Apple Inc. v. Samsung Electronics Co. Ltd. et al

Filing 973

Declaration of Cyndi Wheeler in Support of #930 Administrative Motion to File Under Seal Samsung's Motion for Summary Judgment filed byApple Inc.. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8, #9 Exhibit 9, #10 Exhibit 10, #11 Exhibit 11, #12 Exhibit 12, #13 Exhibit 13, #14 Exhibit 14, #15 Exhibit 15, #16 Exhibit 16, #17 Exhibit 17, #18 Declaration Of Mark D. Selwyn In Support Of Samsungs Administrative Motion To File Documents Under Seal Re Samsungs Motion For Summary Judgment, #19 Proposed Order [Proposed] Order Granting Samsungs Administrative Motion To File Documents Under Seal Re Samsungs Motion For Summary Judgment)(Related document(s) #930 ) (Bartlett, Jason) (Filed on 5/24/2012)

Exhibit 17

EXHIBIT 11
FILED UNDER SEAL

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION

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APPLE INC., a California
corporation,

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Plaintiff,
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vs.

CASE NO.

11 cv 01846 LHK

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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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H I G H L Y
C O N F I D E N T I A L
A T T O R N E Y S' E Y E S O N L Y

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VIDEOTAPED DEPOSITION OF RICHARD WILLIAMSON
REDWOOD SHORES, CALIFORNIA
FRIDAY, OCTOBER 28, 2011

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BY: ANDREA M. IGNACIO HOWARD, CSR, RPR, CCRR, CLR
CSR LICENSE NO. 9830
JOB NO. 42876
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Q

Do you have an engineering

do you have any

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independent knowledge of what a structured electronic

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document is?

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A

Yes.
MR. BARQUIST:

Objection; vague and

ambiguous; calls for a legal conclusion.
THE WITNESS:
language.

I will not interpret the legal

I can tell you about the engineering work.

MR. MACK:

Okay.

I'm not asking for the

legal interpretation.

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Q

Okay.

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A

A structured document is something that has a

And what is a structured document?

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visual structure with structurally interesting

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components.

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structured document, whether it be a .pdf document

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with an imposed structure or whether it be a web page

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with a structure or an .rtf document.

And there are many examples of a

So a structured

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document is something that, you know, a normal human

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can look at and identify areas of interest.

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Q

Okay.

So would it be safe to say a

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structured document has some sort of layout associated

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with it; is that fair?

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MR. BARQUIST:

Objection; vague and

ambiguous.

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THE WITNESS:

I'm not sure.

I mean, that's

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different than the definition I just gave you.

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you know, I think of a structured document more in

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terms of its visual appearance and having visually

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interesting elements that you can zoom in to.

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MR. MACK:
Q

So,

Okay.

So would a

would a plain text document be

a structured document?
MR. BARQUIST:

Objection; incomplete

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hypothetical; calls for a legal conclusion.

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THE WITNESS:

To the extent that that's a

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you know, trying to impose a legal question to me, I'm

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not sure I'm qualified to answer that.

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MR. MACK:

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legal definition.

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Q

Like, would you consider a text document a

structured document from the definition you just gave?

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MR. BARQUIST:

Objection; vague and

ambiguous; incomplete hypothetical.

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Yeah, but I'm not asking for the

THE WITNESS:

What kind of text document?

I

mean, you need to be more specific.

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MR. MACK:

Just a

you know, not a rich

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format; just a regular form

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a .txt file that you're displaying on a screen.

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Q

Would that

regular text document,

would you consider that a

structured document?

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MR. BARQUIST:

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vague and ambiguous.

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THE WITNESS:

Objection; lacks foundation;

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context.

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I mean, it all depends on the

MR. MACK:
Q

Okay.

But you gave examples of a web

you gave

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examples of some structured documents; correct?

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And you said a web page is a structured
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