
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DEPOSITION OF STEVEN CHRISTENSEN
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Taken on behalf of the Defendants
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October 26, 2011
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Job Number: 42864
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DEPOSITION OF STEVEN CHRISTENSEN
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Taken on behalf of the Defendants
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October 26, 2011
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BE IT REMEMBERED THAT, pursuant to the
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California Rules of Civil Procedure, the deposition
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of STEVEN CHRISTENSEN was taken before MICHELE J.
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LUCAS, a Certified Shorthand Reporter, on October
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26, 2011, commencing at the hour of 9:13 a.m., the
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proceedings being reported at 1389 Center Drive
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Medford, Oregon.
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DEPOSITION OF STEVEN CHRISTENSEN
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Wednesday, October 26, 2011
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9:13 a.m.
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THE VIDEOGRAPHER:
This is the start of
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tape labeled No. 1 of the videotape deposition of
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Steve Christensen in the matter of Apple vs. Samsung
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in the court of U.S. District Court, Northern
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District of California, San Jose Division, case
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No. 11 CV 01846 LHK.
This deposition is being held at 1389
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Center Drive in Medford, Oregon on October 26, 2011
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at approximately 9:13 a.m.
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My name is Steve Brown from TSG Reporting,
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Incorporated.
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court reporter is Michele Lucas in association with
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TSG Reporting.
I am the legal video specialist.
The
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Will counsel please introduce yourselves.
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MR. BRIGGS:
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Todd Briggs from Quinn Emanuel
for Samsung.
THE VIDEOGRAPHER:
Would the reporter
please swear in the witness.
MR. KRAMER:
Karl Kramer from Morrison
Foerster on behalf of Apple, Inc. and the witness.
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STEVEN CHRISTENSEN,
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having been first duly sworn,
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was examined and testified as follows:
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EXAMINATION
BY MR. BRIGGS:
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Q.
Good morning.
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A.
Good morning.
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Q.
Can you state your name for the record.
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A.
Steven Christensen.
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Q.
Where do you live, Mr. Christensen?
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A.
Ashland, Oregon.
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Q.
Where is Ashland?
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A.
About ten miles south of here.
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Q.
Where do you work?
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A.
I work for a small startup company that I
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am a cofounder.
It is called Folium & Partners.
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Q.
Do you work for Apple Computer?
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A.
No.
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Q.
Are you a consultant for Apple Computer?
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A.
No.
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Q.
Now, you have worked for Apple in the past,
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correct?
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A.
Yes.
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Q.
And when was that?
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A.
1982 through 1996.
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The actual display of the battery level was
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managed by the module that displays the battery
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level.
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BY MR. BRIGGS:
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Q.
So in this example the battery module would
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obtain information from the operating system about
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the battery level, and then it could communicate that
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information to the Control Strip, correct?
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A.
No.
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Q.
No?
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How does that work?
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MR. KRAMER:
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Objection.
Vague and
ambiguous.
THE WITNESS:
Okay.
As I said before, the
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battery module is a self contained piece of code, and
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all it will do basically is ask the operating system
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what the current battery level is and to convert that
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into a display.
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What causes that module to be redrawn is
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the Control Strip calling the module and saying:
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Draw yourself.
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will make that inquiry of the operating system to see
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what the battery level is.
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(Exhibit 978 was marked for identification)
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BY MR. BRIGGS:
In the process of drawing itself it
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Q.
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Exhibit 978.
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I am handing you what has been marked as
Can you review that document and let me
know if you recognize it.
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A.
Okay.
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Q.
Do you recognize this document?
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A.
Yes.
R
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A
C
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E
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REDACTED
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Q.
Did you write this
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A.
Yes.
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Q.
Did anybody else help you write it?
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A.
Not that I recall.
document?
R
E
.
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Do you see that?
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A.
Yes.
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Q.
And do you think that is an accurate date
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of when this document was written?
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A.
I expect so, yes.
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Q.
