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

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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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