exhibit 1 - A Case study in patent litigation: apple v. samsung ...

Apple Inc. v. Samsung Electronics Co. Ltd. et al, Docket No. 5:11-cv-01846 (N.D. Cal. Apr 15, 2011), Court Docket 

Part Description 

1 23 pages 

2 Declaration of Joby Martin 

3 Exhibit 1 

4 Exhibit 2 

5 Exhibit 3 

6 Exhibit 4 

7 Exhibit 5 

8 Exhibit 6 

9 Exhibit 7 

10 Exhibit 8 

11 Exhibit 9 

12 Exhibit 10 

13 Exhibit 11 

14 Exhibit 12 

15 Exhibit 13 

16 Exhibit 14 

17 Exhibit 15 

18 Exhibit 16 

19 Exhibit 17 

20 Exhibit 18 

Multiple Documents 

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Document Link: http://www.bloomberglaw.com/ms/document/X1Q6LJBLEO82?documentName=1337.xml

Case5:11-cv-01846-LHK Document1322 Filed07/25/12 Page1 of 23 

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QUINN EMANUEL URQUHART & SULLIVAN, LLP 

Charles K. Verhoeven (Cal. Bar No. 170151) 

charlesverhoeven@quinnemanuel.com 

50 California Street, 22 nd Floor 

San Francisco, California 94111 

Telephone: (415) 875-6600 

Facsimile: (415) 875-6700 

Kevin P.B. Johnson (Cal. Bar No. 177129) 

kevinjohnson@quinnemanuel.com 

Victoria F. Maroulis (Cal. Bar No. 202603) 

victoriamaroulis@quinnemanuel.com 

555 Twin Dolphin Drive 5 th Floor 

Redwood Shores, California 94065 

Telephone: (650) 801-5000 

Facsimile: (650) 801-5100 

Michael T. Zeller (Cal. Bar No. 196417) 

michaelzeller@quinnemanuel.com 

865 S. Figueroa St., 10th Floor 

Los Angeles, California 90017 

Telephone: (213) 443-3000 

Facsimile: (213) 443-3100 

Attorneys for SAMSUNG ELECTRONICS 

CO., LTD., SAMSUNG ELECTRONICS 

AMERICA, INC. and SAMSUNG 

TELECOMMUNICATIONS AMERICA, LLC 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION 

 

APPLE INC., a California corporation, 

CASE NO. 11-cv-01846-LHK 

 

 

vs. 

Plaintiff, 

SAMSUNG’S TRIAL BRIEF 

 

 

 

 

 

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. 

 

 

 

 

02198.51855/4869164.9 Case No. 11-cv-01846-LHK 

SAMSUNG’S TRIAL BRIEF


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I. INTRODUCTION 

In this lawsuit, Apple seeks to stifle legitimate competition and limit consumer choice to 

maintain its historically exorbitant profits. Android phones manufactured by Samsung and other 

companies – all of which Apple has also serially sued in numerous forums worldwide -- offer 

consumers a more flexible, open operating system with greater product choices at a variety of 

price points as an alternative to Apple‘s single, expensive and closed-system devices. 

That Samsung is able to offer such a wide variety of quality mobile telecommunications 

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devices is no coincidence. 

Samsung has been researching and developing mobile 

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telecommunications technology since at least as early as 1991 and invented much of the 

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technology for today‘s smartphones. 

Indeed, Apple, which sold its first iPhone nearly twenty 

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years after Samsung started developing mobile phone technology, could not have sold a single 

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iPhone without the benefit of Samsung‘s patented technology. 

Even as Apple has carried out a 

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coordinated campaign of dragging Samsung‘s name through the mud in this lawsuit and in the 

media, it has used Samsung‘s patented technology while flatly refusing to pay for its use. 

For good measure, Apple seeks to exclude Samsung from the market, based on its 

complaints that Samsung has used the very same public domain design concepts that Apple 

borrowed from other competitors, including Sony, to develop the iPhone. Apple‘s own internal 

documents show this. In February 2006, before the claimed iPhone design was conceived of, 

Apple executive Tony Fadell circulated a news article that contained an interview of a Sony 

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designer to Steve Jobs, Jonathan Ive and others. 

In the article, the Sony designer discussed Sony 

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portable electronic device designs that lacked ―excessive ornamentation‖ such as buttons, fit in the 

hand, were ―square with a screen‖ and had ―corners [which] have been rounded out.‖ Ex. 18 

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(DX 649). 1 

Immediately after this article was circulated internally, Apple industrial designer 

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Shin Nishibori was directed to prepare a ―Sony-like‖ design for an Apple phone and had CAD 

drawings and a three-dimensional model prepared. See Exs. 1-2 (DX 623; DX 562). 

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All citations to ―Ex.‖ refer to exhibits attached to the Declaration of Joby Martin, filed 

concurrently herewith. 

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Eliminating any doubt about the origin of the design‘s inspiration, Apple‘s internal CAD drawings 

had the ―Sony‖ name prominently emblazoned on the phone design. Id. Only days later, Apple 

designer Richard Howarth reported that, in contrast to another internal design that was then under 

consideration, Mr. Nishibori‘s ―Sony-style‖ design was ―a much smaller-looking product with a 

much nicer shape to have next to your ear and in your pocket‖ and had greater ―size and 

shape/comfort benefits.‖ Ex. 3 (DX 562). As Mr. Nishibori has confirmed, his ―Sony-style‖ 

design changed the direction of the project that yielded the final iPhone designs. 

Contrary to the image it has cultivated in the popular press, Apple has admitted in internal 

documents that its strength is not in developing new technologies first, but in successfully 

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commercializing them. 

When Apple was developing its campaign to promote the first iPhone, it 

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considered – and rejected – advertisements that touted alleged Apple ―firsts‖ with the iPhone. As 

one Apple employee explained to an overly exuberant Apple marketer, ―I don‘t know how many 

things we can come up with that you can legitimately claim we did first. Certainly we have the 

first successful versions of many features, but that‘s different than launching something to market 

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first.‖ See Ex. 4 (DX 578). 

In this vein, the employee methodically explained that Palm, Nokia 

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and others had first invented the iPhone‘s most prominent features. 

Id. 

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Also contrary to Apple‘s accusations, Samsung does not need or want to copy; rather, it 

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strives to best the competition by developing multiple, unique products. 

Samsung internal 

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documents from 2006, well before the iPhone was announced, show rectangular phones with 

rounded corners, large displays, flat front faces, and graphic interfaces with icons with grid 

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layouts. 

Furthermore, much of what Apple complains of is the ―benchmarking‖ of competitive 

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products by Samsung. 

But this is a universal practice in the smartphone, tablet and other 

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consumer electronics markets. 

It involves doing side-by-side product comparisons of 

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competitors‘ products. 

Samsung certainly does this; so does Apple, and so does any company 

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interested in continually improving its products for the benefit of consumers. There is nothing 

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wrong with this common industry practice. 

That Apple itself zealously engages in the same type 

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of benchmarking says everything about the disingenuous nature of Apple‘s allegation that this 

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evidences ―copying.‖ 

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Apple‘s anticompetitive lawsuit should not be rewarded, and Apple should pay Samsung 

for Apple‘s use of Samsung‘s patented technology, without which Apple could not have become a 

successful participant in the mobile telecommunications industry. 

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II. 

APPLE’S COPYING ALLEGATIONS ARE BASELESS 

In order to distract from the weakness of its infringement claims, Apple offers misguided 

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allegations of copying that are refuted by evidence of Samsung‘s independent creation. Prior to 

the iPhone‘s announcement in January 2007, Samsung was already developing numerous products 

and models with the same design features that Apple now claims were copied from the iPhone. 

In the summer of 2006, Samsung began designing its next generation of mobile phones, based on 

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the market trend of ever-increasing screen size. 

At that time, Samsung‘s designers envisioned a 

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basic design: a simple, rounded rectangular body dominated by a display screen with a single 

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physical button on the face. 

See, e.g.,Exs. 5-6 (DX 522.42-45; DX 625.10). For example, 

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internal Samsung design presentations from the summer of 2006 showed the following designs 

Samsung was considering: 

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Id. One of these designs became the Samsung F700 phone, which was the subject of a Korean 

design registration application in December 2006, a month before Apple unveiled the iPhone. 

Ex. 7 (DX 519). 

Tellingly, Apple at first included Samsung‘s F700 in its indiscriminant 

―copying‖ allegations, but later withdrew its infringement charges once Samsung‘s prior, 

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independent creation left Apple no choice but to concede that its copying accusations against that 

device were false. 

Also during this time period during the Summer and Fall of 2006, Samsung designers 

envisioned a simple icon interface, with rounded rectangular icons arranged in a grid format, 

appropriately spaced for the size of the screen and the human hand. See, e.g., Ex. 8 (DX 566). 

As one example, an internal Samsung design presentation dated September 14, 2006 showed the 

following GUI layouts and adjustable orientations: 

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Id. 

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As these documents confirm, Samsung independently developed the allegedly copied 

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design features months before Apple had even announced the iPhone. 

It did not switch its design 

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direction because of the iPhone. Contrary to Apple‘s cherry-picked ―pre‖ and ―post‖ iPhone 

choices of Samsung‘s phones, Samsung designed and developed large screen smartphones before 

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the iPhone—as well as bar type phones, sliders, and folder phones. 

after the iPhone as well: 

Samsung continued to do so 

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Ex. 9 (DX 684). 

In contrast, Apple‘s supposed proof of copying consists of competitive benchmarking and 

analysis documents created by Samsung. Apple itself, however, regularly conducts the same 

types of detailed competitor analyses that it now contends proves copying. For example, Apple 

conducted tear-downs of Samsung products—such as the Vibrant, Galaxy Tab 10.1, Juke, and YP- 

R1 MP3 player—to analyze their mechanical structure, software features, chipsets, antenna and 

memory components. 

Exs. 10-13 (DX 708; DX 714; DX 715; DX 717). Apple maintains and 

regularly circulates a ―competitive tracker,‖ which keeps close tabs on competing smartphones 

and tablets, compiling data on competitors‘ processors, memory, display screen and camera 

specifications, wireless capabilities, and battery life. 

See, e.g., Exs. 14-16 (DX 709; DX 710; DX 

712). Apple also assembled an ―Android war room,‖ where its employees can study Android 

products. Ex. 17, Feb. 23, 2012 Depo. of Greg Joswiak, Tr. 118:6-11. 

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For its part, Apple‘s ―revolutionary‖ iPhone design was derived from the designs of a 

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competitor—Sony. 

In February 2006, before the claimed iPhone design was conceived of, Apple 

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executive Tony Fadell circulated a news article to Steve Jobs, Jonathan Ive and others. 

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article, a Sony designer discussed Sony designs for portable electronic devices that lacked buttons 

and other ―excessive ornamentation,‖ fit in the hand, were ―square with a screen‖ and had ―corners 

[which] have been rounded out.‖ Ex. 18 (DX 649). Right after this article was circulated 

internally, Apple industrial designer Shin Nishibori was directed to prepare a ―Sony-like‖ design 

for an Apple phone and then had CAD drawings and a three-dimensional model prepared. See 

Exs. 1-3 (DX 623; DX 690; DX 562). Confirming the origin of the design, these internal Apple 

CAD drawings prepared at Mr. Nishibori‘s direction even had the ―Sony‖ name prominently 

emblazoned on the phone design, as the below images from Apple‘s internal documents show: 

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Soon afterward, on March 8, 2006, Apple designer Richard Howarth reported that, in contrast to 

another internal design that was then under consideration, Mr. Nishibori‘s ―Sony-style‖ design 

enabled ―a much smaller-looking product with a much nicer shape to have next to your ear and in 

your pocket‖ and had greater ―size and shape/comfort benefits.‖ Ex. 3 (DX 562). As Mr. 

Nishibori has confirmed in deposition testimony, this ―Sony-style‖ design he prepared changed the 

course of the project that yielded the final iPhone design. 

Design was not the only thing Apple took from other companies in developing the iPhone. 

While Apple touts itself in the popular press as a company of ―firsts,‖ it recognizes the opposite 

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internally. As Apple admitted in internal emails, Apple was not the first ―to incorporate a full 

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touchscreen face‖ with the iPhone. That was the LG Prada. 

Ex. 4 (DX 578). Nor was it the 

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―first phone to have robust apps + app store‖. That was Palm. Id. Indeed, as one Apple 

employee explained to an overly enthusiastic marketer, ―I don‘t know how many things we can 

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come up with that you can legitimately claim we did first. 

Certainly we have the first successful 

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versions of many features, but that‘s different than launching something to market first.‖ Id. 

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III. 

APPLE’S UTILITY PATENTS 

Apple‘s utility patents relate to ancillary features that allow users to perform trivial touch 

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screen functions, even though these technologies were developed and in widespread use well 

before Apple entered the mobile device market in 2007. Samsung does not infringe any of 

Apple‘s patents and has located dead-on prior art that invalidates them. 

A. Claim 19 of U.S. Patent No. 7,469,381 Patent is Invalid and Not Infringed 

Apple asserts that 23 Samsung products infringe claim 19 of the ‗381 patent, which claims 

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a touch screen device capable of performing a ―bounce-back‖ function. 

Samsung‘s products do 

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not infringe claim 19. 

As an initial matter, Apple and its expert‘s infringement analysis is 

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improperly limited to ―representative‖ products and source code, and generalizations that other 

products running the same major release of the Android operating system behave in the same way. 

Products running the same Android release often behave differently, however. Thus, Apple‘s 

reliance on ―representative‖ products and source code cannot meet its burden of proving 

infringement by many of the accused products. 

In addition, Samsung‘s products exhibit numerous features that do not meet the limitations 

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of the ‗381 patent, as interpreted by the Court. 

These non-infringing features include (1) a ―hold 

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still‖ behavior, where Samsung‘s products do not translate the electronic document in a second 

direction; (2) a general snapping behavior, where Samsung‘s products snap forward, not 

backward, if the user scrolls beyond a threshold point; and (3) a ―hard stop‖ behavior, where 

Samsung‘s products do not display an area beyond the edge of the electronic document. 

Furthermore, the ‗381 patent is invalid in light of the prior art that discloses the same 

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―bounce-back‖ feature. 

These references include the Tablecloth program installed on the 

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DiamondTouch system developed by Mitsubishi Electric Research Laboratory (―MERL‖), the 

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LaunchTile and XNav programs developed by Dr. Benjamin Bederson, and International 

Publication Number WO 03/081458. 2 

B. Claim 8 of U.S. Patent No. 7,844,915 Is Invalid and Not Infringed 

Apple asserts that 25 Samsung products infringe claim 8 of the ‗915 patent, which claims a 

touchscreen device capable of distinguishing between single-input scroll operations and multiinput 

gesture operations. 

Samsung‘s products do not infringe claim 8 for at least two reasons. 

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First, Samsung‘s products do not include an ―event object‖ that ―invokes a scroll‖ or gesture 

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operation. 3 

Apple identifies a MotionEvent object in the accused products as the ―event object‖ 

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created in response to detecting user input. 

Apple concedes, however, that a completely different 

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object—the WebView object, which is not an ―event object‖—is the only object that causes 

scrolling or scaling. Second, Samsung‘s products permit multi-finger scrolling, and therefore 

distinguish between scrolling and gesture operations based on criteria other than the number of 

inputs, as required by claim 8. 

