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

Filing 628

RESPONSE to re #623 Order on Administrative Motion to File Under Seal, Apple Inc.s Responsive Claim Construction Brief, Refiled by Court Order (D.N. 623) by Apple Inc.(a California corporation). (Attachments: #1 Declaration of Mark D. Selwyn in Support of Apple's Responsive 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, #12 Exhibit K, #13 Exhibit L, #14 Exhibit M, #15 Exhibit N, #16 Exhibit O, #17 Exhibit P, #18 Exhibit Q, #19 Exhibit R, #20 Exhibit S)(Selwyn, Mark) (Filed on 1/13/2012)

EXHIBIT R

HIGHLY CONFIDENTIAL - OUTSIDE COUNSEL EYES ONLY
MOON-SANG JEONG - 11/17/2011

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Page 46
If I could direct your

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attention to column 6, lines 55 through 61 of your

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patent, would you agree with me that you excluded

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from the description of your invention a device that

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uses a separate music control processor?

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MR. BASSETT:

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MS. MAROULIS:

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Q.

Objection.

Calls for a

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legal conclusion.
THE WITNESS:

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Speaking as an engineer at

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the time of my work on developing this, the aim was

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in the use of -- the nonuse, rather, of an

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independent chipset.

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MR. BASSETT:

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Q.

A nonindependent chipset

for music generation; correct?
MAIN INTERPRETER:

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Interjection by the

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interpreter:

Just so counsel is aware, the

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interpreter said "nonuse of an independent chipset."

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MR. BASSETT:

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MS. MAROULIS:

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Correct, I'm sorry.
You may want to rephrase

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that question.
MR. BASSETT:

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Q.

In the answer you just

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use -- I'm sorry.

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independent chipset for the generation of music;

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gave previously, you meant that the aim was to

correct.

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617-542-0039

The aim was the nonuse of an

(Discussion between the main interpreter

Merrill Corporation - Boston
www.merrillcorp.com/law

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