Apple Inc. v. Samsung Electronics Co. Ltd. et al
Filing
935
Declaration in Support of #934 Administrative Motion to File Under Seal filed bySamsung Electronics America, Inc.(a New York corporation), Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC(a Delaware limited liability company). (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, #11 Exhibit K, #12 Exhibit L, #13 Exhibit M, #14 Exhibit N, #15 Exhibit O, #16 Exhibit P, #17 Exhibit Q, #18 Exhibit R, #19 Exhibit S, #20 Exhibit T, #21 Exhibit U, #22 Exhibit V, #23 Exhibit W, #24 Exhibit X)(Related document(s) #934 ) (Maroulis, Victoria) (Filed on 5/17/2012)
EXHIBIT P
Apple v. Samsung
Confidential – Attorneys’ Eyes Only
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN JOSE DIVISION
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APPLE INC., a California corporation,
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Plaintiff,
v.
Case No.
11-cv-01846-LHK
EXPERT REPORT OF RAVIN
BALAKRISHNAN, PH.D.
REGARDING INFRINGEMENT
OF U.S. PATENT NO. 7,469,381
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 – CONTAINS MATERIAL DESIGNATED AS HIGHLY
CONFIDENTIAL – ATTORNEYS’ EYES ONLY PURSUANT
TO A PROTECTIVE ORDER**
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EXPERT REPORT OF RAVIN BALAKRISHNAN, PH.D. REGARDING INFRINGEMENT OF THE ‘381 PATENT
Case No. 11-cv-01846-LHK
Apple v. Samsung
Confidential – Attorneys’ Eyes Only
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of Bas Ording, the named inventor of the ’381 patent, as well as certain exhibits marked during
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that deposition. In addition, I reviewed portions of the deposition transcripts of Wookyun Koh
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and Seung Yun Lee, as well as certain exhibits marked during those depositions.
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16.
I have also reviewed Samsung’s responses to Apple Interrogatories Nos. 2
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(regarding Samsung’s non-infringement contentions), 16 (regarding Samsung’s design-around
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contentions), and 79 (regarding Samsung’s basis for any contention that Apple does not practice
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Apple’s patents).
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I have examined the following Samsung products: the Captivate; Continuum;
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Droid Charge; Epic 4G; Exhibit 4G; Fascinate; Galaxy Ace; Galaxy Prevail; Galaxy S (i9000);
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Galaxy S 4G; Galaxy S II (including its i9100, AT&T, and Epic 4G Touch variants); Galaxy S
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Showcase (i500); Galaxy Tab 7.0; Galaxy Tab 10.11; Gem; Gravity Smart; Indulge; Infuse 4G;
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Intercept; Mesmerize; Nexus S; Nexus S 4G; Replenish; Sidekick; and Vibrant.
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In addition, I have reviewed technical specifications for the aforementioned
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devices from Samsung’s website. These portions of Samsung’s website, which generally identify
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information such as the type of display on the device, the version of the Android platform on the
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device, and a device’s memory capacity, were printed and labeled with the following Bates
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numbers: APLNDC-Y0000066729 – 66827; and APLNDC-Y0000066830 – 66909. I have also
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reviewed portions of the user manuals for these devices. The manuals were printed and labeled
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with the following Bates numbers: APLNDC-Y0000056289 – 56566; APLNDC-Y0000056784 –
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66728.
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I have also reviewed portions of the publicly available Android source code and
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related documentation available at the Android developers website located at the following URL:
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http://developer.android.com/index.html, as well as portions of the Samsung proprietary source
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code that were produced by Samsung in this litigation prior to the close of fact discovery on
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March 8, 2012. I have been informed that although Apple requested a production of all of the
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Samsung source code for all of the Samsung products accused of infringement and that Samsung
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References to the “Galaxy Tab 10.1” include both the wifi and LTE variants.
EXPERT REPORT OF RAVIN BALAKRISHNAN, PH.D. REGARDING INFRINGEMENT OF THE ‘381 PATENT
Case No. 11-cv-01846-LHK
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Apple v. Samsung
Confidential – Attorneys’ Eyes Only
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AA.
Supplementation
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267.
I reserve the right to supplement this report with new information and/or
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documents that may be discovered or produced in this case, or to address any new claim
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constructions offered by Samsung or ordered by the Court.
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268.
In connection with my anticipated testimony in this action, I may use as exhibits
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various documents produced in this case that refer or relate to the matters discussed in this
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report. In addition, I may have demonstrative exhibits prepared to assist in the presentation of my
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testimony and opinions as set forth or cited in my report.
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Dated: March 22, 2012
RAVIN BALAKRISHNAN
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EXPERT REPORT OF RAVIN BALAKRISHNAN, PH.D. REGARDING INFRINGEMENT OF THE ‘381 PATENT
Case No. 11-cv-01846-LHK
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