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)

Confidential Attorneys' Eyes Only

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION
APPLE INC., a California
corporation,

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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.
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CONFIDENTIAL
ATTORNEYS' EYES ONLY
OUTSIDE COUNSEL
VIDEOTAPED DEPOSITION OF IMRAN CHAUDHRI
Redwood Shores, California
Friday, October 14, 2011

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Reported by:
LORRIE L. MARCHANT, CSR No. 10523, RPR, CRR, CCRR, CLR

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JOB NO. 42879
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A P P E A R A N C E S:

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FOR THE PLAINTIFF APPLE INC.:
MORRISON & FOERSTER
BY: MATTHEW KREEGER, ESQ.
425 Market Street
San Francisco, California 94105

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FOR THE DEFENDANTS SAMSUNG:
QUINN EMANUEL URQUHART & SULLIVAN
BY: ALAN WHITEHURST, ESQ.
1101 Pennsylvania Avenue NW
Washington, D.C. 20004

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and

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BY:

ALEX BAXTER, ESQ
MARGRET CARUSO, ESQ.
BRETT ARNOLD, ESQ.
555 Twin Dolphin Drive
Redwood Shores, California 94065

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and

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BY: MICHAEL ZELLER, ESQ.
865 South Figueroa Street
Los Angeles, California 90017

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ALSO PRESENT:
Cyndi Wheeler, Apple IP Litigation Counsel
Alan Dias, Videographer
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(Marked for identification purposes,

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Exhibit 570 through 572.)

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THE VIDEOGRAPHER:

We are on the video

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record at 9:34 a.m.

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versus Samsung, in the United States District Court,

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Northern District of California.

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11-CV-01846-LHK.

In the matter of Apple Inc.,

Case No.

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We are located today at 555 Twin Dolphin

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Drive, in the City of Redwood Shores, California.

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Today is October 14, 2011, and the time is 9:35 a.m.

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My name is Alan Dias from TSG Reporting.

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Counsel, would you please identify yourself

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for the record.
MR. WHITEHURST:

Good morning.

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Alan Whitehurst.

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Alex Baxter.

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My name

Emanuel, and we represent Samsung.

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And with me today is my colleague,

We are with the law firm Quinn

MR. KREEGER:

Matthew Kreeger, Morrison &

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Foerster, representing Apple.

With me is

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Cyndi Wheeler from Apple.

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THE VIDEOGRAPHER:

Will the court reporter

please swear in the witness.
THE REPORTER:

Do you solemnly swear or

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affirm under the penalties of perjury that the

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testimony you are about to offer will be the truth,
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the whole truth and nothing but the truth?

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THE WITNESS:

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THE VIDEOGRAPHER:

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I do.
You may proceed.

EXAMINATION BY MR. WHITEHURST

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BY MR. WHITEHURST:

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Q.

Good morning, Mr. Chaudhri.

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A.

Good morning.

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Q.

My name is Alan Whitehurst, and I will be

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taking your deposition today.

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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.

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Have you testified in a deposition before?

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A.

I have.

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Q.

How many times?

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A.

Once.

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Q.

And what case was that for?

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A.

It was a -- a case involving Motorola.

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Q.

Was that for a litigation between Motorola

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and Apple?

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A.

I believe so.

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Q.

And when was that deposition?
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R
E
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A
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Q.

patent, for example, Figure 7.

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If you would look at the figures in this

Is Figure 7 a picture of the user interface
for Mac OS X?

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A.

It's a drawing that looks like it could be.

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Q.

And would the user interface in Mac OS X

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look like Figure 7?
A.

I don't know what this is trying to be, but

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there are elements of it that look like Mac OS X for

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sure.

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Q.

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Can you turn to Figure 8, please.
What is Figure 8?

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I understand Figure 8 to be an indicator of

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battery level over the window that we were just

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looking at.

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Q.

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indicator?

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A.

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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?

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A.

It does not look like Figure 8.

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Q.

What does the battery level indicator look
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CERTIFICATE

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STATE OF CALIFORNIA )
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)
COUNTY OF SONOMA

:

ss

)

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I, Lorrie L. Marchant, a Certified Shorthand

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Reporter, a Registered Professional Reporter, a

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Certified Realtime Reporter, and a Certified

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Realtime Professional within and for the State of

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California, do hereby certify:

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That IMRAN CHAUDHRI, the witness whose

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deposition is herein set forth, was duly

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sworn/affirmed by me and that such deposition is a

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true record of the testimony given by such witness.

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I further certify that I am not related to any

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of the parties to this action by blood or marriage

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and that I am in no way interested in the outcome of

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this matter.

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In witness whereof, I have hereunto set my hand
this 15th day of October, 2011.

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--------------------------------------------LORRIE L. MARCHANT, CSR, RPR, CRR, CLR, CCRR

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CSR No. 10523

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