Google Inc. v. Rockstar Consortium US LP et al

Filing 31

Declaration of Kristin J. Madigan in Support of 30 Google Inc.'s Opposition to Defendants' Motion to Dismiss or Transfer filed byGoogle 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 Exhibit 18, # 19 Exhibit 19 - Part 1 of 3, # 20 Exhibit 19 - Part 2 of 3, # 21 Exhibit 19 - Part 3 of 3, # 22 Exhibit 20, # 23 Exhibit 21 - Part 1 of 2, # 24 Exhibit 21 - Part 2 of 2, # 25 Exhibit 22, # 26 Exhibit 23, # 27 Exhibit 24, # 28 Exhibit 25, # 29 Exhibit 26, # 30 Exhibit 27, # 31 Exhibit 28, # 32 Exhibit 29, # 33 Exhibit 30, # 34 Exhibit 31, # 35 Exhibit 32, # 36 Exhibit 33, # 37 Exhibit 34, # 38 Exhibit 35, # 39 Exhibit 36, # 40 Exhibit 37)(Related document(s) 30 ) (Warren, Matthew) (Filed on 2/7/2014) Modified on 2/10/2014 (cpS, COURT STAFF).

EXHIBIT 31

SMVE JOBS

WALT ER
ISAACSON
SIMON & SCHUSTER
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512

WALTER ISAACSON

Jobs had tried to dissuade Google from developing Android.
He had gone to Google's headquarters near Palo Alto in 2008 and
gotten into a shouting match with Page, Brin, and the head of the
Android development team, Andy Rubin. (Because Schmidt was
then on the Apple boarcl, he recused himself from discussions involving the iPhone.) "I said we would, if we had good relations, guarantee
Google access to the iPhone and guarantee it one or two icons on
the home screen," he recalled. But he also threatened that if Google
continued to develop Android and used any iPhone features, such as
multi-touch, he would sue. At first Google avoided copying certain
features, but in January 2010 HTC introduced an Android phone that
boasted multi-touch and many other aspects of the iPhone's look and
feel. That was the context for Jobs's pronouncement that Google's
"Don't be evil" slogan was "bullshit."
So Apple filed suit against HTC (and, by extension, Android),
alleging infringement of twenty of its patents. Among them were
patents covering various multi-touch gestures, swipe to open, doubletap to zoom, pinch and expand, and the sensors that determined how
a device was being held. As he sat in his house in Palo Alto the week
the lawsuit was filed, he became angrier than I had ever seen him:
Our lawsuit is saying, "Google, you fucking ripped off the iPhone,
wholesale ripped us off." Grand theft. I will spend my last dying breath
if I need to, and I will spend every penny of Apple's $40 billion in the
bank, to right this wrong. I'm going to destroy Android, because it's a
stolen product. I'm willing to go to thermonuclear war on this. They are
scared to death, because they know they are guilty. Outside of Search,
Google's products—Android, Google Docs—are shit.

A few days after this rant, Jobs got a call from Schmidt, who had
resigned from the Apple board the previous summer. He suggested
they get together for coffee, and they met at a café in a Palo Alto shopping center. "We spent half the time talking about personal matters,
then half the time on his perception that Google had stolen Apple's
user interface designs," recalled Schmidt. When it came to the latter subject, Jobs did most of the talking. Google had ripped him og

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