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

Filing 709

Declaration of Cyndi Wheeler in Support of #667 Administrative Motion to File Under Seal re Samsung's Motion to Supplement Invalidity Contentions, #675 Administrative Motion to File Under Seal re Exhibit 4 to Briggs Declaration in Support of Samsung's Motion to Supplement Invalidity Contentions filed byApple Inc.. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4)(Related document(s) #667 , #675 ) (Hung, Richard) (Filed on 2/2/2012)

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EXHIBIT 3 EXHIBIT Q FILED UNDER SEAL HIGHLY CONFIDENTIAL UNDER THE PROTECTIVE ORDER Page 1 1 UNITED STATES DISTRICT COURT 2 NORTHERN DISTRICT OF CALIFORNIA 3 SAN JOSE DIVISION 4 5 APPLE, INC., a California 6 corporation, 7 Plaintiff, 8 vs. 9 SAMSUNG ELECTRONICS CO., LTD., NO. 11-CV-01846-LHK 10 a Korean business entity; 11 SAMSUNG ELECTRONICS AMERICA, 12 INC., a New York corporation; 13 SAMSUNG TELECOMMUNICATIONS 14 AMERICA, LLC, a Delaware 15 limited liability company, 16 17 18 Defendants. ______________________________ HIGHLY CONFIDENTIAL UNDER THE PROTECTIVE ORDER 19 DEPOSITION OF STEVEN CHRISTENSEN 20 Taken on behalf of the Defendants 21 October 26, 2011 22 23 24 25 Job Number: 42864 TSG Reporting - Worldwide 877-702-9580 HIGHLY CONFIDENTIAL UNDER THE PROTECTIVE ORDER Page 6 1 STEVEN CHRISTENSEN, 2 having been first duly sworn, 3 was examined and testified as follows: 4 5 EXAMINATION BY MR. BRIGGS: 6 Q. Good morning. 7 A. Good morning. 8 Q. Can you state your name for the record. 9 A. Steven Christensen. 10 Q. Where do you live, Mr. Christensen? 11 A. Ashland, Oregon. 12 Q. Where is Ashland? 13 A. About ten miles south of here. 14 Q. Where do you work? 15 A. I work for a small startup company that I 16 am a cofounder. It is called Folium & Partners. 17 Q. Do you work for Apple Computer? 18 A. No. 19 Q. Are you a consultant for Apple Computer? 20 A. No. 21 Q. Now, you have worked for Apple in the past, 22 correct? 23 A. Yes. 24 Q. And when was that? 25 A. 1982 through 1996. TSG Reporting - Worldwide 877-702-9580 HIGHLY CONFIDENTIAL UNDER THE PROTECTIVE ORDER Page 168 R E D A C T E D TSG Reporting - Worldwide 877-702-9580 HIGHLY CONFIDENTIAL UNDER THE PROTECTIVE ORDER Page 169 R E D A C T E D TSG Reporting - Worldwide 877-702-9580 HIGHLY CONFIDENTIAL UNDER THE PROTECTIVE ORDER Page 170 R E D A C T E D TSG Reporting - Worldwide 877-702-9580 HIGHLY CONFIDENTIAL UNDER THE PROTECTIVE ORDER Page 183 R E D A C T E D TSG Reporting - Worldwide 877-702-9580 HIGHLY CONFIDENTIAL UNDER THE PROTECTIVE ORDER Page 184 R E D A C T E D TSG Reporting - Worldwide 877-702-9580 HIGHLY CONFIDENTIAL UNDER THE PROTECTIVE ORDER Page 185 R E D A C T E D TSG Reporting - Worldwide 877-702-9580 HIGHLY CONFIDENTIAL UNDER THE PROTECTIVE ORDER Page 190 1 patent. 2 Q. Do you have any views on the patent system 3 in general? 4 Some people don't like software patents. 5 Do you have any views like that? 6 7 8 9 I mean some people don't like patents. A. I don't really have an opinion. They just Q. Do you think they are a good thing or bad are. thing? 10 A. I think patents are fine. 11 Q. Do you have any other patents? 12 A. I had done a second patent filing for 13 another company a few years later. 14 recently that the company allowed it to lapse a few 15 years ago. 16 Q. I found out Did that patent relate to windows or 17 control strips or anything like what we have been 18 discussing today? 19 A. No. 20 Q. Do you know -- did you ever receive any 21 awards for the 002 patent? 22 A. No. 23 Q. Any -- did you receive any kind of 24 25 recognition for the 002 patent? A. I think the filing happened after I left TSG Reporting - Worldwide 877-702-9580 HIGHLY CONFIDENTIAL UNDER THE PROTECTIVE ORDER Page 191 1 Apple. 2 Apple. 3 Q. So, no. Or the issuance was after I left Do you know if the Control Strip led to 4 success of any, commercial success, of any Apple 5 products or anything like that? 6 MR. KRAMER: 7 Objection. Lack of foundation, calls for speculation. 8 THE WITNESS: 9 any product's success. 10 11 I have no idea if it improved BY MR. BRIGGS: Q. Did you ever see any reports on -- from 12 consumers saying they liked or didn't like Control 13 Strip? 14 A. I don't remember. There were probably 15 reviews in magazines at the time, but I don't 16 remember now. R E D A C TE D TSG Reporting - Worldwide 877-702-9580 HIGHLY CONFIDENTIAL UNDER THE PROTECTIVE ORDER Page 192 R E D A C T 4 5 Q. Do you still own -- or do you own Apple stock? 6 A. No. 7 Q. And today do you develop software for Apple 8 products? 9 A. I develop software for IOS devices, which 10 is I-Phone and I-Pad, and my company in general also 11 develops for windows phone seven. 12 Q. 13 and windows? 14 A. At a high level. 15 Q. Applications? 16 A. Yes. 17 Q. Are there any specific applications? 18 A. They are related to publishing and audio 19 At a high level what do you develop for IOS Applications. books, not one single title. 20 MR. BRIGGS: Can we take a break, and then 21 I think I can wrap it up in another half hour at the 22 most. 23 24 25 THE VIDEOGRAPHER: The time is 3:19, and we are off the record. (Recess taken) TSG Reporting - Worldwide 877-702-9580 HIGHLY CONFIDENTIAL UNDER THE PROTECTIVE ORDER Page 196 1 CERTIFICATE 2 3 I, Michele J. Lucas, do hereby certify that pursuant 4 to the Rules of Civil Procedure, the witness named herein 5 appeared before me at the time and place set forth in the 6 caption herein; that at the said time and place, I reported 7 in stenotype all testimony adduced and other oral 8 proceedings had in the foregoing matter; and that the 9 foregoing transcript pages constitute a full, true and 10 correct record of such testimony adduced and oral proceeding 11 had and of the whole thereof. 12 13 14 IN WITNESS HEREOF, I have hereunto set my hand this 27th day of October, 2011. 15 16 17 18 19 _________________________ 20 /Signed August, 2013 21 Michele J. Lucas Commission Expiration 22 23 24 25 TSG Reporting - Worldwide 877-702-9580

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