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Moreover, Apple did not invent multi-touch gesture recognition. 

The ‗915 patent is 

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invalid in light of prior art such as the Mandelbrot program installed on MERL‘s DiamondTouch 

system, Japanese Patent Publication Number 2000-163031, and Jefferson Han‘s multi-touch 

system from the 2005 SIGGRAPH conference. 

C. Claim 50 of U.S. Patent No. 7,864,163 Is Invalid and Not Infringed 

Apple asserts that 25 Samsung products infringe claim 50 of the ‗163 patent, which claims 

a touch screen device capable of enlarging and translating a ―structured electronic document.‖ 

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Apple cannot carry its burden of proving infringement of claim 50, however. 

For example, 

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Apple fails to identify how Samsung‘s products display a structured electronic document with a 

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By discussing specific prior art references, Samsung in no way waives its right to present 

evidence of other prior art references cited in Samsung‘s Invalidity Contentions, interrogatory 

responses, and Notice of Prior Art Pursuant to 35 U.S.C. § 282. 

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The Court construed ―event object invokes‖ a scroll or gesture operation to mean the 

―event object causes‖ a scroll or gesture operation. (Dkt. 1159 at 18-20.) 

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plurality of boxes of content; instead, Apple‘s expert merely superimposes rectangles on logical 

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regions of a webpage. 

Apple also fails to show that the accused products ―determin[e] a first box 

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in the plurality of boxes at the location of the first gesture,‖ because Apple only addresses cases 

involving a single box—not a plurality of boxes—at the location of the first gesture. Finally, 

Apple fails to show that the accused products translate the structured electronic document so that 

the first and second boxes are substantially centered, because the instances of alleged infringement 

only show centering in one direction or no direction at all, or cases where no ―translating‖ occurs 

because the box is already centered prior to the gesture. 

Moreover, the ‗163 patent discloses the use of techniques (zooming and panning) that were 

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well-known, as shown by references. 

For instance, Dr. Bederson‘s LaunchTile and XNav 

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programs publicly disclosed each limitation of claim 50 prior to Apple‘s asserted conception date. 

The ‗163 patent is also anticipated by Bryan Agnetta‘s prior invention, described in a provisional 

patent application, No. 60/718,187. Finally, U.S. Patent Publication No. 2002/0030609 

reinforces the ‗163 patent‘s lack of novelty by showing a motivation to combine techniques used 

in application management systems with browser applications on portable electronic devices. 

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IV. 

APPLE’S DESIGN PATENT CLAIMS 

Apple persists in misstating the legal standards for design patent infringement, including as 

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it seeks to present them to the jury during trial. 

A. Design Patent Infringement Requires Deceptive Similarity 

Apple must prove that an ordinary observer, conversant with the prior art, would be 

deceived into buying the accused product thinking that it was the same design as the patented 

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design. The Supreme Court so held in Gorham Co. v. White, 81 U.S. 511, 528 (1872): 

―We 

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hold, therefore, that if, in the eye of an ordinary observer, giving such attention as a purchaser 

usually gives, two designs are substantially the same, if the resemblance is such as to deceive such 

an observer, inducing him to purchase one supposing it to be the other, the first one patented is 

infringed by the other.‖ (emphasis added). As the Court explained, deception is required and is 

fundamental to the purpose of design patent protection: 

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It is persons of the latter class [i.e., ordinary observers] who are the principal purchasers of 

the articles to which designs have given novel appearances, and if they are misled, and 

induced to purchase what is not the article they supposed it to be, if, for example, they are 

led to purchase forks or spoons, deceived by an apparent resemblance into the belief that 

they bear the ―cottage‖ design, and, therefore, are the production of the [patent holder] …, 

when in fact they are not, the patentees are injured, and that advantage of a market which 

the patent was granted to secure is destroyed. 

Id. (emphasis added). 

Gorham remains binding precedent, and the Federal Circuit‘s en banc decision in Egyptian 

Goddess, Inc. v. Swisa, Inc., 543 F.3d 665 (Fed. Cir. 2008), reiterated that Gorham is the sole test 

for infringement. 

―In the language used by the Supreme Court in Gorham, 81 U.S. at 528, we 

hold that the accused design could not reasonably be viewed as so similar to the claimed design 

that a purchaser familiar with the prior art would be deceived by the similarity between the 

claimed and accused designs, ‗inducing him to purchase one supposing it to be the other.‘― 543 

F.3d at 681. The Federal Circuit has recited and applied this standard time and time again—both 

before and after Egyptian Goddess. See, e.g., Crocs v. ITC, 598 F.3d 1294, 1303 (Fed Cir. 2010) 

(―To show infringement under the proper test, an ordinary observer, familiar with the prior art 

designs, would be deceived into believing that the accused product is the same as the patented 

design.‖) (emphasis added); Richardson v. Stanley Works, Inc., 597 F.3d 1288, 1295 (Fed. Cir. 

2010) (infringement occurs where ―an ordinary observer would be deceived into thinking that any 

of the [accused] designs were the same as [the] patented design‖) (emphasis added); Amini 

Innovation Corp. v. Anthony California, Inc., 439 F.3d 1365, 1371 (Fed. Cir. 2006) (―If a design 

includes both functional and ornamental features, infringement occurs if an ordinary person 

‘would be deceived by reason of the common features in the claimed and accused designs which 

are ornamental.‘― (quoting Read Corp. v. Portec, Inc., 970 F.2d 816, 825 (Fed. Cir. 1992)) 

(emphasis added)). 

Apple concedes that Gorham‘s ―such as to deceive‖ language is ―an elaboration on how 

similar two designs must be to be ‗substantially the same.‘― See Disputed Jury Instructions, Dkt 

No. 1232 at 164. Yet, Apple advocates withholding from the jury this indispensable aspect of the 

legal test. 

Id. Apple likewise seeks to truncate Gorham‘s language that deception must be 

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considered in the purchasing context. Dkt No. 1232 at 165. As its justification, Apple contends 

that Samsung supposedly uses the phrase ―to suggest that there needs to be evidence of deception 

of a consumer purchasing a Samsung product for an Apple product in order to prove 

infringement.‖ Dkt No. 1232 at 164. Tellingly, Apple cites nothing where Samsung has 

advocated such a requirement. Also contrary to Apple‘s suggestion, courts have repeatedly 

found evidence of deception — or lack thereof — in the real world purchasing context to be 

relevant to the inquiry. See, e.g., L.A. Gear, Inc. v. Thom McAn Shoe Co., 988 F.2d 1117, 1125- 

26 (upholding a design patent infringement ruling based on evidence of real world confusion 

between products); Arminak & Assocs. Inc. v. Saint-Gobain Calmar, Inc., 501 F.3d 1314, 1324 

(Fed. Cir. 2007) (relying on expert and lay testimony there would be no confusion between 

patentee‘s product and accused product); OddzOn Prods, Inc. v. Just Toys, Inc., 122 F.3d 1396, 

1405-07 (Fed. Cir. 1997) (finding real world confusion evidence relevant but insufficient because 

it did not factor out functional features). 

As another justification for its misstatements of the Gorham test, Apple complains that 

―emphasis on the ‗purchase‘ phrase in Gorham may mislead the jury away from focusing on and 

comparing the claimed designs.‖ Id. at 165 (emphasis in original). But informing the jury 

about the proper legal standard as articulated by binding precedent is scarcely a distraction or 

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misleading. 

Indeed, the very definition of what makes two designs ―substantially the same‖ is 

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that the ordinary observer would be deceived in purchasing. ―Two designs are substantially the 

same if their resemblance is deceptive to the extent that it would induce an ordinary observer, 

giving such attention as a purchaser usually gives, to purchase an article having one design 

supposing it to be the other.‖ Door-Master Corp. v. Yorktowne, Inc., 256 F.3d 1308, 1313-14 

(Fed. Cir. 2001) (emphasis added); see also Arminak, 501 F.3d at 1321 (―This test requires an 

objective evaluation of the question of whether a hypothetical person called the ‗ordinary 

observer‘ would find substantial similarities between the patented design and the accused design, 

so as to be deceived into purchasing the accused design believing it is the patented design.‖) 

(emphasis added). This Court has recognized this as well, expressly ruling that ―designs are 

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‗substantially the same, if the resemblance is such as to deceive [an ordinary observer], inducing 

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him to purchase one supposing it to be the other.‘― 

Goddess, 543 F.3d at 670). 4 

B. Minor Differences Matter 

Dkt No. 449 at 9-10 (quoting Egyptian 

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Apple argues that ―[m]inor differences should not prevent a finding of infringement.‖ 

Dkt No. 1232 at 157. But this is contrary to law. The hypothetical ordinary observer is 

assumed to be familiar with the prior art. Egyptian Goddess, 543 at 681-83. Here, the crowded 

field of art includes a spectrum of rectangular devices with rounded corners, flat surfaces, bezels, 

display screens with borders around them, and lozenge shapes above display screens. 

Accordingly, the hypothetical ordinary observer will readily identify and take into account 

differences that may go unnoticed in the abstract, such as the specific roundness of a corner, 

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thickness of a border, or shape of a bezel. 

―[D]ifferences between the claimed and accused 

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designs that might not be noticeable in the abstract can become significant to the hypothetical 

ordinary observer who is conversant with the prior art.‖ Egyptian Goddess, 543 F.3d at 678; see 

also id. (―[W]hen the claimed design is close to the prior art designs, small differences between 

the accused design and the claimed design are likely to be important to the eye of the hypothetical 

ordinary observer.‖) (emphasis added). This Court too has recognized this already, noting that 

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4 This and other formulations of the test appear verbatim in Samsung‘s instruction, yet Apple 

erroneously suggests that Samsung is rewording the standard. Dkt No. 1232 at 164. Apple also 

quarrels with the phrase ―deceptively similar‖ used in Samsung instructions as shorthand for the 

infringement test. This is surprising because the phrase is pulled straight out of Federal Circuit 

precedent. Just two years ago in Richardson v. Stanley Works, for example, the Federal Circuit 

stated that ―infringement cannot be found unless the accused product creates an appearance 

deceptively similar to the claimed design.‖ 597 F.3d at 1296 (citing Egyptian Goddess). In 

Arminak v. Saint-Gobain, the Federal Circuit commended the trial court for applying the design 

patent infringement test ―in the proper manner‖ because it ―determine[d] whether an ordinary 

observer would find the accused design deceptively similar‖ to the patented design. 501 F.3d 

1314, 1327 (Fed. Cir. 2007). And Egyptian Goddess itself said that where an accused design 

copies a novel feature of the asserted design, it is ―more likely to be regarded as deceptively 

similar to the claimed design, and thus infringing.‖ 543 F.3d at 677 (emphasis added). 

Apple‘s related objection to Samsung‘s design patent infringement instruction that the phrase 

―deceptively similar‖ is used instead of the phrase ―substantially the same‖ in what is otherwise a 

direct quote from Arminak is wrong. Dkt No. 1232 at 165. As shown, the phrase ―deceptively 

similar‖ was the choice of the Arminak Court itself. It is not the creation of Samsung. 

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―the prior art references identified by Samsung, as well as the overall simplicity of the D‘677 

patent, may make minor differences between the patent-in-suit and the front view of the Infuse 4 

— for example, the addition of buttons and writing on the Samsung Infuse 4 that are not present in 

the Apple patents — take on greater significance in the eyes of the ordinary observer.‖ Dkt No. 

449 at 27; see also id at 26 (―Moreover, given the simplicity of the design at issue, and the fact 

that consumers purchasing this product are purchasing an expensive electronic device, minor 

differences between the patent and the accused device are likely to take on greater significance in 

the eyes of the ordinary observer.‖). 

Minor differences that are important to the ordinary observer conversant with the prior art 

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can certainly prevent a finding of infringement. 

For example, in Smith v. Whitman Saddle Co., 

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148 U.S. 674 (1893), a case heavily relied on in Egyptian Goddess, the hypothetical ordinary 

observer was held to distinguish the accused and claimed saddle designs based solely on the angle 

of the drop at the rear of the pommel because a combination of prior art designs yielded a design 

having all but that feature. Id. at 682; see also Arminak v. Saint-Gobain, 501 F.3d 1314, 1324-25 

(Fed. Cir. 2007) (finding ordinary observer would not be deceived where only minor differences 

existed). As another example, in Goodyear Tire & Rubber Co. v. Hercules Tire & Rubber Co., 

162 F.3d 1113, 1115 (Fed. Cir. 1998), the plaintiff asserted infringement of the patent on the left 

below by the design on the right. 

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The court held that ―[a]lthough there are apparent similarities in the overall appearance of the 

designs, we affirm the conclusion that the trucker as ordinary observer would notice the 

differences in the designs and recognize that they are not colorably the same.‖ Id. at 1121-22. 

Any generalized argument by Apple that minor differences must preclude a finding of non- 

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infringement is therefore unsupported by law and misleading. This is especially true where, as 

here, Apple is claiming only parts of a hand-held device with minimal features. 

C. Design Patents Do Not Protect The Shape Or Configuration Of A Design 

Absent The Surface Ornamentation 

Apple urges that its design patents cover the shape or configuration of an article regardless 

of the surface ornamentation. This is contrary to precedent as well as legislative amendments to 

the Patent Act, which currently permits design patents only for the ―new, original, and ornamental 

design for an article of manufacture.‖ 35 U.S.C. 171 (emphasis added). 

The Patent Act previously offered protection for shapes, but that provision was removed 

over a century ago. 

Before then, the Patent Act protected a range of design patent types 

including those for ―any new, useful, and original shape or configuration of any article of 

manufacture.‖ Act of July 8, 1870, c. 230, § 71, 16 Stat. 209 (emphasis added); see also Act of 

Aug. 29, 1842, c. 263, § 3, Stat. 543 (providing protection for ―any new and original shape or 

configuration of any article of manufacture‖) (emphasis added). 

In 1902, Congress replaced that 

section with what is essentially the language in effect today. See Act of May 9, 1902, c. 783, § 

4929, 32 Stat. 193 (―Any person who has invented any new, original, and ornamental design for 

an article of manufacture . . .‖) (emphasis added); Act of July 19, 1952, c. 950, § 171, 66 Stat. 805 

(―Whoever invents any new, original and ornamental design for an article of manufacture may 

obtain a patent therefor . . .‖); see also 37 C.F.R. § 1.153 (―The claim shall be in formal terms to 

the ornamental design for the article (specifying name) as shown, or as shown and described.‖). 

Federal Circuit law confirms that design patents are ―limited to ornamentation‖ and ―do 

not and cannot include claims to the structural or functional aspects of the article.‖ Lee v. 

Dayton-Hudson, 838 F.2d 1186, 1188 (Fed. Cir. 1988). There, the Court cited to the current 

statute in rejecting the patentee‘s argument that ―the novelty of his design resides in its basic 

configuration, not the surface details‖. Id. Relatedly, mere symmetry is also not a protectable 

ornamental feature. 

In re Carletti, 328 F.2d 1020, 1022 (Cust. & Pat. App. 1964) (―The creation 

or origination of an ornamental design does not reside in the mere avoidance of dissymmetry.‖). 

