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

Filing 721

AFFIDAVIT in Opposition re #667 Administrative Motion to File Under Seal re Samsung's Motion to Supplement Invalidity Contentions DECLARATION OF RICHARD S.J. HUNG IN SUPPORT OF APPLES OPPOSITION TO SAMSUNGS MOTION TO SUPPLEMENT INVALIDITY CONTENTIONS filed byApple Inc.. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Exhibit J)(Related document(s) #667 ) (Hung, Richard) (Filed on 2/9/2012)

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Confidential Attorneys' Eyes Only Page 1 1 2 3 4 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION APPLE INC., a California corporation, 5 6 7 8 9 10 11 12 Plaintiff, vs. Case No. 11-CV-01846-LHK SAMSUNG ELECTRONICS CO., LTD., a Korean business entity; SAMSUNG ELECTRONICS AMERICA, INC., a New York corporation; SAMSUNG TELECOMMUNICATIONS AMERICA, LLC, a Delaware limited liability company, Defendants. ---------------------------------/ 13 14 15 16 17 18 19 20 CONFIDENTIAL ATTORNEYS' EYES ONLY OUTSIDE COUNSEL VIDEOTAPED DEPOSITION OF IMRAN CHAUDHRI Redwood Shores, California Friday, October 14, 2011 21 22 23 Reported by: LORRIE L. MARCHANT, CSR No. 10523, RPR, CRR, CCRR, CLR 24 JOB NO. 42879 25 TSG Reporting - Worldwide (877)-702-9580 Confidential Attorneys' Eyes Only Page 3 1 A P P E A R A N C E S: 2 3 4 5 FOR THE PLAINTIFF APPLE INC.: MORRISON & FOERSTER BY: MATTHEW KREEGER, ESQ. 425 Market Street San Francisco, California 94105 6 7 8 9 10 FOR THE DEFENDANTS SAMSUNG: QUINN EMANUEL URQUHART & SULLIVAN BY: ALAN WHITEHURST, ESQ. 1101 Pennsylvania Avenue NW Washington, D.C. 20004 11 12 and 13 BY: ALEX BAXTER, ESQ MARGRET CARUSO, ESQ. BRETT ARNOLD, ESQ. 555 Twin Dolphin Drive Redwood Shores, California 94065 14 15 16 17 and 18 19 BY: MICHAEL ZELLER, ESQ. 865 South Figueroa Street Los Angeles, California 90017 20 21 22 23 24 25 ALSO PRESENT: Cyndi Wheeler, Apple IP Litigation Counsel Alan Dias, Videographer ---oOo--TSG Reporting - Worldwide (877)-702-9580 Confidential Attorneys' Eyes Only Page 4 1 (Marked for identification purposes, 2 Exhibit 570 through 572.) 3 THE VIDEOGRAPHER: We are on the video 4 record at 9:34 a.m. 5 versus Samsung, in the United States District Court, 6 Northern District of California. 7 11-CV-01846-LHK. In the matter of Apple Inc., Case No. 8 We are located today at 555 Twin Dolphin 9 Drive, in the City of Redwood Shores, California. 10 Today is October 14, 2011, and the time is 9:35 a.m. 11 My name is Alan Dias from TSG Reporting. 12 Counsel, would you please identify yourself 13 14 for the record. MR. WHITEHURST: Good morning. 15 Alan Whitehurst. 16 Alex Baxter. 17 My name Emanuel, and we represent Samsung. 18 And with me today is my colleague, We are with the law firm Quinn MR. KREEGER: Matthew Kreeger, Morrison & 19 Foerster, representing Apple. With me is 20 Cyndi Wheeler from Apple. 21 22 23 THE VIDEOGRAPHER: Will the court reporter please swear in the witness. THE REPORTER: Do you solemnly swear or 24 affirm under the penalties of perjury that the 25 testimony you are about to offer will be the truth, TSG Reporting - Worldwide (877)-702-9580 Confidential Attorneys' Eyes Only Page 5 1 the whole truth and nothing but the truth? 2 THE WITNESS: 3 THE VIDEOGRAPHER: 4 I do. You may proceed. EXAMINATION BY MR. WHITEHURST 5 BY MR. WHITEHURST: 6 Q. Good morning, Mr. Chaudhri. 7 A. Good morning. 8 Q. My name is Alan Whitehurst, and I will be 9 taking your deposition today. 10 11 12 13 14 15 Could you please state your full name and address for the record. A. My name is Imran Chaudhri. My address is 57 Beaumont, San Francisco, California 94118. Q. And before the deposition, I marked as Exhibit 570 a copy of your Deposition Notice. 16 Have you testified in a deposition before? 17 A. I have. 18 Q. How many times? 19 A. Once. 20 Q. And what case was that for? 21 A. It was a -- a case involving Motorola. 22 Q. Was that for a litigation between Motorola 23 and Apple? 24 A. I believe so. 25 Q. And when was that deposition? TSG Reporting - Worldwide (877)-702-9580 Confidential Attorneys' Eyes Only Page 13 R E D A 3 4 Q. patent, for example, Figure 7. 5 6 If you would look at the figures in this Is Figure 7 a picture of the user interface for Mac OS X? 7 A. It's a drawing that looks like it could be. 8 Q. And would the user interface in Mac OS X 9 10 look like Figure 7? A. I don't know what this is trying to be, but 11 there are elements of it that look like Mac OS X for 12 sure. 13 Q. 14 15 Can you turn to Figure 8, please. What is Figure 8? A. I understand Figure 8 to be an indicator of 16 battery level over the window that we were just 17 looking at. 18 Q. 19 indicator? 20 A. 21 22 23 And does Mac OS X have a battery level There are battery level indicators in Mac OS X. Q. And does the battery level indicator in Mac OS X look like Figure 8? 24 A. It does not look like Figure 8. 25 Q. What does the battery level indicator look TSG Reporting - Worldwide (877)-702-9580 Confidential Attorneys' Eyes Only Page 254 1 CERTIFICATE 2 STATE OF CALIFORNIA ) 3 ) COUNTY OF SONOMA : ss ) 4 5 I, Lorrie L. Marchant, a Certified Shorthand 6 Reporter, a Registered Professional Reporter, a 7 Certified Realtime Reporter, and a Certified 8 Realtime Professional within and for the State of 9 California, do hereby certify: 10 That IMRAN CHAUDHRI, the witness whose 11 deposition is herein set forth, was duly 12 sworn/affirmed by me and that such deposition is a 13 true record of the testimony given by such witness. 14 I further certify that I am not related to any 15 of the parties to this action by blood or marriage 16 and that I am in no way interested in the outcome of 17 this matter. 18 19 In witness whereof, I have hereunto set my hand this 15th day of October, 2011. 20 21 22 23 --------------------------------------------LORRIE L. MARCHANT, CSR, RPR, CRR, CLR, CCRR 24 CSR No. 10523 25 TSG Reporting - Worldwide (877)-702-9580

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