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)

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EXHIBIT P Apple v. Samsung Confidential – Attorneys’ Eyes Only 1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 SAN JOSE DIVISION 11 12 APPLE INC., a California corporation, 13 14 15 16 17 18 19 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. 20 21 22 **CONFIDENTIAL – CONTAINS MATERIAL DESIGNATED AS HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY PURSUANT TO A PROTECTIVE ORDER** 23 24 25 26 27 28 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 1 of Bas Ording, the named inventor of the ’381 patent, as well as certain exhibits marked during 2 that deposition. In addition, I reviewed portions of the deposition transcripts of Wookyun Koh 3 and Seung Yun Lee, as well as certain exhibits marked during those depositions. 4 16. I have also reviewed Samsung’s responses to Apple Interrogatories Nos. 2 5 (regarding Samsung’s non-infringement contentions), 16 (regarding Samsung’s design-around 6 contentions), and 79 (regarding Samsung’s basis for any contention that Apple does not practice 7 Apple’s patents). 8 17. I have examined the following Samsung products: the Captivate; Continuum; 9 Droid Charge; Epic 4G; Exhibit 4G; Fascinate; Galaxy Ace; Galaxy Prevail; Galaxy S (i9000); 10 Galaxy S 4G; Galaxy S II (including its i9100, AT&T, and Epic 4G Touch variants); Galaxy S 11 Showcase (i500); Galaxy Tab 7.0; Galaxy Tab 10.11; Gem; Gravity Smart; Indulge; Infuse 4G; 12 Intercept; Mesmerize; Nexus S; Nexus S 4G; Replenish; Sidekick; and Vibrant. 13 18. In addition, I have reviewed technical specifications for the aforementioned 14 devices from Samsung’s website. These portions of Samsung’s website, which generally identify 15 information such as the type of display on the device, the version of the Android platform on the 16 device, and a device’s memory capacity, were printed and labeled with the following Bates 17 numbers: APLNDC-Y0000066729 – 66827; and APLNDC-Y0000066830 – 66909. I have also 18 reviewed portions of the user manuals for these devices. The manuals were printed and labeled 19 with the following Bates numbers: APLNDC-Y0000056289 – 56566; APLNDC-Y0000056784 – 20 66728. 21 19. I have also reviewed portions of the publicly available Android source code and 22 related documentation available at the Android developers website located at the following URL: 23 http://developer.android.com/index.html, as well as portions of the Samsung proprietary source 24 code that were produced by Samsung in this litigation prior to the close of fact discovery on 25 March 8, 2012. I have been informed that although Apple requested a production of all of the 26 Samsung source code for all of the Samsung products accused of infringement and that Samsung 27 1 28 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 5 Apple v. Samsung Confidential – Attorneys’ Eyes Only 1 2 AA. Supplementation 3 267. I reserve the right to supplement this report with new information and/or 4 documents that may be discovered or produced in this case, or to address any new claim 5 constructions offered by Samsung or ordered by the Court. 6 268. In connection with my anticipated testimony in this action, I may use as exhibits 7 various documents produced in this case that refer or relate to the matters discussed in this 8 report. In addition, I may have demonstrative exhibits prepared to assist in the presentation of my 9 testimony and opinions as set forth or cited in my report. 10 11 12 Dated: March 22, 2012 RAVIN BALAKRISHNAN 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 EXPERT REPORT OF RAVIN BALAKRISHNAN, PH.D. REGARDING INFRINGEMENT OF THE ‘381 PATENT Case No. 11-cv-01846-LHK 61

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