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Apple‘s attempt to assert its patents to monopolize the shape of an article irrespective of the 

surface details found in either the patent or the accused devices is contrary to law. 

V. SAMSUNG’S PATENT INFRINGEMENT CLAIMS AGAINST APPLE 

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Unlike Apple, which was not a participant in the mobile communications industry until it 

released the first iPhone in mid-2007, Samsung began developing mobile communications 

technology in 1991. Samsung has since invested billions of dollars in developing the backbone 

of the industry and the wireless standards necessary for smartphones. Between 2005 and 2010 

alone, Samsung invested $35 billion in research and development relating to telecommunications 

technology, with over 20,000 engineers worldwide dedicated to telecommunications research and 

development. 

Apple relied heavily on Samsung‘s technology to enter the telecommunications space, and 

it continues to use Samsung‘s technology to this day in its iPhone and iPad products. 

example, Samsung supplies the flash memory, main memory, and application processor for the 

iPhone. Samsung also manufactures Apple‘s A5X processor and is the sole supplier of the 

Retina display used in the new iPad. But Apple also uses patented Samsung technology that it 

has not paid for. This includes standards-essential technology required for Apple‘s products to 

interact with products from other manufacturers, and several device features that Samsung 

developed for use in its products. 

A. Apple’s Infringement of Samsung’s Standards Patents 

Standards organizations are an important part of telecommunications technology, setting 

requirements that ensure that components from different manufacturers are compatible. The 

most important telecommunications organization is the European Telecommunications Standards 

Institute, or ETSI, which produces global standards for information and communications 

technologies. ETSI creates these standards in ―working group‖ meetings in which companies 

submit proposals identifying a new standard or an improvement on an existing standard. 

Samsung has played an active role in these working group meetings, and its contributions have 

helped build the standards used in the telecommunications industry. Some of these contributions 

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SAMSUNG’S TRIAL BRIEF 

For


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are the subject of the three standards-essential patents at issue in this lawsuit, which Apple uses 

and benefits from through its compliance with ETSI standards. 

The first of these, U.S. Patent No. 7,675,941 (―the ‗941 patent‖), is directed to a ―method 

and apparatus for transmitting/receiving packet data using pre-defined length indicator in a mobile 

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communications system.‖ 

In general, the ‗941 patent allows a cell phone‘s processor to quickly 

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determine what kind of data is being sent, allowing for less computing time, faster data speeds and 

longer battery lives. Specifically, when data is transmitted in a mobile device it is first broken 

into chunks and these chunk broken into even smaller groups. When the data is received, a 

computer processor re-assembles the smaller groups back into the original data. The ‗941 patent 

recognizes which of these smaller groups of data can be processed most quickly and then unpacks 

those particular groups and immediately forwards them to the correct component, reducing the 

time and resources required to process data and resulting in faster data transfer. 

This technology, referred to as the ―Alternative E-Bit Technology,‖ is required by the 

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3GPP specification. 

In order to sell a wireless phone, Apple must comply with the 3GPP 

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specification, which necessitates use of the Alternative E-Bit Technology. Apple‘s products 

therefore benefit from the Alternative E-Bit Technology and infringe Samsung‘s ‗941 patent. 

Samsung‘s second standards patent, U.S. Patent No. 7,447,516 (―the ‗516 patent‖), is 

directed to a ―method and apparatus for data transmission in a mobile telecommunication system 

supporting enhanced uplink service.‖ The ‗516 patent keeps the power used by radio antennae 

on mobile devices below the limit imposed by the Federal Government, while simultaneously 

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ensuring that all necessary information is still sent. 

The ‗516 patent thus helps reduce 

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interference in crowded networks and helps calls intended for one person from being overhead by 

others. Apple‘s infringement of the ‗516 patent is confirmed by its compliance with the 3GPP 

standard as well as third-party testing documents. 

B. Apple’s FRAND Defenses Are Meritless 

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Long before Apple even announced any of its 3G products that use Samsung‘s standardsessential 

technology, Samsung had offered licenses for these patents(along with other patents) to 

virtually every major player in the mobile phone industry, successfully striking cross-licensing 

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deals with all of them. After Apple released products that use the technology patented in the 

‗941 and ‗516 patents, Samsung similarly offered a cross-licensing deal to Apple, asking for a fair 

and reasonable royalty in return for Apple‘s use of Samsung‘s technology. Unlike all the major 

players in the mobile phone industry, however, Apple refused to enter a cross-licensing deal with 

Samsung. 

Instead, despite the fact that virtually every other major industry participant was willing to 

take a license from Samsung for use of the standards-essential patents in this suit, Apple claimed 

that Samsung‘s patents are unenforceable because, according to Apple, Samsung should have 

disclosed these patents to ETSI during the working group discussions concerning the technology. 

But the ‗941 and ‗516 patents did not even exist at that point. What Apple is really arguing is 

that Samsung should have disclosed confidential Korean patent applications during the working 

group discussions—but this is contrary to ETSI‘s own rules, which expressly exclude confidential 

information from ETSI‘s disclosure requirements for intellectual property rights, or so-called 

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IPRs. 

In fact, ETSI‘s Guide on IPRs instructs ETSI members that technical meetings are not an 

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appropriate place for discussion of IPRs. 

And Apple‘s own expert on this issue, a former 

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Chairman of the Board of ETSI, has stated that he cannot recall a participant ever disclosing IPRs 

in the working group meetings. 

Apple argues in the alternative that Samsung‘s proposed royalty is not fair and reasonable, 

but Samsung‘s opening offer to Apple is consistent with the royalty rates other companies charge 

for use of their standards-essential patents. Moreover, Apple never even made a counteroffer. 

Instead, it simply rejected Samsung‘s opening offer, refused to negotiate further and to this day 

has not paid Samsung a dime for Apple‘s use of Samsung‘s standards-essential technology. 

C. Apple’s Infringement of Samsung’s ‘460, ‘711 and ‘893 Patents 

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In addition to infringing Samsung‘s standards patents, Apple‘s products use features 

invented and patented by Samsung, and infringe the three remaining patents Samsung has asserted 

in this lawsuit. The first of these patents, U.S. Patent No. 7,577,460 (―the ‗460 patent‖), is 

directed to the integration of a cell phone, digital camera and email technologies in a single device. 

Samsung is 

asserting Claim 1 of the ‗460 patent at trial, which describes Samsung‘s innovation 

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as a five-step method performed on a camera phone. Together, these five steps describe three 

core functions performed on a camera phone – sending text-only emails, sending emails 

displaying both text and an image, and sequentially displaying images stored on the device. 

Apple‘s products perform the five steps and three core functions described in the ‗460 patent. 

The technology patented by the second of Samsung‘s feature patents, U.S. Patent No. 

7,456,893 (―the ‗893 patent‖), is also used by Apple‘s iPhones and iPads. The ‗893 patent allows 

users to bookmark an image in an image gallery so that, after taking new pictures with the camera, 

the user returns to that same image instead of the new images. At the time of this invention, 

galleries on digital cameras displayed the most recently captured image, which resulted in users 

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losing their place in the image gallery if they paused to take new photos. 

Samsung‘s 

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bookmarking invention is described in claim 10 of the ‗893 patent, which is infringed by Apple‘s 

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iPhones and iPads. 

Importantly, Apple did not incorporate this patented feature into any of its 

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devices until seven months after the ‗893 Patent issued. 

The third of Samsung‘s asserted feature patents, U.S. Patent No. 7,698,711 (―the ‗711 

patent‖), addresses the longstanding problem earlier mobile devices had with allowing users to 

multi-task while listening to music in the background. The patented technology solved this 

problem by providing users with the ability to play music in the background while simultaneously 

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accessing other programs and menus. 

‗711 patent. 

Apple‘s products use this feature and infringe Samsung‘s 

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VI. 

DAMAGES 

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A. Unlike Samsung’s Reasonable Royalty Claims, Apple’s Claims For Lost 

Profits and Disgorgement of Samsung’s Profits Lack Credibility 

Apple‘s overreaching claim for damages is a natural extension of its attempt to monopolize 

the marketplace. 

It demands the entirety of Samsung‘s revenues on the accused phones and 

tablets for the alleged infringement of a design patent that shows little more than a blank rectangle 

with rounded corners. 

It seeks to collect ―lost profits‖ despite the fact that no one buys phones 

because they have ―bounce back‖ feature or other manifestations of Apple‘s alleged inventions 

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asserted in this case. 

Damages are meant to compensate, not confer an absurd windfall at the 

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expense of competitions and consumers worldwide.‖ 

Samsung, on the other hand, has simply demanded a reasonable royalty for its patents. 

Samsung invested billions of dollars in researching and developing wireless technology, including 

contributions Samsung has made to the UMTS standard. The UMTS standard is important to the 

performance of smartphones and, like other smartphone manufacturers, Apple charges consumers 

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a premium for devices that use UMTS standards because they perform better. 

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however, Apple did not contribute to the development of the UMTS standard. Nor has Apple 

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paid for its use of the UMTS technology Samsung developed. 

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free-ride on Samsung‘s investments without paying for the use of Samsung‘s technology. 

Samsung‘s royalty rate for its standards patents is a reasonable percentage of the selling 

price of the device using the UMTS standard, which is consistent with other industry license rates 

for smartphones using standards patents. While Samsung‘s standards patents enable a mobile 

device to actually work, Samsung‘s feature patents make mobile devices more convenient for 

people to use. Consequently, the royalty for those patents is less. 

A. Under Section 289, Apple May Only Recover Profits From The Allegedly 

Infringing Cases Of Samsung’s Products, Not Their Functional Contents And 

Components. 

Apple seeks to recover windfall profits that bear no proportion to any claimed harm to 

Apple or alleged wrongful gains by Samsung. 

According to Apple, the cases of Samsung‘s 

phones and tablets are infringing because those cases infringe Apple‘s patented designs. Yet 

Apple seeks all of Samsung‘s profits from sales of the accused phones and tablets on the grounds 

that 35 U.S.C. § 289 purportedly grants such a windfall – even if the non-infringing contents of 

Samsung‘s devices are in fact what creates Samsung‘s profits. 

Apple‘s request for a noncompensatory 

windfall overlooks Section 289‘s requirement that profits disgorgement be limited 

to the ―article of manufacture‖ to which a patented design is applied, and is contrary to law. The 

Court has not previously addressed the identity of Section 289‘s ―article of manufacture‖ as 

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applied to the D‘889, D‘087 and D‘677 design patents; it will need to do so should liability be 

found. 

The Federal Circuit explained in Nike Inc. v. Wal-Mart Stores, 138 F.3d 1437, 1442 (Fed. 

Cir. 1998), that the legislature removed ―the need to apportion the infringer‘s profits between the 

patented design and the article bearing the design‖ in the Act of 1887, which led to the current 

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Section 289. 

It remains necessary under Section 289, however, to determine the amount of 

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profits earned from the ―article of manufacture to which [the patented] design or colorable 

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imitation has been applied‖. 35 U.S.C. § 289. 

A Second Circuit case explains how to make that 

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determination where, as here, the product that is sold consists of an ornamental case that surrounds 

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a functional core. 

See Bush & Lane Piano Co. v. Becker Bros., 222 F. 902, 903-904 (2d Cir. 

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1915) (―Bush & Lane Piano‖); see also Bush & Lane Piano Co. v. Becker Bros., 234 F. 79 (2d 

Cir. 1916) (opinion after remand) (―Bush & Lane Piano II‖). 

In Bush & Lane Piano, the plaintiff proved infringement of its patented design for a piano 

case – i.e., ―the structure which incloses and holds in position the piano proper, viz., the part 

which produces the music. The former appeals to the eye, the latter to the ear.‖ 222 F. at 903. 

Applying the Act of 1887, the predecessor to Section 289, the Court reversed an award of ―the 

entire profits of the sales of the piano and case,‖ holding instead that only ―the profits upon the 

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sale of the case‖ could be disgorged. 

Id. The Court explained: 

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To attribute the sale of 958 Imperial pianos solely to the design of the case which 

inclosed them seems unwarranted. Such a supposition is unsupported by the proof 

and involves too violent a presumption to be accepted. What Lane invented was a 

piano case, not a piano. He received a patent for a ‗piano case‘ and not for a piano, 

but he has recovered the profits on 958 pianos. 

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Id. at 904. 

A dissent urged that all profits from piano sales properly were awarded under the Act 

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of 1887 because ―the article which the complainant manufactures and sells is a piano and the 

article to which the design is applied is a piano,‖ and the ―complainant neither manufactures the 

case nor sells it separately.‖ Id. at 905-06 (Ward, J., dissenting). But for the majority, 

―[w]hen the patent owner is awarded the profits due to his design he receives all he is entitled to. 

If the rule be established that a design for a case enables the owner to collect damages for the case 

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not only, but for the contents of the case as well, it will lead to results which shock the conscience. 

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A design for a watch case will include the watch itself. A design for a gun case will include the 

gun, a design for a hat case will include the hat and so on.‖ Id. at 905. 

This holding is fully consistent with Section 289, and the Act of 1887 on which it is based. 

As the Federal Circuit explained in Nike, the Act of 1887 was a response to a ―series of cases 

involving carpet designs,‖ where infringing defendants were found ―liable for no more than 

‗nominal damages‘ of six cents because the patentees could not show what portion of their losses 

or the infringers‘ profits was due to the patented design and what portion was due to the 

unpatented carpet.‖ Nike, 138 F.3d at 1441. The legislature removed ―the need to apportion the 

infringer‘s profits between the patented design and the article bearing the design‖ in response. 

Id. But this removal of the need to apportion did not remove the need to limit an award of profits 

to ―the article bearing the design‖ itself, and to determine what the article bearing the design 

actually is. Id. In Bush & Lane Piano, the article bearing the design was the infringing piano 

case; without engaging in apportionment proscribed by the Act of 1887, profits therefore were 

properly ―confined to the subject of the patent - a piano case.‖ 222 F. at 904. This presents an 

unresolved issue that will require the Court‘s attention; while the Court has previously addressed 

apportionment under Section 289, see June 29, 2012 Order at 9, it has not resolved what the 

relevant ―article of manufacture‖ is as applied to Apple‘s design patents. 

In some cases the article bearing the infringing design is inseparable from the entire article 

as sold, and therefore all profits from sales of the article are recoverable under Section 289. An 

infringing carpet design, see Dobson v. Dornan, 118 U.S. 10 (1886), or a design for a spoon 

handle, see Gorham v. White, 81 U.S. 511 (1871), ―is inseparable from the article to which it is 

attached, or of which it is a part,‖ and all profits from sales of such infringing products are 

recoverable. Bush & Lane Piano, 222 F. at 904. By contrast, a ―patent for a ‗book binding‘ 

cannot, either justly or logically, be so identified with the entire book as to give all the profits on a 

work of literary genius to the patentee of a binding, although the binding was manufactured with 

and for that one book, and has no separate commercial existence. The binding and the printed 

record of thought respond to different concepts; they are different articles.‖ Bush & Lane Piano 

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II, 234 F. at 81-82. So too as to the outer case of a functional product. 

