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 2

EXHIBIT 38

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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,

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vs.

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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,

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Case No. 11-CV-01846-LHK

Defendants.
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VIDEOTAPED DEPOSITION OF DANIELE De IULIIS
Redwood Shores, California
Friday, October 21, 2011

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Reported by:
LORRIE L. MARCHANT, CSR No. 10523, RPR, CRR, CCRR,CLR
JOB NO. 43000

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TSG Reporting 877-702-9580

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Q.

Did you work on the design of this tablet?

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A.

I worked alongside my colleagues in the

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industrial design department as a collective and as

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a team on this.

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MR. MONACH:

Objection.

Vague.

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Q.

You've been handed what has been marked as

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Exhibit 8, Lutton Exhibit 8.

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Do you have that in

front of you?

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A.

Yes.

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Q.

Do you -- and that is US Design Patent

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504889 --

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A.

Yes.

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Q.

-- correct?

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You're named as an inventor of this design;
is that correct?

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A.

Yes.

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Q.

Did you participate in the team that

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8

created this design?
A.

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I did.

BY MS. CARUSO:

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Q.

Do you see Figure 6 of the D889 patent?

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A.

I do.

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Q.

There's a circular element on that.

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Do you

see it?

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A.

I do.

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Q.

In Figure 1 of the D889 patent, there's

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a -- a line that's thicker than the other lines.

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Do

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you see that?

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MR. MONACH:

Objection.

Vague.

Objection

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to the extent it may not accurately reflect the

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drawing.

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THE WITNESS:

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BY MS. CARUSO:

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Q.

I see a bad photocopy.

Starting at the left, do you see three

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parallel lines on the left-hand side of the top

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drawing?

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A.

I do.

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Q.

Do you see the middle line of those three?

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A.

I do.

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Q.

Does it appear to you to be thicker than

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the other two?

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A.

Yes.

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Q.

Do you have an understanding of why it's

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thicker?

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MR. MONACH:

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foundation.

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Objection.

Lack of

Objection to the extent it calls for a

legal conclusion.

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THE WITNESS:

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BY MS. CARUSO:

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Q.

I don't.

Do you have any understanding of what that

middle line represents?
MR. MONACH:

Same objection.

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THE WITNESS:

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What was your

question.

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One more time.

BY MS. CARUSO:
Q.

Do you have any understanding of what that

middle line represents?
A.

No.

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Q.

If you'd look at this --

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A.

Thank you.

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Q.

-- and if you could just hold that up again

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for the camera.
THE VIDEOGRAPHER:
the front.

I didn't get a shot of

You have to hold it longer for me.

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Thank you.

Great.

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BY MS. CARUSO:

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