Now, is this a copy of a document you found
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in your files?
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A.
Yes.
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Q.
Where did you find this?
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A.
It was in a folder on my hard disk, my
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computer.
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BY MR. BRIGGS:
Q.
Okay.
The next clause states:
"And
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wherein each of the plurality of display areas is
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associated with one of the plurality of individual
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programming modules."
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What does that part mean to you?
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MR. KRAMER:
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Objection.
Calls for a legal
conclusion, lacks foundation.
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THE WITNESS:
Again, my nonlegal reading is
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that it is saying that each of the display areas that
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is shown in the Control Strip in that graphic, if you
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want, is generated by a particular module.
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BY MR. BRIGGS:
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Q.
programming module?
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So in this case what is an individual
MR. KRAMER:
Objection.
Calls for legal
conclusion, lacks foundation.
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THE WITNESS:
In the case of the Control
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Strip, it refers to one of these code modules that
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are described in the ERS, the details of, you know,
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what is required to implement and are loaded by the
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Control Strip when the operating system starts up.
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BY MR. BRIGGS:
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Q.
Okay.
Let's go to the next part of this
limitation.
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It states:
"The first window region and
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the plurality of independent display areas
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implemented in a window layer that appears on top of
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application programming windows that may be
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generated."
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A.
I am sorry.
Can you tell me what line that
is on.
Q.
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Yeah.
Let me start over.
It is on 28.
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A.
Okay.
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Q.
So it states:
It starts off, comma, "the."
"The first window region and
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the plurality of independent display areas
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implemented in a window layer that appears on top of
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application programming windows that may be
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generated."
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What does that mean to you?
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MR. KRAMER:
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Objection.
Calls for a legal
conclusion, lacks foundation.
THE WITNESS:
Okay.
In the case of the
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Control Strip it means to me that a layer is created
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that is above, or is in front of, to be accurate, the
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layers that contain the windows for application
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programs, and the Control Strip creates a window that
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lives in that layer so that it floats in front of the
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application windows, and that the window contains a
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number of display areas, and I think that is all.
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think that is enough of that, yes.
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BY MR. BRIGGS:
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Q.
I
Does that mean that any application windows
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that are generated appear underneath the first window
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region?
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MR. KRAMER:
Objection.
Lacks foundation,
calls for a legal conclusion, vague and ambiguous.
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THE WITNESS:
It means that the Control
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Strip window floats in front of the other windows,
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and so if an application creates a window it will
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appear behind the Control Strip window.
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BY MR. BRIGGS:
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Q.
And that's how the Control Strip worked on
the PowerBook computers, correct?
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MR. KRAMER:
Objection.
Vague and
ambiguous.
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THE WITNESS:
The window floated in front
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of the application window
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windows, yes, and it was on the PowerBooks
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originally, and also it migrated to desktop
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McIntoshes over time.
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BY MR. BRIGGS:
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Q.
claim.
the other application
Let's move to the next portion of this
It states:
"An indicia generation logic
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couple to the data display screen to execute at least
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one of the plurality of individual programming
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modules to generate information for display in one of
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the plurality of display areas in the first window
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region."
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So what is the indicia generation logic?
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MR. KRAMER:
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conclusion, lack of foundation.
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THE WITNESS:
Objection.
Calls for a legal
I wouldn't have written it
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that way.
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but for the Control Strip what I understand it to be
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is that a Control Strip is basically
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modules that are installed, and so it is calling them
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to execute their code to draw their content in the
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space that they have been provided.
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BY MR. BRIGGS:
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Q.
It sounds like it is overcomplex sounding,
has a list of
So you would say that the indicia
generation logic is part of the Control Strip?
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MR. KRAMER:
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conclusion, lack of foundation.
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THE WITNESS:
Objection.
Calls for a legal
My understanding that what it
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implies would be part of the Control Strip, yes.
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BY MR. BRIGGS:
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Q.
So this same phrase it states:
"An indicia
generation logic coupled with the data display screen
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