Even though the piano 

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―case and works were merely component parts of an integral whole, and [] there was no instance 

of a sale of a piano without a case, or a case without works,‖ only profits attributable to the case 

itself could be awarded because the case, and not the piano works, was ―the article to which the 

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versus works). 

Id. at 79, 83 (affirming award of profits based on proportionate cost of case 

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Any ruling that grants ―the owner of a design patent for a receptacle intended to hold an 

expensive article of manufacture the profits made on the sale of the receptacle and its contents, 

must certainly lead to inequitable results and cannot be sustained.‖ Bush & Lane Piano, 222 F. 

at 904-905. Apple seeks precisely such a ruling from the Court. Following the Second 

Circuit‘s guidance, the Court should reject Apple‘s request for windfall profits that are not 

attributable to the allegedly infringing phone and tablet cases sold by Samsung. 

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DATED: July 23, 2012 

QUINN EMANUEL URQUHART & 

SULLIVAN, LLP 

By /s/ Victoria F. Maroulis 

Charles K. Verhoeven 

Victoria F. Maroulis 

Kevin P.B. Johnson 

Michael T. Zeller 



AMERICA, INC., and SAMSUNG 


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02198.51855/4869164.9 



Case5:11-cv-01846-LHK Document1322-1 Filed07/25/12 Page1 of 5 

1 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 


Charles K. Verhoeven (Bar No. 170151) 




Telephone: (415) 875-6600 

Facsimile: (415) 875-6700 

Kevin P.B. Johnson (Bar No. 177129 


Victoria F. Maroulis (Bar No. 202603) 


555 Twin Dolphin Drive, 5 th Floor 

Redwood Shores, California 94065-2139 

Telephone: (650) 801-5000 

Facsimile: (650) 801-5100 

Michael T. Zeller (Bar No. 196417) 




Telephone: (213) 443-3000 

Facsimile: (213) 443-3100 

Attorneys for SAMSUNG ELECTRONICS CO., 

LTD., SAMSUNG ELECTRONICS AMERICA, 

INC. and SAMSUNG 




 

 

 

 

 

 

 

 

 

 

 


vs. 








Defendant. 


DECLARATION OF JOBY MARTIN IN 

SUPPORT OF SAMSUNG’S TRIAL 

BRIEF 

 


MARTIN DECLARATION IN SUPPORT OF SAMSUNG'S TRIAL BRIEF


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I, Joby Martin, declare as follows: 

1. I am an associate in the law firm of Quinn Emanuel Urquhart & Sullivan, LLP, 

counsel for Samsung Electronics Co., Ltd., Samsung Electronics America, Inc., and Samsung 

Telecommunications America, LLC (collectively, “Samsung”). I submit this declaration in 

support of Samsung’s Trial Brief. I have personal knowledge of the facts set forth in this 

declaration and, if called upon as a witness, I could and would testify to such facts under oath. 

2. Attached hereto as Exhibit 1 is a true and correct copy of Defendant’s Exhibit No. 

623, a document produced by Apple in this litigation bearing Bates label APLNDC- 

NCC00000274. 


690, a document produced by Apple in In Re Certain Electronic Digital Media Devices and 

Components Thereof, Inv. No. 337-TA-796 ("ITC 796 Investigation"), bearing Bates label APL- 

ITC-X0000016675. 


562, a document produced by Apple in this litigation bearing Bates label APLNDC0003040119. 


578, a document produced by Apple in the ITC 796 Investigation, bearing Bates label APL-ITC- 

0000119763. 


522, a document produced by Samsung in this litigation bearing Bates label 

SAMNDCA00321382. 







 

 

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10. Attached hereto as Exhibit 9.is a true and correct copy of Defendant’s Exhibit No. 

684, which is a chart prepared by Samsung’s counsel depicting a timeline of mobile phone 

products released by Samsung before and after the release of the iPhone. 






715, a document produced by Apple in the ITC 794 Investigation bearing Bates label 

APL7940009836305. 




709, a document produced by Apple in the ITC 794 Investigation bearing Bates label 

APL7940014663269. 





18. Attached hereto as Ex. 17 is a true and correct copy of excerpts from the February 

23, 2012 deposition transcript of Greg Joswiak, an Apple witness. 



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I declare under penalty of perjury under the laws of the United States that the foregoing is 

true and correct. Executed on the 23 rd day of July, 2012, in San Francisco, California. 

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____/s/ Joby Martin 

Joby Martin 

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General Order 45 Attestation 

I, Victoria F. Maroulis, am the ECF user whose ID and password are being used to file this 

Declaration. In compliance with General Order 45(X)(B), I hereby attest that Joby Martin has 

concurred in this filing. 

/s/ Victoria Maroulis 

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02198.51855/4871770.1 




EXHIBIT 1


DEFENDANT'S EXHIBIT 

NO. 623.001 

United States District Court 

Northern District of California 

No. 11-CV-01846-LHK (PSG) 

Apple v. Samsung 

Date Admitted:___________By:___________ 

cf 

I 

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APLNDC-NCC00000276



IDGHLY CONFIDENTIAL- ATTORNEYS' EYES ONLY APLNDC-N CC000002 77



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EXHIBIT 2


CONTAINS APPLE CONFIDENTIAL BUSINESS INFORMATION 

SUBJECT TO PROTECTIVE ORDER 

APL-ITC796-X0000016675 

DEPOSITION 

EXHIBIT




APL-ITC796-X0000016676




APL-ITC796-X0000016677




APL-ITC796-X0000016678




APL-ITC796-X0000016679




APL-ITC796-X0000016680




APL-ITC796-X0000016681




APL-ITC796-X0000016682




APL-ITC796-X0000016683




APL-ITC796-X0000016684




APL-ITC796-X0000016685




APL-ITC796-X0000016686




APL-ITC796-X0000016687


TONY 



APL-ITC796-X0000016688




APL-ITC796-X0000016689




APL-ITC796-X0000016690


SONY 



APL-ITC796-X0000016691




APL-ITC796-X0000016692




APL-ITC796-X0000016693


EXHIBIT 3


Subject: on: the sony vs apple competition 

Date: Wed, 08 Mar 2006 02:46:30 +0000 

From: "Richard Howarth" 

To: "Jonathan Ive" 

Message-ID: 


NO. 562.001 

United States District Cowt 

N orthem District of California 

No. 11-CV-01846-LHK (PSG) 


DateAdmitted: ___ By: __ _ 

hi Jony, 

i'm worried about the extrudo shape we're using for P2 etc. looking 

at what shin's doing with the sony-style chappy, he's able to achieve 

a much smaller-looking product with a much nicer shape to have next 

to your ear and in your pocket. also note that it's only half a step 

away from where we were with the metal band, black insides before we 

changed to the 3-equal-striped sandwich which i show below. It looks 

a lot smaller to me and it makes the X a load narrower, which is 

something i've been going on about for ages because i'm worried that 

the round sides are so inefficient. I agree that the one we did below 

isn't right, and it looks old next to the extrusion, but it does have 

the size and shape/comfort benefits i mentioned before and these are 

hard to ignore with a product we have to carry and use all day, every 

day. i'm really worried that we're making something that is going to 

look and be too wide. 

i'm also worried that if we start cutting volume buttons on the side, 

then it removes some of the purity of the extrusion idea and seems 

like the wrong shape for the job. We can only add so much too it 

before it becomes a style/ a shape, rather than the most efficient 

construction method and that would be bad. 

r. 

Highly Confidential- Attorneys' Eyes Only 

APLNDC0003040119



------ end message ------ 

Highly Confidential- Attorneys' Eyes Only APLNDC0003040 120




APLNDC0003040121




APLNDC0003040122




APLNDC0003040123




APLNDC0003040124


EXHIBIT 4



NO. 578.001 

Subject: Re: iPhone "firsts" 

Date: Wed, 14 Apr 2010 17:44:02 +0000 

From: "Kelly Altick" 

To: "Steve Sinclair" , "Eric Jue" 

Message-ID: 



No. 11-CV-01846-LHK (PSG) 



Just a heads up, it will likely be a group of 6 or so people today, along with Tamara and I. 

Here is a list of questions they prepped in advance that hopefully you can talk to. 

Thanks again for taking the time to chat with the team. 

See you at 2:30. 

On Apr 12, 2010, at 3:58PM, Kelly Altick wrote: 

Perfect. Done deal. 

On Apr 12, 2010, at 3:07PM, Steve Sinclair wrote: 

Ok- add Eric please- he was here at original iPhone launch and may have a few more "firsts" up 

his sleeve.:-) 

On Apr 12,2010, at 2:09PM, Kelly Altick wrote: 

Hi Steve, 

I grabbed 2:30-3 on your calendar for this convo on Wednesday. Let me know if I should add 

anyone else to the invite. Are you ok heading over to our building for the meeting? Thinking that 

might be easiest since the agency team will be in another meeting over here right before. 

Thanks, 

Kelly 


Sure- my iCal is up to date. 

On Apr 8, 2010, at 4:50PM, Rebecca VanDyck wrote: 

CONTAINS APPLE CONFIDENTIAL BUSINESS INFORMATION, 

SUBJECT TO PROTECTIVE ORDER APL-ITC796-0000 119763



Steve, the agency would love some time with you in person to ask some of these questions. 

Could you be available next Wednesday 4/14? They'll come up here. Is there a time that could 

work for you? 

I'm asking Kelly to be on point for our team for this, as I am out next week. 

Thanks all 

On Apr 6, 2010, at 4:39PM, Rebecca VanDyck wrote: 

Good idea ... 

I'll try and set something up. 

On Apr 6, 2010, at 2:55 PM, Michael Lewis wrote: 

yeah, i hear ya 

yes, maybe there's a different approach ... becca, it might be more efficient to get on the phone 

with the agency (with steve and eric) and see if there's another angle into this. hard to know 

what they're thinking based on the below. what do you think? 


Hey Michael, 

It's tough to approach this with the criteria being "first". I don't know how many things we 

can come up with that you could legitimately claim we did first. Certainly we have the first 

commercially successful versions of many features, but that's different than launching 

something to market first. 

Can we nuance this so it isn't about shipping a feature first? 

-the first phone to incorporate a full touchscreen face 

Not true http://en.wikipedia.org/wiki/LG Prada (KE850) 

-the first phone to have a multitouch interface/ gestures 

I think this may be true, but I haven't been able to confirm. 

-the first phone to have robust apps + apps store 

Palm had well over 10,000 apps in its ecosystem back in 2005ish and some of the games for 





both Nokia and Palm phones weren't that bad - definition of "robust" is a hard for me to 

judge. There have been app and music stores from other vendors and wireless carriers before 

the App Store, including from Nokia. None have been anywhere near as successful, but they 

existed before ours. 

-the first phone to incorporate a proximity sensor 

Not sure about this one - there were proximity sensors available for mobile phones from 

suppliers in 2004, but I can't find which phones actually used them. 

And before anyone asks, the accelerometer was put into Nokia 5500 phones back in 2006. 

I'll keep thinking about it and see if I can come up with some "firsts" that are defendable. 

What it really comes down to is that we're usually first at doing it "right"! 

Steve 

On Apr 5, 2010, at 5:52PM, Michael Lewis wrote: 

hey guys, would you be able to help? 

Begin forwarded message: 

From: Rebecca VanDyck 

Date: April 5, 2010 4:39:11 PM PDT 

To: Eric Starr , Michael Lewis 

Cc: Bob Ferrini , Mia Lee , 

Stephanie Chen , Besse Gardner 

, Tamara Whiteside 

Subject: Re: iPhone "firsts" 

Very cool list. 

I'm cc-ing Michael Lewis on this note. Michael, with Tamara out, do you think you could 

help us get a list like this from product marketing? 

On Apr 5, 2010, at 2:22PM, Eric Starr wrote: 

hi becca, 

as we're starting to think about the next round of work on iPhone, we're trying to get 

smart of some of iPhone's historical milestones. 

so starting with the very first iPhone, we're looking for a list of innovations/technologies 





that iPhone was the first to incorporate. some examples: 

-the first phone to incorporate a full touchscreen face 

-the first phone to have a multitouch interface/ gestures 

-the first phone to have robust apps + apps store 

-the first phone to incorporate a proximity sensor 

i've done a little research on this, but was hoping someone from the product team at 

Apple could help with putting together a list of "firsts." 

thanks a lot 

enc 

This e-mail is intended only for the named person or entity to which it 

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business information that is proprietary, privileged, confidential and/or 

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If you received this e-mail in error, any review, use, dissemination, 

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------ end message ------ 





MAL I APPLE Product Innovations Discussion. Wed. 4/14 @ 2:30PM 

PATENTS 

• How many patents were filed for the first phone, 3G, and 3GS? 

• What would you consider the more noteworthy patents? 

• Which patents set iPhone apart from the competition? 

• Which patents has the competition tried to copy? 

• Any interesting facts about the process of filing patents? Do you apply for 

more than actually make it in the device? 

INNOVATION 

• What are the biggest innovation milestones for the iPhone? Hero 

features? 

• Which features do you think helped iPhone revolutionize the category? 

• Which features in your opinion show how iPhone has changed how people 

use phones forever? 

• What can iPhone 'claim', if anything? 

o Hardware claims? (one button, touch screen, multi-touch, materials) 

o Software claims? (apps) 

o Superlatives? (eg, the thinnest smartphone yet) 

• What are 'iPhone only' features? 

• For several phone features (multi-tasking, cut/paste), apple is often not the 

"first to the party" but rather "the best." In your words, what does it entail to 

out-do the competition? What does 'better' look like? What does 'worse' 

look like? 

• What features are most often imitated? 

• Do you have any device comparisons (by feature, by claims, etc) 

• Will apps continue to play a role in the major innovations of the phone? 

Anything coming up that you're able to discuss? 

OTHER 

• Any future development to share? 




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Telephone: (415) 875-6600 

Facsimile: (415) 875-6700 







Telephone: (650) 801-5000 

Facsimile: (650) 801-5100 





Telephone: (213) 443-3000 

Facsimile: (213) 443-3100 







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MANUAL FILING NOTIFICATION FOR 

EXHIBIT 5 TO THE DECLARATION OF 

JOBY MARTIN 

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Defendants. 

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02198.51855/4870485.1 

NOTIFICATION OF MANUAL FILING


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MANUAL FILING NOTIFICATION 

PLEASE TAKE NOTICE that Exhibit 5 to the Declaration of Joby Martin in Support of 

Samsung’s Trial Brief was not e-filed for the following reason: Voluminous Document (PDF file 

size larger than e-filing system allowances). 

5 

6 

7 

8 

9 

This filing is in paper or physical form only, and is being maintained in the case file in the 

Clerk’s office. If you are a participant on this case, this filing will be served in hard-copy shortly. 

For information on retrieving this filing directly from the court, please see the court’s main web 

site at http://www.cand.uscourts.gov under Frequently Asked Questions (FAQ). 

