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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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 3 1 APPEARANCES 2 3 Appearing on behalf of the Plaintiff and the 4 witness: 5 KARL J. KRAMER, ESQ. 6 Morrison & Foerster 7 755 Page Mill Road 8 Palo Alto, California 94304 9 10 11 12 13 Appearing on behalf of the Defendants: 14 TODD M. BRIGGS, ESQ. 15 Quinn Emanuel Urquhart & Sullivan 16 555 Twin Dolphin Drive 17 Redwood Shores, California 94065 18 19 20 21 22 ALSO PRESENT: Steve Brown, Videographer 23 24 25 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 161 1 Q. So if I were to ask you if you had an 2 opinion as to whether any of Samsung's products 3 infringed any of the claims of the 002 patent, would 4 you have an opinion? 5 A. I have no opinion. 6 Q. And you have never done any sort of 7 analysis to determine whether any Samsung products 8 meet the claims of the 002 patent? 9 A. No. 10 (Exhibit 984 was marked for identification) 11 BY MR. BRIGGS: 12 13 Q. as Exhibit 984. 14 15 MR. KRAMER: one. 18 19 I don't have a copy of that If you could hand me that, that would be great. 16 17 I am going to hand you what has been marked Thanks, Todd. BY MR. BRIGGS: Q. Can you review this document and let me know when you are done. 20 A. I have. 21 Q. So you are familiar with this document? 22 A. I am. 23 Q. What is it? 24 A. It is the "read me" file that accompanied 25 Super Clock. 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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