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)

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EXHIBIT R HIGHLY CONFIDENTIAL - OUTSIDE COUNSEL EYES ONLY MOON-SANG JEONG - 11/17/2011 • Page 46 If I could direct your 10:45:46 2 attention to column 6, lines 55 through 61 of your 10:45:47 3 patent, would you agree with me that you excluded 10:45:52 4 from the description of your invention a device that 10:46:02 5 uses a separate music control processor? 10:46:06 MR. BASSETT: 1 MS. MAROULIS: 6 7 Q. Objection. Calls for a 10:46:12 legal conclusion. THE WITNESS: 8 10:46:10 Speaking as an engineer at 10:46:44 the time of my work on developing this, the aim was 10:46:45 10 in the use of -- the nonuse, rather, of an 10:46:48 11 independent chipset. 10:46:54 9 • MR. BASSETT: 12 13 Q. A nonindependent chipset for music generation; correct? MAIN INTERPRETER: 14 Interjection by the 15 interpreter: Just so counsel is aware, the 16 interpreter said "nonuse of an independent chipset." 17 MR. BASSETT: 18 MS. MAROULIS: 19 Correct, I'm sorry. You may want to rephrase 10:47:06 10:47:12 10:47:13 10:47:17 10:47:22 10:47:24 10:47:25 that question. MR. BASSETT: 20 10:47:03 Q. In the answer you just 10:47:27 21 10:47:29 22 use -- I'm sorry. 10:47:37 23 independent chipset for the generation of music; 10:47:42 24 • gave previously, you meant that the aim was to correct. 10:47:45 25 617-542-0039 The aim was the nonuse of an (Discussion between the main interpreter Merrill Corporation - Boston www.merrillcorp.com/law 10:47:45

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