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SULLIVAN, LLP 








INC., and SAMSUNG 

TELECOMMUNICATIONS AMERICA, LLC


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Telephone: (650) 801-5000 

Facsimile: (650) 801-5100 





Telephone: (213) 443-3000 

Facsimile: (213) 443-3100 







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JOBY MARTIN 

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EXHIBIT 7


(19)~ ~li} ~ ~ "8178 (KR) 

(12) ~~q A}C{!_:g.]!(S) 


NO. 519.001 



No. 11-CV-01846-LHK (PSG) 



(52) ~ff- H3-301 

(45) i?-JL~;z;} 

(11) %~1:8~ 

(24) %~~;z;} 

2007\'!08~27~ 

30-0452985%J.}2 

2007\'!08~17~ 

(51) ~'ll~ft 

(21) ~~ 'i'!~ 

(22) ~'t1_~7-} 

14-03 

30-200fl-00507flY 

2006 \:! 12~ 20~ 

1{-Aj~AtT~~,\} 

?cl7l~ 4--'eP·l 0 a~T- oBI'f% 416 

l:lf~~ 

Aj~~'&_A] 0 j:~T ~Aj3-\ij- 1192-2 Aj~c:':-7}0]~ 3:Z} 702~ 

o]~y 

'i]~-'if~Al-lf-'13T- ~~2% r~-q-o}10}E 107% 1101~ 

~Aj-'i'l 

"l~~';ll_Al "l~T t1JllH4% 809-26 cJ1+'@lol-'--7}-it-E1 201% 603~ 

(7 4) cJ1 2.1 'il 

(54) *--cR% ~~71 

3. {1-Jl~ loll ~Al'E! 1l}9] i{o] 7]rr1j.:c:=_Qj ~"-J-£ i!1E1CQWERTY)7].£.£9] i{o]llH'i'J.iO}cxj 7}_50_5'._ ~Jl J.}§ ~ "? 9]~:;:! 

0] 

0• 

.;;:.-'t) t:j?-}'1] ~ ~r:l ~-£ 7]-;;: ~ "-d- __()_3'._ iO}cxj, '~i"i]3:j __()_3'._ -lf-£ cl-& ~~-£ -~3] {:l ~ iO} Jl ~~ ;,-j] 'C! 'i'l n] tl--£ K ~ ~ --;! ~ 

r::1 7-}'i]?;j-3} Yl%91 81l __()_£._ w. 

- l- 

SAMNDCA00255357



- 2- 

SAMNDCA00255358



00000000 

0000000 

- ::J- 

SAMNDCA00255359



z '; '1 :A}'{} 30-0452985 A-A]2 

[ IJd'iJ.x l 

6 ) 

[ "l 'i':!x l 

( l J 

3 

[ %.JJS 1 ] 

oooooooooooo 

00000000000 

OOOOOOOOc=J 

- 4- 

SAMNDCA00255360



CERTIFICATION OF TRANSLATION 

I certify that the Korean to English translation of the Korean document entitled KR30-0452985(KR30-2006- 

0050769)is an accurate and complete rendering of the contents of the source document to the best of my 

knowledge and ability. I further certify that I am a qualified professional translator familiar with both languages 

with more than twenty years of experience in Korean to English translation of various legal, technical or 

business documents including a number oflegal evidentiary documents submitted to various courts in the 

United States. 

December 23, 2011 

Alex N. Jo, Translator 

SAMNDCA00255361



(19) Korea Intellectual Property Office (KIPO) (KR) 

(12) Official Gazette of Registered Industrial Designs (S) 

Registered Design 30-0452985 S2 

(52) Classification 

(51) Int. Cl. 

(21) Application No.: 

(22) Application Date: 

H3-301 

14-03 

30-2006-0050769 

December 20, 2006 

(45) Publication Date: August 27, 2007 

(11) Registration No.:30-0452985 S2 

(24) Registration Date: August 17, 2007 

(73)Design right holder 

(72) Inventors: 

(74) Agents: 

Samsung Electronics Co., Ltd. 

416 Maetan-dong, Youngtong-gu, Suwon, Gyeonggi-do, Korea 

Hyung Shin Park 

1192-2 Shinjeong 3-dong (JeongEunSkyville 3rd #702), 

Yangcheon-gu, Seoul, Korea 

Chang Soo Lee 

Chungcheon 2-dong (Daewoo Apartment # 107-1101 ), Bupyong-gu, 

Incheon Metropolitan City, Korea 

Sang Min Hyun 

809-26 Bangbae 4-dong (Daewoo Members County #201-603), 

Seocho-gu, Seoul, Korea 

Myung Hyun Ryu 

Gwang JeWoo 

Examiner: HyoSeok Han 

(54) Portable Phone 

Physical Target Object of the Design 

Portable phone 

Description of the Design 

1. It is made of metals and synthetic resin. 

2. It has a digital camera on top of the front surface. 

3. As illustrated in Informational Figure 1, the key pad is aligned in the same manner as a QWERTY keyboard, 

allowing the user to use it in a horizontal direction. 

Main Points of the Creative Design Contents 

Taking a folder type as a basic fonn factor, the present design emphasizes a smooth curve on the whole and 

expresses much simpler and more elegant sense of aesthetics. 

- 1 - 

SAMNDCA00255362



[Perspective View] 


[Frontal View] 

- 2- 

SAMNDCA00255363



[Rear View] 


OIJ!eoQIOO(II'.l 

~~OC'OOO 

ooooooaa 

~D'IJ~9 00 

DQOGo 00 o£1o(l 

[Left Lateral View] 

- 3 - 

SAMNDCA00255364




[Right Lateral View] 

@ 

[Plan View] 

€ ~ 

[Bottom View] 

( l J 

3 

[Informational Figure 1] 

oooooooooooo 

000000000 0 

OOOOOOOOCJ 

- 4- 

SAMNDCA00255365


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Telephone: (415) 875-6600 

Facsimile: (415) 875-6700 







Telephone: (650) 801-5000 

Facsimile: (650) 801-5100 





Telephone: (213) 443-3000 

Facsimile: (213) 443-3100 







18 



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JOBY MARTIN 

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Defendants. 

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02198.51855/4870485.1 



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EXHIBIT 9



NO. 684.001 



No. 11-CV-01846-LHK (PSG) 



Bar-type Touch-screen Display 

Bar- 

e 

Folder- 

e 

E700 

(3Q, '03) 

Before 

Flipper 

Mock-up 

(2006) 

Mock-up 

(2006) 

" Slide" 

Design 

(2006) 

"Vessel" 

Mock-up 

(Aug.2006) 

" Slide" 

Design 

(2006) 

1700 

(3Q, '03) 

Slide-type 

Blackjack 

(4Q, '06) 

T100 

(2002) 

Merit 

(2006) 

card3 "Wrap" Model "Framer" Model F300 

(2006) (Aug.2006) (Aug.2006) (Oct. '06) 

i830 

(Jan. '06) 

D908 

(Aug. '06) 

Bar-type 

Folder-type 

iPhone 

(Jan. 2007) 

U410 

(Oct. 2007) 

After 

F700 

(Feb. 2007) 

i8910 

(May 2009) 

Jet 

(Jun.2009) 

Impression 

(Apr. 2009) 

Replenish E590 Intensity 11 

(May 2011) (Jan. 2007) (July 201 O) 

Slide-type (TSD) 

U700 

(3Q, 2007) 

Gem 

(Feb.2011) 

GalaxyS2 

(2011 ) 

SCH-1500 

(2010) 

Gravity Touch 

(June 2010) 

Reclaim 

(Jan. 2009) 

Gravity 

(Nov. 2008)


EXHIBIT 10


Competitive MP3 Player Tear-Apart 

(w/ Bluetooth Capabilities) 

11/15/2011 iPod PD - Apple Confidential 

Highly Confidential - Attorneys' Eyes Only 

APLNDC0002230566

Samsung YP-R1 


• 2.6” TFT LCD 

• FM Radio 

• Bluetooth v2.0 + EDR 

(Supports music streaming, 

hands-free, and file transfer) 

• Aluminum / glass housing 



APLNDC0002230567

Samsung YP-R1 

• Bluetooth-enabled MP3 player 

- No other RF capability 


• Note: no cans or apparent forms of shielding 

MLB top side 

MLB bottom side 

antenna region 

BT chipset? 



APLNDC0002230568

Samsung YP-R1 


SUS plate 

Al housing 

antenna window 

antenna 



APLNDC0002230569

Cowon S9 


• 3.3” AMOLED w/ touch 

• FM Radio 

• Accelerometer 


(supports A2DP, AVRCP) 

• Plastic housing 



APLNDC0002230570

Cowon S9 


plastic housing 

shielding foil? 


opening for antenna 


MLB top side 

note: no apparent shielding beside foil tape 



APLNDC0002230571

Cowon S9 


2x NAND 

BT module 


(directly above NAND) 

removable 

2nd board 



APLNDC0002230572

Iriver Spinn 


• 3.2” AMOLED w/ touch 

• FM Radio 


(supports A2DP, AVRCP) 

• Magnesium / plastic housing 



APLNDC0002230573



Mg housing 

foil patch antenna? 

- 

spring contact to foil 

BT module 

(had can) 




APLNDC0002230574



note: no apparent form of shielding 


although these appear to be can 

tracks, nothing mates with them 

MLB top side 



APLNDC0002230575

Microsoft Zune HD 


note: no bluetooth, but included for 

reference due to minimal shielding 

• 3.3” OLED w/ touch 

• 802.11 b/g 

• FM & HD radio 

• Accelerometer 

• Magnesium / aluminum / glass / 




APLNDC0002230576



Al housing 

large gap in 

shielding 

can tracks 

conductive foam 

forms “can” 

between MLB 

bottom side and 

housing 

plastic 

antenna cap 





APLNDC0002230577



Mg frame and 

exposed side rails 

locally shielded 

RF module 

MLB top side 

note: no cans on MLB top side 




APLNDC0002230578


1 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 


Charles K. Verhoeven (Bar No. 170151) 




Telephone: (415) 875-6600 

Facsimile: (415) 875-6700 

Kevin P.B. Johnson (Bar No. 177129 


Victoria F. Maroulis (Bar No. 202603) 


555 Twin Dolphin Drive, 5 th Floor 

Redwood Shores, California 94065-2139 

Telephone: (650) 801-5000 

Facsimile: (650) 801-5100 

Michael T. Zeller (Bar No. 196417) 




Telephone: (213) 443-3000 

Facsimile: (213) 443-3100 



INC. and SAMSUNG 




 

 

 

 

 

 

 

 

 

 

 


vs. 








Defendant. 



EXHIBIT 11 TO THE DECLARATION 

OF JOBY MARTIN 

 


MANUAL FILING NOTIFICATION


1 

 

 

 

 

 

 

 









 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 



SULLIVAN, LLP 








AMERICA, INC., and SAMSUNG 


02198.51855/4871770.1 


MANUAL FILING NOIFICATION


EXHIBIT 12


Mini-Teardown: 

Samsung Galaxy S 

(T-Mobile Vibrant) 

iPod/iPhone New Tech 

8.10.10 

• Summary 

• Product Specs 

• Features 

• Disassembly 

• HW Components 

• Software Features 

• Additional Comments 

Wednesday, September 8, 2010 

APPLE CONFIDENTIAL BUSINESS INFORMATION, 

p2 

p3 

p4 

p5 

p10 

p12 

p13 

Contributors: 

Jeff Mehlman 


jmehlman@apple.com 

Ryan Garrone 


rgarrone@apple.com 

APL7940009836305 

SUBJECT TO PROTECTIVE ORDER

Summary 

Goals of Teardown: 

• Analyze the mechanical structure and components used 


• Examine software features and UI 

• Research reviews & issues 

Key Learnings/Observations: 

• Onboard GPU PowerVR SGX540 is very powerful: 90M triangles/sec vs. 22M triangles/sec on the Snapdragon 

• Uses the same CPU ARM core (Cortex A8) as the iPhone 4 

• International version has a front facing camera, but the US version does not 

• Bump-out at bottom of phone is for the antenna. Phone doesn’t feel right to hold 

• Power/wake button placement is poor (side vs. top). No other way to wake the phone. 

• Haptic feedback for capacitive button bar (settings/home/back/search) 

Outstanding issues/complaints: 

• Major issues w/the GPS exist - it does not work well. Supposed fix is in the works for November 

• Issues also exist with the filesystem - it is “not optimized” - utilizes RFS (Non-flash filesystem) 



APL7940009836306 



Product (Marketing) Specifications 

Key Features Swype, Social Hub (integrated SMS, email, calendar), Layar Reality Browser, USB Tethering 

Operating System Android 2.1, Modified UI (Eclair) 

CPU “Hummingbird” 1Ghz ARM Cortex-A8, onboard PowerVR SGX450 GPU 

Mass Storage Capacity 8/16GB + microSD (up to 32GB) 

Connectors USB 

Price 

AT&T: $199.99 w/2 year contract, $499.99 w/o 

T-Mobile: $199.99 w/contract, $499.99 w/o 

Dimensions 64.2 X 122.4 X 9.9 mm 

Weight 119g 

Display 4.0” WVGA(480x800) 16M SUPER AMOLED, Atmel MXT22 touch driver 

Battery Samsung LiPol 1,500mAh, 51x51x5mm 

Talk time: 391 minutes, Standby: 625 hours (3G network) 

Camera 5.0 Megapixel AF camera, HD record @ 720p 

Audio Compatible Format MP3, AAC, AAC+, eAAC+, OGG, WMA, AMR-NB, AMR-WB, WAV, MID, AC3, IMY, FLAC, XMF 

Video Compatible Format 

HD Video Player & Recorder 720p @ 30fps 

supported codecs: DivX, XviD, MPEG4, H.263, H.264, WMV, VC-1 

Wireless 

WAN: HSUPA 900/1900/2100 , EDGE/GPRS 850/ 900/1800/1900 

LAN: WiFi 802.11b/g/n, Bluetooth 

Sensors Light, Accelerometer, GPS, Proximity, Digital Compass, multi-touch display 


APL7940009836307 



Micro USB w/door 

Speaker 


Volume buttons 

Phone Features 

Light sensor 

Location of front 

facing camera on 

international version 

(not pictured) 

Super AMOLED 4.0” 

WVGA(480x800) 

Samsung Touchwiz 

UI 3.0 (Android 2.1) 

Location of antenna 

(weird lip) 

Capacitive 

Touch buttons 



Power/wake/ 

sleep button 5MP Camera 

3.5mm jack 

APL7940009836308 



Disassembly (1) 



Step 1: Remove back cover 

Step 2: Remove battery 

APL7940009836309 




Step 3: Remove mid-housing 

Step 3a: Remove antenna 

Antenna back Antenna front 

Mid-housing back Mid-housing front 


APL7940009836310 





Loudspeaker 

Touch/Display assembly + 

audio i/o 

SD SIM 

Step 4a: Lift SD, SIM, 

loudspeaker daughterboard 

Antenna 

sprung 

contacts 


Step 4b: Remove 

multi-PCB assembly 


PCB Assembly Front PCB Assembly Back 

APL7940009836311 



Micro USB 

Battery contacts 


Camera module 

Step 5: 

Separate submodules 

PCB Assembly Front 

Loudspeaker 



*With camera 

team for further 

analysis 

SD/SIM cards 

Main PCB Module 

Push button 

Volume buttons 

Metal can removed 

APL7940009836312 


Hole for ALS 


Display/touch driver 

flex 


Magnesium 

body 

*With display 

team for further 

analysis 

3.5mm jack Speaker 

Step 6: Touch/ 

Display/Audio I/O 

assemblies 


audio i/o 

Antenna 

sprung 

contacts 



Vibration 

Motor 

Microphone 

Hole for front facing 

camera 


microphone, vibe motor 

APL7940009836313 


1. TriQuint TQM676021 

WCDMA / HSUPA Band I Tritium III PA Duplexer Module 

2. Infineon 5703 

PMB 5703 SMARTi UE 



WCDMA/HSUPA PA-Duplexer Module 

4. Epcos D1056 

HW Components (1) 

8 

5 

7 

Top PCB 


? 


