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 1 IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION 2 3 4 APPLE, INC., Corporation, a California 5 Case No.: 11-cv-01846-LHK Plaintiff, 6 vs. 7 8 9 10 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, 11 12 13 14 Defendants. ________________________________ UNITED STATES INTERNATIONAL TRADE COMMISSION WASHINGTON, D.C. ________________________________ In the Matter of: 15 16 17 CERTAIN PORTABLE ELECTRONIC Investigation DEVICES AND RELATED SOFTWARE No. 337-TA-797 ________________________________ -o0o- 18 **CONFIDENTIAL - ATTORNEYS' EYES ONLY** 19 VIDEOTAPED DEPOSITION OF RICHARD WOOLLEY 20 Taken on behalf of the Defendants 21 DATE TAKEN: Thursday, January 19, 2012 TIME: PLACE: 9:36 a.m. - 4:00 p.m. MORRISS, O'BRYANT, COMPAGNI ATTORNEYS AT LAW 724 East 200 South Salt Lake City, Utah 84102 22 23 24 25 TSG Reporting - Worldwide (877)702-9580 Confidential Attorneys' Eyes Only Page 2 1 2 3 Stenographically Reported by: Susan Hellberg-Young Registered Professional Reporter #16196 Certified Shorthand Reporter (Utah) #191 JOB NO: 45336 4 5 6 APPEARANCES: 7 8 9 10 11 12 13 14 Counsel for Apple, Inc.: MATTHEW I. KREEGER Morrison & Forester, LLC 425 Market Street San Francisco, California 94105-2482 mkreeger@mofo.com MARK BELLOLI Feinberg, Day, Alberti & Thompson Attorneys at Law 401 Florence Street, Suite 200 Palo Alto, California 94301 mbelloli@fienday.com 15 16 Counsel for Samsung and HTC Corporation: 17 18 19 20 21 22 23 CHARLES A. BASINGER Quinn Emanuel Urquhart & Sullivan Attorneys at Law 1299 Pennsylvania Avenue N.W., Suite 825 Washington, D.C. 20004 charlesbasinger@quinnemanuel.com JARED W. NEWTON Quinn Emanuel Urquhart & Sullivan Attorneys at Law 1299 Pennsylvania Avenue N.W., Suite 825 Washington, D.C. 20004 jarednewton@quinnemanuel.com 24 25 TSG Reporting - Worldwide (877)702-9580 Confidential Attorneys' Eyes Only Page 3 1 2 3 4 5 APPEARANCES (continued) Counsel for Cirque Corporation and ALPS Electric DAVID O'BRYANT MORRISS, O'BRYANT & COMPAGNI Attorneys at Law 724 East 200 South Salt Lake City, Utah 84102 obryant@utahpatents.com 6 7 8 9 10 JEFF BOYCE GENERAL COUNSEL ALPS ELECTRIC, NORTH AMERICA, INC. 2463 South 3850 West Suite A Salt Lake City, Utah 84120-2916 jeff.boyce@alps.com 11 12 Also Present: 13 14 15 16 Marc Gatzambide - videographer TSG Reporting, Inc. 747 Third Avenue New York, NY 10017 www.tsgreporting.com 17 18 19 20 21 22 23 24 25 TSG Reporting - Worldwide (877)702-9580 Confidential Attorneys' Eyes Only Page 6 9:00 1 January 19, 2012 a.m. 2 3 P R O C E E D I N G S 4 5 THE VIDEOGRAPHER: We are on the 6 record. 7 1 in the video deposition of Richard Woolley in 8 the matter of Apple, Incorporated versus Samsung 9 Electronics Company, Limited, Samsung Electronics This is the start of tape labeled number 10 America, Incorporated, Telecommunications 11 America, LLC, number, dash, 11-CV-01846-CH -- or 12 LHK, excuse me. 13 International Trade Commission, Washington, D.C. 14 in the matter of Certain Portable Electronic 15 Devices and Related Software, number 337-TA-797. Also, in the United States 16 This deposition is being held at 734 17 East 200 South, Salt Lake City, Utah on January 18 19th, 2012 at approximately 9:36. 19 My name is Marc Gatzambide. I'm the 20 legal video specialist from TSG Reporting, 21 Incorporated, headquartered at 747 3rd Avenue, 22 New York, New York. 23 The court reporter is Susan 24 Hellberg-Young in association with TSG Reporting. 25 Will counsel please introduce TSG Reporting - Worldwide (877)702-9580 Confidential Attorneys' Eyes Only Page 7 1 yourself after which the court reporter will 2 please swear in the witness. 3 4 5 6 7 8 9 MR. NEWTON: Jared Newton from Quinn Emanuel on behalf of HTC. MR. BASINGER: Charles Basinger, also Quinn Emanuel, on behalf of the Samsung entities. MR. KREEGER: Matthew Kreeger of Morrison and Foerster, representing Apple. MR. BELLOLI: Marc Belloli from 10 Feinberg Day representing Apple in the 797 11 investigation. 12 13 14 MR. O'BRYANT: David O'Bryant representing Cirque Corporation. MR. WOOLLEY: Richard Woolley 15 representing Cirque Corporation, of Cirque 16 Corporation. 17 18 RICHARD DOUGLAS WOOLLEY, 19 called as a witness, having been duly sworn, 20 was examined and testified as follows: 21 22 MR. NEWTON: Before we begin, I want 23 to acknowledge on the record that the deposition 24 is being taken on behalf of HTC in the USITC 25 investigation number 337-TA-797, and on behalf of TSG Reporting - Worldwide (877)702-9580 Confidential Attorneys' Eyes Only Page 209 1 REPORTER'S DEPOSITION CERTIFICATE 2 STATE OF UTAH 3 COUNTY OF SALT LAKE 4 I, Susan Hellberg-Young, Registered 5 Professional Reporter, Certified Shorthand 6 Reporter, and Notary Public in and for the State 7 of Utah at large, hereby certify that the witness 8 appeared before me for the taking of the 9 foregoing deposition, and that I was authorized 10 to and did stenographically and electronically 11 report the deposition, and that the transcript is 12 a true and complete record of my stenographic 13 notes and recordings thereof. 14 15 I FURTHER CERTIFY that I am neither 16 an attorney, nor counsel for the parties to this 17 cause, nor a relative or employee or any attorney 18 or party connected with this litigation, nor am I 19 financially interested in the outcome of this 20 action. 21 DATED THIS 19th day of January, 2012, 22 at Salt Lake City, Utah. 23 ____________________________ 24 SUSAN HELLBERG-YOUNG, RPR, CSR 25 TSG Reporting - Worldwide (877)702-9580

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