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

Filing 974

Declaration of Cyndi Wheeler in Support of #934 Administrative Motion to File Under Seal Re Samsungs Motion To Strike Expert Testimony 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 Declaration Of Mark D. Selwyn In Support Of Samsungs Administrative Motion To File Documents Under Seal Re Samsungs Motion To Strike Expert Testimony, #14 Selwyn Decl. Ex. 1, #15 Selwyn Decl. Ex. 2, #16 Proposed Order [Proposed] Order Granting Samsungs Administrative Motion To File Documents Under Seal Re Samsungs Motion To Strike Expert Testimony)(Related document(s) #934 ) (Bartlett, Jason) (Filed on 5/24/2012)

Exhibit 3

EXHIBIT K
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, )CASE NO.

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VS.

)11-CV-01846LHK

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SAMSUNG ELECTRONICS CO., LTD., a Korean)

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business entity; SAMSUNG ELECTRONICS

)

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AMERICA, INC., a New York corporation; )

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SAMSUNG TELECOMMUNICATIONS AMERICA,

)

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LLC, a Delaware limited liability

)

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company,

)

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DEFENDANTS. )

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_______________________________________)

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DEPOSITION OF SANJAY SOOD, Ph.D.

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LOS ANGELES, CALIFORNIA

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FRIDAY, APRIL 20, 2012

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REPORTED BY:

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CHRISTY CANNARIATO, CSR #7954, RPR, CRR

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JOB NO.: 48726
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very important in terms of formulating a survey?
A.

Definitely.

That's what I struggle with

all the time when I'm designing surveys.
Q.

So can you turn to page 36202.

Do you see

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that this slide is basically looking at the issue of

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overall satisfaction with iPhone?

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A.

Yes.

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Q.

And you see the US part there.

02:05

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There are

percentages ranging from 86 percent to 94 percent?

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A.

Yes.

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Q.

Would you consider that a high level of

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02:05

satisfaction?

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A.

Yes.

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Q.

And we agreed that consumers think that

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the functionalities that we talked about earlier, the

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web browsing and checking one's e-mail, that those

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functions are important to consumers.

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A.

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Absolutely.
MR. PLUNKETT:

Mischaracterizes.
A.

02:06

Objection.

Vague?

02:06

I think that people make decisions based

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on multiple components of the product.

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features are going to be important.

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to be important.

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Carrier is going to be important.

So functional

Design is going

Price is going to be important.

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Q.

You can see why I'm curious about those

questionnaires.

02:28

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A.

Yes.

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Q.

So any luck in getting the questionnaires?

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A.

Not yet.

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MR. PLUNKETT:

So I will just note that

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counsel had the opportunity ask for the questionnaires

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before this deposition.

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today that you had questions about the questionnaires

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and that they weren't there.

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02:28

Presumably you knew before

MS. HUTNYAN:

Right?

Well, presumably you knew in

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furnishing Dr. Sood's report the dictates of Rule 26

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which require all the bases and conclusions to be

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included with the report.

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catch you and identify the things that are missing

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before I've gotten a chance to depose Dr. Sood really

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isn't a very good answer to the question.

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MR. PLUNKETT:

02:29

So that I'm supposed to

02:29

Counsel, you can meet and

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confer before a deposition if there's documents that

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you need and don't have.

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responsibility today, and you've made several comments

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on the record about it, to have brought those with

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him.

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meet and confer on it prior to this deposition, and

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you had the opportunity to.

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making.

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So it's not the witness's

It's an issue between counsel.

MS. HUTNYAN:

02:29

And you did not

That's the point I'm

I have never once said

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02:29