WCDMA / HSUPA Band II Tritium III PA Duplexer Module 

6. TriQuint TQM6M9014 

Quad-Band GSM / GPRS / EDGE-Linear TRP Tx Module 

7. Wolfson Micro WM8994E 

Digital audio codec 

8. FA052523A 

? Possibly Broadcom BCM4329FKUBG WiFi, Bluetooth, FM 


9. Atmel MXT22 

Touchscreen driver 

6 

3 

BGA735 

4 

1 

2 

9 

APL7940009836314 



HW Components (2) 

4 

1 

3 

2 

7 

Bottom PCB 



5, 6 

1. Broadcom GPS 

2. Samsung KLMAG8DEDD 

moviNAND, 16GB 

3. Maxim MAX8998 

Power management IC 

4. Infineon 8824 

Infineon X-GOLD 61x Baseband processor 

5. Lower chip: Samsung KB100D00WM-A4 

Hummingbird Cortex A8 processor 

6. Upper chips: KB100D00WM-A4 

KFG8GH6Q4M (8 Gb of OneNand), 

K4X2G323PB (2 Gb of DDR SDRAM), 

K4X1G323B (1 Gb of DDR SDRAM). 

7. Accelerometer? 

8. NEC MC-10170 

Camera processor + memory 

8 

APL7940009836315 



Software Features 

Samsung Touchwiz UI 3.0 

Custom skinned Android 2.1 operating system 

Youtube 



Swype (Beta) 

3rd party application, still in 

beta version for Android 

Drag-to-text keyboard input 

software 

Up to 40 words per minute 

Social Hub 

Samsung widget 

Integrates all messaging 

streams into one 

APL7940009836316 



Additional Analysis 

Display team teardown underway 

• Camera module handed off to camera team week of 8/2. Awaiting 

report 


APL7940009836317 




EXHIBIT 13


Samsung Galaxy Tab 10.1 Take-Apart 

iPad PD - 5/24/2011 


Saturday, February 11, 2012 


APLNDC0002868532

Key Features 


Enclosure Type 

Display Details 

Dimensions 

Molded plastic back and sides, 

glass screen, Magnesium Chassis 

1280 x 8000 WXGA 10.1” 1080p 

PLS 

256.2 x 172.9 x 8.6 mm 

Weight 

595g 

Battery 

3.7V Li-ion, 25.90Wh / 7000 mAh 

Storage Size 

Physical I/O 

Wireless 

Camera Details 

16/32 GB 

proprietary connector similar to 

Apple 30-pin 

802.11 a/b/g/n with dual 

antennas 

3MP Rear / 2MP Front 

Feedback 

Linear Vibe Motor 




APLNDC0002868533


Samsung Galaxy Tab 10.1 vs iPad 2 Spec Comparison 

Samsung Galaxy 10.1 

K93/4/5 

256.2 x 172.9 x 8.6mm 241.2 x 185.7 x 8.8mm 

595 g 601 - 613g 

10.1” 9.7” 

1280 x 800 1024 x 768 

16/32 GB 16/32/64 GB 

7000 mAh 6570 mAh 

4G (HSPA+) 

3G 

802.11 a/b/g/n 802.11a/b/g/n 

2/11/2012 iPhone PD - Apple Confidential 



APLNDC0002868534

Product Disassembly 


1. 2. 

3. 

1. Silver caps are glued to screw tops. 

2. Two screws secure cover to chassis. 

3. Cover unsnaps from chassis. 

4. Cover can now be removed. 

4. 




APLNDC0002868535

Battery Removal 


Battery is taped to a plastic carrier. 

Label cells, BMU, 6pin connector 

The plastic carrier is screwed to the chassis. 

Number of screws, interesting 

things about their position? 




APLNDC0002868536

Galaxy tab critical z-stack 


Flex (0.10) 

Plastic Back (1.1) 

Total Thickness: 8.6mm 

Show DG as 0.2mm, list total air gap 

of 0.3mm, flip 180deg so that glass is 

on top. 

M-chassis (0.19) 

Reflector (0.18) 

Battery holder (3.45) 

Polarizer (0.20) 

TFT (0.25) 

CF (0.25) 

Polarizer (0.20) 

Film 2 (0.07) 

Film 3 (0.05) Light Guide (0.79) 

BEF (0.15) 

AR Layer (0.03) 

Ditto Layer 2 (0.09) 

Ditto Layer 1 (0.13) 

Dust gasket (0.5) 

Glass (0.87) 




APLNDC0002868537

K93 vs Galaxy Tab critical stack 


Ask Raff for K94 critical stack 




APLNDC0002868538

Comparison of LCD stackup to K93 





APLNDC0002868539

K93 battery specs vs Galaxy Tab battery specs 


Galaxy Tab 

K9x 

Thickness 

3.5 2.83 

Length 

78.3 115 

Width 

232.1 197.5 

Capacity 

7000 6570 

add pictures of batteries 




APLNDC0002868540

Galaxy Tab 10.1 | Component Overview 


LCD MLB Battery Module 

Glass, Grape, AR Film 

Mag Chassis 

Back Cover 




APLNDC0002868541

Interesting Features- Two Layer Plastic Ditto 


One layer has X-axis sensing, the other has Y-axis sensing. 

Ditto thickness? 

Traces from both 

layers extend into flex 




APLNDC0002868542

0.03mm AR Film, One piece Dust Gasket 


Although thin, this layer is surprisingly strong 

Single piece dust gasket 

thickness? 

How far is the DG 

from the active area? 




APLNDC0002868543

Board on flex, similar to desktops 


Comments needed from Derek 




APLNDC0002868544

Screw down cans with conductive tape 


Comments needed from Alex 

Cans screw to 

MLB, no fence 

required. 

Conductive tape blocks EMI, 

peels away for rework 




APLNDC0002868545

Antenna integrated with cover 


Comments needed from Erik 

push pins form 

connection with 

metallized 

portion of cover, 

used as an 

antenna 




APLNDC0002868546

Compact speaker geometry 


Comments needed from Alex 

Compact speakers project 

sound directly at metal plate, 

sound port is perpendicular to 

speaker orientation. 




APLNDC0002868547

Linear actuator mounted on speaker 


Comments needed from Steve 

Linear actuator integrated 

with speaker housing 




APLNDC0002868548

Unsealed 3.5mm Audio Jack 


Comments needed from Raff 

Holes in audio jack 

would permit fluid 

entry to product 




APLNDC0002868549

Camera LED Fash on Fex 


Comments needed from Conor 

3MP Rear Cam 

2MP Front Cam 

LED Fash 

onfex 




APLNDC0002868550

Tape on cover for flatness 


Comments needed from Steve 

Tape around flexes helps to 

keep the thin plastic cover flat. 




APLNDC0002868551

Chassis has plastic antenna window 


Comments needed from Kevin 




APLNDC0002868552

Folded metal camera bezel 


Comments needed from Conor 




APLNDC0002868553


EXHIBIT 14

Pr$.ved by: IPhooe Finance Te• m 

OEM 

_ 

HANDSET MODEL 

Note: not exhaustive 

i Phone (3G) 

iPhone 

0 m 

:< 

.... 

~ 

~ m 

z 

m 

.- 

.- 

-< 

(") 

(J) 

71 

U1 

... 

"' 

U1 

I I r 

J 

GENERAL 

SIZE 

DISPLAY 

RINGTONES 

MEMORY 

DATA 

FEATURES 

BATTI!RY 

2G Network 

3G Network 

Announced 

Status 

Dimensions 

Welaht 

Type 

Size 

Type 

Size 

VIbration 

Phonebook 

call record• 

C:.rd slot 

GPRS 

HSCSD 

EDGE 

3G 

WLAN 

Bluetooth 

Infrared port 

USB 

OS 

Mess-ulng 

Browser 

G•m•• 

Colo,. 

camera 

Other 

Stand-by 

Tatktlme 

GSM 850 I 900 I 1800 I 1900 

HSDPA 850 I 1900 I 2100 

2008. June 

ComlnQ soon. ~xp . release 2008, July 

115.5 x 62.1 x 12.3 mm 

133 Q 

Touchscreen, 16M color s 

320 x 480 pixels. 3.5 Inches 

- Mu l~·touch Input method 

• Accelerometer sensor for auto-rotate 

- ProximitY sensor for auto tum-off 

- Ambient llaht sensor 

Polyphonic, MP3 

Download 

Yes 

- 3.5 mm headset lack 

Practically unlimited entries and ftelds, 

Photocall 

100 received, dialed and missed calls 

No 

- 8/16 GB shared memory 

Yes 

No 

Yes 

HSDPA 

Wi-FI 802.11b/a 

Yes, v2.0, headset support only 

No 

Yes. v2.0 

Mac OS X v10.4 . 10 

SMS, ~mall 

HTML CSafar1) 

No 

Black(B/16 GB). White (16GB) 

2 MP. 1600xl200 pixels 

• Built-In GPS receiver 

- A·GPS function 

- Gooale Maps 

- Wldaets support 

- IPod audio/VIdeo plover 

- PIM lncludlna calendar, to·do list 

-TV output 

- Photo Browser/editor 

- Voice memo 

• lnteqrated handstree 

Standard battery, Ll-lon 

Up to 300 h 

Up to 10 h 

GSM 850 I 900 I 1800 I 1900 

2007. January 

Available. Released 2007, June 

115 x 61 x 11.6 mm 

135 Q 

Touchscreen. 16M colors 

320 x 480 pixels, 3.5 Inches 

- Multi-touch Input method 

- Accelerometer sensor for auto-rotate 

- Proxlmitv sensor for auto turn-off 

Polyphonic, MP3 

Download 

Yes 

- 3.5 mnn headset lack 

Practically unlimited entries and fields, 

Photocall 

100 received, dialed and missed calls 

No 

- 4/8/16 GB shared memory 

Yes 

No 

Ye s 

No 

WI-FI 802.1lb/a 

Yes, v2.0, headset support onlv 

No 

Yes. v2.0 

Mac OS X vl0.4.8 

SMS, Email 

HTML (Safari) 

No 

Black 

2 MP, 1600xl200 pixels 

- GoOQie Maps 

- Wldaets support 

- IPod audio/video player 

- PIM lncludina calendar. to-do list 

-TV out:out (firmware 1.1.1) 

- Photo Browser/editor 

- Voice memo 

- lntearated handsfree 

Standard battery, U·lon 

Up to 250 h 

Up to 8 h 


•o 



APL7940014663269

Note: ttOl exn.ustlve 

N95 (8G8) N95 N78 N81 (8GB) N81 6600 Slide 

~ 

·• 

~ 

~~ .... ~ 

~ 

GfNI!.ItAL 1G Netwottl GSI't 8SO I 90011800 /1900 GSM 850 I tOO /1800 I 1900 GSM 850/900/1800/1900 GSM 850/900/1800/ 1900 GSM 850/900/1800 I 1900 GSM 850/900 I 1800/1900 

3G HMwOftl HSOPA 2100 HSOPA 2100 HSOPA 2100/900 UHTS 2100 UHTS 2100 UMTS 850/2100 

HSOPA 850 1 1900 - US vtrsron HSOPA 850/1900 - US version HSOPA 850/1900 - US version 

Announce4 2007. Auoust 2006. Seotember 2008. Febi'Uarv 2007. Auoust 2007. Auaust 2008. Ao11l 

StAtus Av.thbltt ReMo.utd 2007. Oc:to~r Avilllable R«le.ued 2007. March Av1Yible Release

Note; not exMu~fVe 

E90 

COMING SOON 

N96 

COMING SOON 

E66 

GINtltAL 2G N.twortc GSM 850 I 900 I 1800 I 1900 

.JG H.twoftl HS09A 2100 

Announc.d 2007. Februarv 

Status 

Av•llabl•· Released 2007. Jvnft 

.... Ol~•on• ll2 x 57 x 10 mm. 140 a: 

110 0 

DIS"-AY ..... -·· 

TFT. 161'4 CX)Iors 

&oo x J SZ ohcets. • Inches 

-Second extern I I 16M c olors d iSp&ay 

(240 x 120 phl:ets), llnches 

A llt'NIIF"IITY iuo~ 

tuHGTOHlS .... ~ (64 channels}, Mlo>J 

C:Uatomltatlon Download 

VUw• tton 

Yto 

MlMOA'f' "*'•book Pr«:dutt; unlamltad entrtes •net fields. 

Ptlolocol 

C::.lt NCOrdt Cetal!od. max 30 davs 

.......... mk:roSC (ll'ansf'fast'l), up to 8GB, 

hotsw~, buy memory 

- 128 Me ~red memono 

• JJO MN: ARM Of"OGfiUOr 

..... DATA Yes 

ltiCSD 

•• 

lOG I 

v •• 

... 

