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 7
EXHIBIT 45
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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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 DOUGLAS SATZGER
REDWOOD SHORES, CALIFORNIA
TUESDAY, NOVEMBER 8, 2011
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BY: ANDREA M. IGNACIO HOWARD, CSR, RPR, CCRR, CLR
CSR LICENSE NO. 9830
JOB NO. 42999
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archive storage space.
Q
So when the move occurred, some of the files
were just sent directly to an archive?
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A
Storage.
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Q
As opposed to being moved to the new
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offices --
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MR. DAVIS:
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MR. ZELLER:
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A
Foundation.
Q.
-- as you understood it?
I -- I don't know where they were moved,
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actually.
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off-site, we had in-office, and we had on-campus
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storage.
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I'm not sure if they -- we had -- we had
Q
I don't recall.
Did you ever see an index or -- or a database
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or other list of files that you had that were in
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archive?
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A
No.
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Q
If you wanted to find out, back in the time
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period when you were working at Apple, whether or not
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any of your files were in archive, is there somebody
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you would ask?
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A
No.
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Q
Do you recall the last time that you saw any
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of the loose page sketches you did?
A
My recollection is when we were on Valley
Green.
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Q
And those were the old offices before --
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A
Old office, yeah.
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MR. DAVIS:
You stepped over him a little
bit.
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THE WITNESS:
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MR. DAVIS:
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Just make sure you let him finish
his question, but you're fine.
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Oh, yeah.
MR. ZELLER:
Directing your attention back to
Exhibit 1172.
Q
Among these pages, did you see any pages that
relate to any tablet computer design?
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A
No.
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Q
I take it at some point you -- you do recall
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doing some sketches or drawings of tablet computer
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designs or potential tablet computer designs when you
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were at Apple?
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A
I -- yes.
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Q
Do you have any idea where those are?
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A
I do not.
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Q
I'm going to show you what was previously
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marked as Exhibit 8, which is a copy of United States
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Design Patent 504,889.
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you've had a chance to look at the '889 design patent.
And please let me know when
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A
Pardon me.
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Q
Do you recognize the '889 design patent as a
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patent you're a named inventor on?
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A
Yes.
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Q
Focusing on the design that's shown here in
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the '889 design patent, did you create sketches of --
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of this design?
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A
Yes.
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Q
And I take it you didn't see any of those
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sketches here in 1172?
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A
No.
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Q
Do you have any -- any idea or knowledge or
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information as to where any of the sketches that you
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prepared in connection with the '889 design patent
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design are?
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A
No.
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Q
Do you have any idea where they were as of
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the time you left Apple in 2008?
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A
No.
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Q
Do you have any knowledge or information --
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well, let me try it this way:
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time in 2008 when you left Apple, is there any place
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you can think of you would go and ask and look?
If -- if -- as of the
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A
Yes.
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Q
What -- what did you have in mind for that?
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A
I would search the in-office storage for any
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of my file boxes, and then the other on-campus storage
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MR. HUNG:
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THE WITNESS:
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MR. ZELLER:
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Do you have the 035 mockup?
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MR. HUNG:
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MR. ZELLER:
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MR. HUNG:
Objection; vague.
Yes.
All right.
No.
Okay.
I didn't actually -- we didn't
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receive an e-mail, I think, asking us to bring it to
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this depo.
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MR. ZELLER:
We've asked for it to be
available for all of the interim depositions.
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Do you have these?
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MR. HALL:
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Would you please mark as Exhibit 1173 a
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Yes.
multipage document consisting of photographs of the -TSG Reporting - Worldwide
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what people call the 035 mockup.
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(Document marked Exhibit 1173
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for identification.)
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MR. ZELLER:
Q
All right.
And so you know, what we've marked as
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Exhibit 1173 are photographs of a mockup -- an Apple
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mockup that has generally been identified as the 035
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mockup.
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A
Uh-huh, yes.
MR. HUNG:
Objection; calls for a legal
conclusion; foundation.
MR. DAVIS:
Calls for speculation.
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