Mirror Worlds, LLC v. Apple, Inc.

Filing 160

CLAIM CONSTRUCTION RESPONSE BRIEF re: 151 Mirror Worlds' Claim Construction Brief, filed by Apple Inc. (Attachments: # 1 Decl. of Stefani C. Smith ISO Apple's Brief, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, # 10 Exhibit I, # 11 Exhibit J, # 12 Exhibit K, # 13 Exhibit L)(Smith, Stefani) Modified on 1/11/2010 (mll, ).

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Mirror Worlds, LLC v. Apple, Inc. Doc. 160 Att. 13 DAVID GELERNTER June 18, 2009 Page 1 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK ----------------------------) MIRROR WORLDS, LLC ) Plaintiff ) Civil Action No. VS ) 6:08-CV-88 (LED) ) APPLE, INC. ) Defendant ) ----------------------------) DEPOSITION OF: DAVID GELERNTER DATE: JUNE 18, 2009 HELD AT: OMNI HOTEL 155 TEMPLE STREET NEW HAVEN, CONNECTICUT Reporter: WENDY J. ALLEN, RPR, CRR, LSR #00221 Merrill Legal Solutions (800) 869-9132 Dockets.Justia.com DAVID GELERNTER June 18, 2009 Page 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 APPEARANCES: REPRESENTING THE PLAINTIFF: RICHARD NA, ESQ. KENNETH STEIN, ESQ. STROOCK & STROOCK & LAVAN 180 Maiden Lane New York, NY 10038-4982 Tel 212-806-5400 Fax 212-806-6006 ran@stroock.com REPRESENTING THE DEFENDANT: STEVEN CHERENSKY, ESQ. SONAL MEHTA, ESQ. LISA MARIE SCHULL, ESQ. WEIL, GOTSHAL & MANAGES 201 Redwood Shores Parkway Redwood Shores, CA 94065 Tel 650-802-3126 Fax 650-802-3100 steven.cherensky@weil.com Merrill Legal Solutions (800) 869-9132 DAVID GELERNTER June 18, 2009 Page 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I WITNESS: N D E X PAGE: David Gelernter Direct Examination by Mr. Cherensky 6 ______________________________________________________ EXHIBITS: Exhibit 1, US Patent 6,006,227 Exhibit 2, US Patent 6,638,313 B1 Exhibit 3, US Patent 6,725,427 B2 Exhibit 4, US Patent 6,768,999 B2 Exhibit 5, Washington Post article Exhibit 6, April 1995 Yale technical report Exhibit 7, August 1995 Yale technical report Exhibit 8, dissertation Exhibit 9, April 1995 Yale technical report Exhibit 10, grant request Exhibit 11, thesis by Nancy Silver Exhibit 12, file history Exhibit 13, paper authored by Scott Fertig, Eric Freeman and David Gelernter Exhibit 14, paper authored by Richard Mander, Gitta Salomon and Yin Yin Wong Exhibit 15, subpoena Exhibit 16, CoverFlow display screen shot Exhibit 17, email stream from 11/23/08 Exhibit 18, statement of David Gelernter to US Patent and Trademark Office Exhibit 19, patent purchase agreement ______________________________________________________ Merrill Legal Solutions (800) 869-9132 DAVID GELERNTER June 18, 2009 Page 32 1 2 3 09:02 4 5 6 7 8 09:02 9 10 11 12 13 09:02 14 15 16 17 18 09:03 19 20 21 22 23 09:03 24 25 the 999 patent? A Q A No. Why not? It deals with a topic and proposes a technology which is not my topic and not my imagine. Q And what do you consider to be the topic of the 999 patent? A Well, insofar as I didn't write the patent and wasn't involved in the work that went up to it, I can't say a lot about it, but it deals with information management in a so-called enterprise environment or enterprise computing environment. Q What do you understand an enterprise computing environment to be? A hold. It's an environment in which several things Information services are provided by server client models, because two important aspects of the enterprise, as I understand it. I really think that more of it is a commercial term than technical term, although it has technical implications. A large number of users may be involved, therefore issues of efficiently storing, indexing, searching, maybe I should say very large numbers of documents become important, and it is a dynamic environment in the sense that I don't know beforehand, I can't say Merrill Legal Solutions (800) 869-9132 DAVID GELERNTER June 18, 2009 Page 33 1 2 3 09:04 4 5 6 7 8 09:04 9 10 11 12 13 09:04 14 15 16 17 18 09:04 19 20 21 22 23 09:05 24 25 statistically how many computers are encompassed, how many users there are, what types of computers, computer sets in the door at any time. Q Now, you've said in that answer that you didn't, or maybe the previous answer, you didn't write the 999 patent. Did you write the specification for the other three patents, Exhibits 1 through 3? MR. AN: Objection to form. I did not write but was THE WITNESS: involved in the process. MR. AN: Before you continue, without gettin

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