-- 

HSDPA. 3.6 Mbos 

W

a 

a 

OEM 

HANDSET MODEL 


GENERAL 

SIZE 

DISPLAY 

RINGTONES 

MEMORY 

DATA 

FEATURES 

BATTERY 

2G Ne twork 

3Ci Network 

Announced 

Status 

Dlmen.elon• 

Welaht 

Tvoe 

Size 

Tyge 

CustomlzaUon 

VIbration 

Phonebook 

Call reccwd• 

C.rdalot 

GPRS 

HSCSD 

EDGE 

3G 

WLAN 

aluetooth 

lnh'arec:l port 

usa 

OS 

Me.a.olna 

erow•er 

G11mes 

Colora 

Camer• 

Other 

Stand•bv 

Talk time 

8820 

Same ~s 8800 but lncl WIFI 

GSM 850 1900 I 1800 11900 

2007. Julv 

Available 

114 x 66 x 14 mm 

134 Q 

65K cnlors 

320 x 240 Dlxels 

• Full OWER.TY kevboard 

• Trackball naviQatlon 

Polvohonlc. MP3 

Yes 

Yes 

Yes 

mlcroSO (Transflast!), buy memory 

• 64 MB nash memorv 

· 16MB SIIAM 

Yes 

No 

Yes 

No 

Wlfl B02.11bla 

Yes. vz.o w A2DP 

No 

Yes. m lniUSB 

Black.Berrv OS 

SMS. MMS, Email. Instant Messaolna 

WAP 2.0/xHTML. HTML 

• order now 

Stiver 

No 

• BuiiHn GPS navigation with 

BlackBerrv Maos 

- Java 

- Medlo player 

• Oroanlzer 

- Built· In handsfree 

·to-do list 

• document vtewer (Microsoft Word, 

EKcel and PowerPoint, Corel 

WordPerfect and Adobe POF) 

· Voice dial 

Standard batterv. Ll-lon 

Uo to 530 h 

Uo to 5 h 

8800 

GSM 850 I 900 11800 I 1900 

2007. Februarv 

AvaUable 

114 x 66 x 14 mm 

134 0 

65K colors 

320 x 240 oixels 

a Full OWERTY kevboard 

a Trackball navlaatlon 

Polvohonic. MP3 

Yes 

Yes 

Yes 

mlcroSO (TransFiash), buy memory 

64 MB nash memorv 

- 16 M8 SRAM 

Yes 

No 

Yes 

No 

No 

Yes. v 2.0 

No 

Yes. mlniUSB 

BlackBerrv OS 

SMS. MMS, Email. Instant M essat~~na 

WAP 2 .01xHTML. HTML 

• order now 

Sliver 

No 

- Built-In GPS navigation with 

BlackBerry Macs 

·Java 

~ Media player 

- Oraanlzer 

• Built-In handsfree 

- to·do list 

document viewer ( Microsoft Word, 

Excel and PowerPolnt, Corel 

WordPerfect and Adobe PDF) 

-Voice d ial 

Standard batterv. U -lon 

Uo to 530 h 

uo to s h 

Curve 8310 

Note: 8300, 8320 don 1 t have GPS 

r--1 

II 

GSM 850 I 900 11800 I 1900 

2007. Auoust 

Available 

10? x 60 x 15.5 mm 

111 Q 

65K colors 

320 x 240 otxels 

- Full QWERTY kevboard 

- Trackball navlaation 

- Walloaoers 

PolvDhonlc (32 channels). MP3 

Download. order now 

Yes 

Yes. Photocall 

Yes 

mlaoSO (ll'ansF1ash), buy memory 

- 64 MB flash memorv 

Yes 

No 

Yes 

No 

No 

Yes. v2.0 with A20P 

No 

Yes. mlniUSB 

61ack8errv OS 

SMS. MMS, Email. Instant Messaolna 

HTML 

Yes + downloadable. order now 

Sliver 

2 MP. 1600x1200 Dlxels. nash 

- Integrated GPS 

·Java 

- Mec:Na player 

- BlackBerrv Maos 

- Oraantzer 

- calculator 

- Vok:e dial 

- Built-In handsrree 

- to-do list 

Standard battery, U ~ Ion 1100 mA.h 

uo to 408 h 

Uo to 4 h 

Pearl8110 

Note: 8120 doesn't have GPS 

GSM 850 I 900 I 1800 I 1900 

2008. Januarv 

Available. Released 2008. Januarv 

107 x Sox 14 mm 

910 

6SK colors 

240 x 260 Dlxels 

• OWERlY kevboard 

• Walloapers 

P

OEM __ 

HANDSET MODEL 

Note: not exhausdve 

GENERAL 

SIZE 

DISPLAY 

RINGTONES 

MEMORY 

DATA 

fEATURES 

BATTERY 

2.G Network 

3G Network 

Announced 

Status 

Dlmen .. one 

Weloht 

Type 

Size 

Type 

cuatomlutlon 

V'bratlon 

Phonebook 

C.lt record• 

car

OEM 

HANDSET MODEL 

Note: not exMustfve 

1900 Om nia 

F480 

Samsuna Tocco 

F490 G810 1640 

G!NlltAL 

SIZE 

DISPLAY 

RJHOTONES 

MEMORY 

DATA 

fEATURI!:S 

aATnRY 

2C Network 

lG Network 

AnnourK:ed 

StatUI 

Dlmenllona 

Weloht 

Type 

Slz• 

TVIMI 

Cwatomlzatlon 

VIOmkm 

Phonebook 

C .. I recorda 

C•f'CI slot 

CiPRS 

HSCSO 

~OCiE 

3G 

WLAN 

-.IYetooth 

tnfrar.d PGrt 

usa 

OS 

.. _ 

... 

Mu .. glng 

G•me• 

Colors 

camw• 

ott .... 

Stand· l>'f 

Talk ttme 

GSM 850 19001180011900 

HSDPA 850/1900/2100 

2008. June 

Comtna soon. Exa, release 2008. June 

112 x 56.9 x U .S mm 

127 0 

TfT touchscreen, 256K colors (651< 

etrea:lvel 

240 x 400 olxels. 3.2 Inches 

- Accelerometer sensor tOt' auto-rotate 

• Handwt1Una recoanittoo 

PolvDhonlc. MPJ 

Download 

Yes 

Practlally unllrrUted entries and nelds, 

Pnotocotl 

Pracdcallv unltmlted 

mlaoSD (TransF1ash}, up to 8GB 

- 128MB RAM. 256 HB ROM 

- 624MHz Marvell PXA312 processor 

- 8 GB/Ui GB Internal memorv 

aess 12 (4+1/3+2/2+3/1+4 slots), 32 

- 48 kbos 

No 

OISS 12 

HSOPA. 7.2 Mbos 

wt-FI 802.llb/Q 

Yu. v2.0 with A20P 

No 

Yes. v2.0 

Microsoft Window Mobile 6.1 

Professional 

SHS, EMS, HHS, Email, lnstant 

Me:ssaQina 

WAP 2.0/ICHTML. HTML, RSS feeds 

Yes + Java downloadable 

Sll'¥'er 

S MP, 2592x1944 phuels, ~utotocus, 

Image Stllblllser. VJdeo, nuh; 

secondlrv vldeoc:all cam era 

• 8ultt•ln GPS recello'er 

- Java MlOP 2.0 

.. FM Radio w it h ROS 

- MS Office doOJment viewer/editor, 

PDF viewer 

• MPJIAAC/AAI;+IWMA/OGG/AMR 

Olaver 

• OtvX/XVID/WMV/MP4 olaver 

· lV out 

·Voice memo 

• 8ullt·ln handsfree 

Stand•rd batterv. U-lon 1440 mAh 

Uo to 500 h 

Up to S h SO mJn 

GSM 900 /1800 I 1900 

HSDPA 2100 

2008. Feb ruarv 

AvaltabiP Released 2008. Mev 

98.4 x 55 x 11.6 mm 

100.60 

TfT touchscreen, 256K colors 

240 x 320 ohtels. 2.8 Inches 

Polvohonlc !64 channels), HPJ 

Download, order now 

Yes 

1000 entnes, Photocall 

30 dialect 30 received. 30 missed calls 

mlcroSD (lransFiash), up to 8GB, buy 

m emorv 

- 232 Mil or k'lttmat memON 

Closs 12 (4+113+2/2+311+4 slots), 32 

• ~ kbos 

No 

Oass12 


No 

Yes. v2.0 with A2DP 

No 

Yes v2 0 

SMS, EMS, HMS, Email, Instant 

MessaQfna 

WAP 2.0/xHTML, HTML 

Yes. order now 

Black 

5 MP, 2592JC19« phc.e:ls, autotocus, 

vtdeo(QVGA), ft..sh 

- Java MJOP 2.0 

- H.264/H.263/MPEG4 olaver 

- MPJ/AAC/AAC+ player 

• Camera hlce detection 

- FM Radio with ROS 

• Oraanlser 

- document viewer 

- euUt-ln handsfree 

st•n~rd batterv. U-l on 1000 mAh 

Uo to 250 h 

Uo to J h 

GSM 900 11800 I 1900 GSM 900 I 1800 I 1900 GSM 9001180011900 

HSOPA 2100 HSDPA 2100 HSDPA ::UOO 

2008, Januarv 2008. Febroarv 2008. Februarv 

Available. Released 2008, March Available. R.eleast'd 2008. Aor11 Available. Released 2008, Febi"'Uerv 

US x 53.5 x 11.8 mm 103 • 52.9 x 17.9 mm 94.4 x 61 x 16.9 mm 

102 a 1390 148 0 

TFT touch5aeen, 256K c:olors TFT, 2561< t:olors TFT, 651< colors 

240 x •32 olxels. 3. 3 lncheSJ 240 x 320 abtels. 2.6 Inches 320 JC 240 olxe-ls. 2 .4 Inches 

• QWERTY keybo•rd, Jog dlol 

Polvohoolc. MPl Pol'¥'DhDnlc, HPJ Potvohonk: f40 ehennelsl. MPJ 

Do.,.nload. order now Download, order now Download. order now 

Yes Yes Yes 

1000 entries, PhotouU Praa.lcally unltmlted entnes and fields, Practlally unlimited entries and f ields, 

Photocall 

Photoc:att 

30 dll~d. 30 received. 30 m l$$ed calls Detailed. maJC 30 davs PractJc.llv unlimited 

mlcroSD (n"ansFiash), buy memory m!croSO (TtansFlash), buy memory mlcroSD (TnmsAash), buy memory 

• 130 MB shared memorv • 130 MB shared memorv • 128>18 ROM. 64MB AAM 

- 330 MHz ARM1136 processor (n 

OMAP 2430 chlosetl 

Class 10 (4+113+2 slots), 32 • 48 kbps Class 10 (4+113+2 slots), 32 - 48 kbps Closs 10 (4+1/3+2 slots), 32 • 48 kbps 

No No No 

Oass 10. 236.8 kbos Oass: 10. 236.8 kbDS Oass 10. 236.8 kbos 

HSOPA, 3.6 M bos HSDPA, 3.6 Mbps HSDPA. 3.6 Mbps 

No WI-A 802.11 blo No 

Yes , v2.0 with A20P Yes v2.0 with A20P Yes. '¥'2. 0 with EOA. 

No No No 

Yes: v2.0 Yes v2 0 Yes vl.l 

Symbion OS v9.2, Ser1es 60 rei. 3.0 Miao50ft: Windows Mobile: 6.0 Standard 

SMS, EHS, MMS, EmaH, Instant SMS, MMS, Email SMS, MMS, Email, Instant Messoglng 

Messaolna 

W~ 2.0/xHTML. HTML (Netfront 3.4) WAP 2 .0/JCHTML, HTML. RSS reader WAP 2.0/xHTML... HTML. RSS teeds 

Yes. order now Yes + downla.dable. order now Yes. order now 

Black ntan Grev 51!'¥'er 

5 HP, 2592 lit 1944 pixels, autofocus, 5 MP, 2S60X1920 pints, autotoc:us, 2 MP, 1600xl200 pb:ets, vk:Jeo; 

Vlde.o(QVGA. lSfps), nash; secondary race detecdon, vkleo(VG~). xenon secondary VGA vldeoc.a11 camera 

v ldeocall camera 

flash. JJC octlcal zoom 

• lava MIOP 2 .0 - euut-ln GPS receiver • Java MIOP 2.0 

• 3.Smm audio lack - Navlaon GPS na'

I.SMtsuna. 

OEM 

HANDSET MODEL i617 BlackJack 11 

Note: not exhaustflle 

i780 

F700 

G!Nt:IU.L 2G NetwCM'k GSH 850/900 /1800/1900 

JG Network HSDPA 850/1900/2100 

Announced 2007. October 

Statue 

Available 

SUI! Dimensions U4x61x13mm 

W•klht 

116 a 

DISPLAY Type TFT, 6Sk colors 

Sin 

320 k 240 Dixels. 2.4 Inches 

• QWERTY keyboard 

RINQTONt:S Tvoe Poi'¥'DhOniC C40 channels1. HPJ. WAV 

Ct.latomlutJon Download, order now 

Vibr•tlon y .. 

MI!MORY Phonebook Pntctlc.ally unlimited entries and nelds, 

Photocall 

CeUrecord• Pntctlc:aUv unlimited 

catd slot mJaoSO (TransFiash), up to 4 GB 

soooorted, buv m.t!!morv 

- ROM 256 M8. RAM 128MB 

- DUll Core ARM 9 (260 MHZ) 

orocessor 

DATA GPRS a ... 10 (4+1/3+2 ~ots), 32 -48 kbps 

HSCSD 

EDGE 

JG 

WLAN 

aauetooth 

lnfr.,.dPOrt 

No 

Oass 10. 236.8 kbos 


No 

'r'es. v2.0 with A lOP 

No 

usa 'r'es. v2.0 

fQTURtS OS Mlc;rosot't Window s Mobile 6.0 

&ATTI.RY 

M .. Nglng 

arow•er 

GaMe• 

Co Iori 

c ....... 

Other 

Stand-bY 

Talk tim• 

SHS, EMS, HHS, Emall, lnsc.nt 

HenaaJno 

WAP 2.0/)cHTML. HTHL, A.SS (t:eds 


Slack 

2 MP, 1600xl200 p!.)l'el$, video 

~ Bullt~ln GPS receiver 

• Mobile TV recel11er 

- Java support fOf' el)f)lkatlon 

OownfOad 

- WMVIJGP/H.263/MPEG4 player 

- WHA/MP3/AAC/AAC ... /OGG/ASF 

olaver 

- Oroanlser 

- document viewer (MS Word, Exr;el, 

PPT. POFl 

- 8ui1Nn handsfrH 

Standard battery, U-lon 1700 mAh 

UD t o 330 h 

Up to 7 h 

GSH 900 /1800 I 1900 GSM 900/1800/1900 

HSOPA 2100 HSDPA 2100 

2007. Seotemoer 2007. Februarv 

Available. Released 2008, Februarv 

Available. Re~ e ased 2007. December 

115.9 k 61.3 x 12.9 mm 112 x 56 x 15.9 mm 

120a 139. 

TFT touchscreen, 65K colors 

TFT touchsaeen, 256K colors 

320 x 320 olxels, 2.55 lnc.hes 240 x 440 olxels. 3.2 Inches 



Polvohonlc (64 channels), HPJ 

Downloa d, order now 

Ye< 

Pntctk.ally unlimited ent:nes and fte1ds, 

Photo call 

Pntctlc.allv unlimited 

mlcroSD (Trl!nsFiash), buy memory 

256MB ROM and 128MB RAM 

Polvohonlc. MP3 

Download. order now 

Yes 

1000 entnes, PhotocaU 

30 dialed, 30 received. 30 missed cells 

mlcroSD (l'l"ansflash), buy memory 

- 112 MB Shared memorv 

Clus 10 (4+1/3+2 slots), 32 - 48 kbps Class 12 (4+1/3+2/2+3/1+4 SlOtS), 32 

- 48 kbps 

No 

No 

O•ss 10, 236.8 kbDS Oass 12 

HSOPA. 3.6 Mbps 

HSOPA, 3.6 Mbps 

WI-A 802-110/0 

No 

'r'es. v2.0 with A2DP Yes. ~2 . 0 with A20P 

No 

No 

Y•s 

Yes 

Microsoft Windows Mobile 6.0 

Professional 

SMS, MMS, EMail, Instant Messaging SMS, fHS, MMS, Email, Instant 

HessaaiOQ 

WAP 2.0 I HTML, Ooel'il Mobile 8.65 

WAP 2.0/xHTML, HTML 

Yes, order now 


Bl•dt 

Block 

2 HP, l600x1200 pixels, vtdoo, 3.15 MP, 204811.1536 pixels, autofocus, 

secnndary VGA vldeOc:all camera 

nash, ~ldeo; secondary VGA vtdeoaM 

camera 

- Java MI OP 2.0 - lava MJOP 2.0 

- Built•ln GPS navloatlon - H.26 ../ H.263/MPEG4 ola~er 

• A·GPS support 

• MP3/AAC/AAC+ player 

- Finger Mouse - Organlser 

- Side bar - Google Maps 

- MS Otrk:e Mobile - document ~er 

-Voice memo 

- Bullt·ln handstree 

- C.llla olaver. Callla Reader 

-Photo Slides 

- Search 

- SmertConverter 

- Mini olaver 

- Windows Medle ola~er 

Standard batterv. U-lon 1480 rnAh 

Uo to 400 h 

Up to 7 h 

Standard batterv. U -lon 1000 mAh 

Uo to 300 h 

Up to,. hJOmln 




APL7940014663275

OEM LHTC 

HANDSET MODEL 

Note: not extMusrtve 

GENERAl. 

SUI 

0151'\.AY 

RINGTONeS 

MIMOAY 

DATA 

FIATURU 

&ATTIItY 

2G Network 

3G "-work 

.......... 

St M:u s 

DlMMslons 

we .. ht 

Type 

SIJo 

TyP4 

CUMOMiutkm 

Ylbf'lltlon 

PhoMbook 

C.ll record a 

C.nt .. ot 

G ... I 

HSCSO 

EDC.I 

3G 

W LAN 

~u«ooth 

l nfrw .. IMH"l 

U A 

OS 

.. __ 

........ ,.. 

a 

Oc/Asla 

HSDPA 850 I 1900 ror ArneritU 

2008. Mfv 

AYIIIIblt. Rtieestd 1008. Mav 

102 x 51 x u .s mm 

ltO a 

TFT toochscreen, 6Sk wk)rs 

480 x 640 ~xels. 2.8 lnd1es 

- TouthFLO JD t'lnoer swloe na'licwtion 

• Acuterometer sen101 for .uto·rot.te 

• touch-wnslttve ntviOflth)n atntrds 

- ~andwtttlna rec:oanltlon 

PolyphOnic (40 Channels), MPJ, WAV, 

WMA 

Dow~. oroer now 

y .. 

Prtct~ultv unVm.ted entnes and netds. 

PhOt:oall 

PrKtlcallv unlimited 

No 

- 4GB user avaUtblo rMmorv 

- 192 M8 OOR SOAAM, 256MB ROM 

- QutiO>mm MSM7201A 528 Mht 

orocessor 

Cess 10 (4+1/JU Slots). 32-48 t(bos 

NO 

Clus 10. 236.8 t(bos 

HSOPA. 7.2 MbPI 

WHJ 802.11 blo 

Yu. v2.0 vrnth A20P 

No 

Yes mlniUSB 

MICrosoltWindOWI Hobtle 6,1 

Prof.ssiOnol 

SMS, MMS, Etn~!l, lnst1nt Messoqlnq 

WAP 2.0/)(Hl'ML. HTML 

Yes. ORI«now 

lll>

OEM 

HANDSET MODEL 

Noce: nor «.m•u.JCI've 

TyTN JI 

Older T'vTN nu no GPS 

GINIIU.L 2G M

OEM 

- 

HANDSET MODEL KF750 Secret 

--- 


i 

GENERAL 2G Network GSM 900 I 1600 I 1900 

3G Network HSDPA 2100 

Announced 2008, Ap

Sonr 

r.nm 

OEM 

HANDSET MODEL 


GENEAAI. 

1G Network 

:JGHetwork 

A.rmouneed 

StatUI 

Olmen•lone 

Woklht 

SW! 

DISPlAY ,..... 

Slzo 

RINGTONES 

MEMORY 

DATA 

FI!ATUR£5 

IIATT1!RY 

Tvoe 

CuRoml.utlon 

V~•tlion 

P'honebook 

Callr.cord• 

Canl -'ot 

GPRS 

HSCSD 

£00£ 

, .. 

WI.AN 

alr.Mtooth 

Infrared port 

usa 

OS 

Meuag&ng 

•rowMtt 

G•me• 

c-.. 

c ......... 

01- 

Stond•by 

Talk time 

XPERIAX1 

GSM 850 I 900 11800 I 1900 

HSOPA 850/1900 I 2100 

2008. Februarv 

ComlnQ soon 

uo.s x 52.6 11: 17 mm 

158 a 

TFT touchscreen. 65K colors 

800 x 480 oixels. J lnd\es 

-full QWERTY keYboard 

- OodQt 1ovstlek navlaatlon 

PolvPhonic, HPJ 

Comooser. downl~d 

Yes 

Practically unlimtted entne5 and rtetds, 

PhotJX.atl 

Pr3ctlcallv unlimited 

mk::rOSO (Transflash) 

- 400 MB Internal memorv 

-256MB RAM. 512MB storaoe memorv 

• Qualcomm MSM7200 528MHl 

orocessor 

Ou.s 10 f4+1/3+2 slotsl. 32-48 kbos 

No 

Yes 

HSOPA, 7.2 Mbps 

WHl 802.Ub/Q 

Yes. v2.0 with A20P 

No 

Yes . v2.0 mlniUSB 

Mi.;rosoft Windows Mobile 6.1 

Professional 

SMS, MHS, Email, Posh E·Mall, 1M 

WAP 2.0/HTML (IE). RSS feed s 

Yes + downtoadable 

SoUd a.adc. Steel Sliver 

3. 15 MP, 204Sx1536 plxefs, autorocus, 

vldeo(VGAGIJOrps), nash; secondary 

video"' 380 h 

UDto9h 




• 

APL7940014663279


EXHIBIT 15


Subject: Fwd: Tablet Competitive Update July 7th, 2011 

Date: Thu, 07 Jul 2011 23:24:27 +0000 

From: "evans hankey" 

To: "Eugene Whang" , "Shin Nishibori" , "Jody 

Akana" , "Duncan Kerr" , "Danny Coster" 

, "Rico Zorkendorfer" , "Daniele De Iuliis" 

, "Peter Russell-Clarke" , "Bart Andre" 

, "Jeremy Bataillou" , "Christopher Stringer" 

, "Matt Rohrbach" , "Richard Howarth" 

, "Jony Ive" , "Julian Hönig" 

Message-ID: 


From: Paul Meade 

Date: July 7, 2011 4:15:20 PM PDT 

Subject: Tablet Competitive Update July 7th, 2011 

Quick competitive update: 

- Most of the summers competitive devices are now available, see chart below for details. 

(Samsung Galaxy 10 clearly the closest in reviewers minds). 

- The HP TouchPad launched on July 1st to less than stellar reviews. 

- The Toshiba Thrive will be available on July 10th. 

- Attached the latest version of the Competitive Tracker. 

HP TouchPad Highlights: 

- 9.7" IPS display (very similar display module to K48), 1024x768 

- Snapdragon APQ8060 dual core 1.2Ghz 

- WebOS 3.0 

- Front facing camera only 1.3MP 

- Size = 240mm x 189mm x 14mm 

- weight = 740g (1.6Ibs) 

- 22.2Whr battery 

- Has inductive charging coil built in to be used with optional TouchStone dock ($80) 

- Initial reviews have been pretty harsh with weight (1.6Ibs) and sluggish OS being major 

complaints. In our own testing, the display seems "dull" even compared to K48 and the 

accelerometer/orientation control seems extremely "twitchy". In our video playback tests we 

achieved 6hrs of playback (65% brightness). 

- The SW itself is intuitive and easy to use but the glitches and sluggishness are hard to overcome 

and the product feels it was shipped before it was ready. 

- In the take apart it was clear there are provisions for a cellular model soon with plenty of space 

for the cellular components. 


APLNDC0001509486


- Available July 1st. 

- the HP roadmap found on the web shows the 64GB and 4G Touchpad's coming next month 

along with the 7" Opal in the Fall. 

Toshiba Thrive Highlights: 

- Available on July 10th. 

- Comes in a 8GB configuration for $429 

- Also has removable colored back covers for personalization 

- 10.1" display, 1280x800 

- Android 3.1 

- Tegra2 with 1GB RAM 

- 2MP F/F and 5MP R/F 

- User replaceable battery 

- Full sized SD and HDMI 

Amazon Tablet Coming Soon? 

- Probably the last of the summers competitive threats will be from Amazon. Its no secret that 

they have been staffing up their local Lab126 development center and its likely to ship a tablet (or 

tablets) in August/Sept. 

- Amazon it likely one of the few potential competitors that have enough of the platform pieces to 

mount an interesting offensive on the tablet front considering their brand loyalty, cloud services, 

video streaming service, Android App store and its MP3 store. 

Motorola Xoom 

- Currently been discounted by $100 at BestBuy (32GB for $499) 

- Also the original Xoom launch was 3G with the promise of a 4G upgrade by the end of June. 

The latest word from Motorola is now the upgrade will be available by the end of Summer. This 

must be infuriating for current shoppers especially with the 4G of the latest Samsung Galaxy 10.1" 

now up for pre-order. 

Samsung Galaxy 10.1" 

- Now available for pre-order with 4G on Verizon, available mid to late August. 


APLNDC0001509487


iPad makes up 1% of global web browsing: 

- Report from NetMarketShare shows iPad is now responsible for 1% of WW web browsing. 

Tablet App Stores: 

- This week it was reported that the number of tablet apps in the Apple App store crossed the 100,000 mark. 

- In comparison, CNNMoney reported that the number of Android Apps optimized for tablets was 1,345. 

- WebOS on their launch day (July 1st) had a total of 300 (8,000 apps available for the Palm Pre but only 

70% of them work and there is no magnify feature so you are stuck with the phone sized app on the tablet) 

------ end message ------ 


APLNDC0001509488



APLNDC0001509489



APLNDC0001509490


iPad Competitive Landscape 2011 

--· 

~- . . . ..._ ...... 

'... . ii . 

- 

..... 

T-Uc!OIIlG 

- 

S.. 

. .... 

-- 

= 

- .... ... 


APLNDC0001509491

.- ··· 


Coming soon! Order now 10 get It as soon 

as Its available. 

Samsung Galaxy Tab"' 10.1 

16GB 

• 

$529.99 


APLNDC0001509492


Od 'O 

..... 

Jw\"'11 

Feb '11 Mcr'H l



APLNDC0001509494

K48/K48M K93/K94 Galaxy Tab Dell Streak 7 Moto Xoom Playbook LG G-Slate Acer Iconia Tab 


A500 

ASUS Eee Pad HTC Flyer Galaxy Tab 10.1 HP “Touchpad” Toshiba Thrive Vizio Galaxy 8.9” HP - “Opal” Streak Pro Sony S1 Sony S2 Lenovo ThinkPad Fujitsu Q550 ViewSonic ViewPad ViewPad 7x Dell Latitude ST 

10 Pro 

OS iOS iOS Android 2.2 Android 2.2 Android 3.0 QNX Android 3.0 Android 3.0 Android 3.0 Android 2.3 Android 3.0 WebOS 3.0 Android 3.0 Android 2.3 Android 3.0 WebOS 3.0 Android 3.0 Android 3.0 Android 3.0 Android 3.0 Windows 7 Pro Windows 7 Pro Android 3.0 Windows 7 

(Gingerbread) 

Processor H3P: A8 @ 1Ghz H4P: dual core A9 @ Samsung Nvidia Tegra2, dual Nvidia Tegra2, dual TI OMAP 4330 Nvidia Tegra2, dual Nvidia Tegra2, dual Nvidia Tegra2, dual Snapdragon Nvidia Tegra2, dual APQ8060 1.2Ghz Nvidia Tegra2, dual 1Ghz Nvidia Tegra2, dual APQ8060 1.2Ghz Tegra T25 Nvidia Tegra2, dual Nvidia Tegra2, dual Nvidia Tegra2, dual Intel Oak Trail 1.5Ghz Intel Oak Trail 1.5Ghz Nvidia Tegra2 Intel Oak Trail 1.5Ghz 

1Ghz Hummingbird A8 @ core @ 1Ghz core @ 1Ghz dual core 1Ghz core @ 1Ghz or 3D core @ 1Ghz core @ 1Ghz or 3D Hummingbird core @ 1Ghz 

core @ 1Ghz 

core @ 1Ghz 

core @ 1Ghz core @ 1Ghz core @ 1Ghz 

1Ghz (1.2Ghz in v2) 

version? 

version? 

@1.5Ghz 

RAM 256MB 512MB 512MB 1GB 1GB 1GB 1GB 1GB 1GB 1GB? 1GB DDR2 ? 512MB 1GB? ? 2GB DDR2 2GB DDR2 2GB RAM 

LCD Size 9.7” 9.7” 7.0” 7” 10.1” 7.0” 8.9” 10.1” 10.1” IPS 7” 10.1” 9.7” XGA w/IPS 10.1 8” 8.9” 7” 10” 9.4” pair of 5.5” 10.1” 10.1” 10.1” 7” 10” 

LCD Resolution 1024x768 (4:3) 1024x768 (4:3) 1024x600 (10:6) WVGA 800x480 1280x800 (16:10) 1024x600 (10:6) 1280x768 (15:9) 1280x800 (16:10) 1280x800 (16:10) 1024 x 600 (10:6) 1280 x 800 (16:10) 1024x768 (4:3) 1280x800 (16:10) 1024x768 (4:3) 1280 x 800 (16:10) 1024x768 (4:3) 1280 x 800 1280 x 800 (16:10) 1024 x 480 (21:9) 1280 x 800 (16:10) 1280x800 (16:10) 1024x600 1366 x 768 

LCD PPI 132 132 169 133 149 169 167 149 149 169 149 132 149 169 182? 160 205 149 160 

R/F Camera None HD, 720p 1MP 3MP (5MP in v2) 5MP AF 5MP 5MP dual R/F 5MP 

5MP 5MP AF 5MP AF 3MP AF none 5MP none 3MP AF none? yes yes yes 3MP 

Stereoscopic 

F/F Camera None VGA 1.3MP 1.3MP 2MP 3MP 2MP 2MP 1.2MP 1.3MP 2MP 1.3MP 2MP VGA 2MP yes yes yes yes 1.3MP 

Camera Flash None None Led flash no dual LED flash None yes, LED No no LED no None LED no ? 

Video Recording None 720p 720p yes 720p 1080p 1080p, 720p 3D ? 720p 1080p ? 720p 1080p ? 1080p 1080p 

Adobe Flash None None Yes, 10.1 yes Yes, 10.1 10.1 probably, 10.1? 10.2 after upgrade 10.1 10.2 yes yes, 10.1 10.2 yes 

Internal Storage 16/32/64 GB 16/32/64 GB 16/32 GB 16GB 32 GB 8/16/32/64 GB 32GB 16 GB 16GB + web storage 16GB 16/32/64GB 16/32 GB unknown 16/32/64GB 30/62GB SSD 32GB up to 128GB SSD 

Memory Slot None None uSD uSD uSD None none uSD uSD (up to 32GB) uSD (up to 32GB) ? SD uSD (up to 32GB) ? 

WiFi 802.11a/b/g/n 802.11a/b/g/n 802.11a/b/g/n 802.11b/g/n 802.11b/g/n 802.11a/b/g/n 802.11 b/g/n/l 802.11 b/g/n 802.11 b/g/n 802.11 b/g/n 802.11a/b/g/n 802.11b/g/n 802.11 802.11b/g/n 802.11a/b/g/n ? 802.11a/b/g/n 

Bluetooth 2.1 2.1 + EDR 3.0 2.1 + EDR 2.1 + EDR 2.1 + EDR 2.1 2.1 + EDR 3.0 2.1 + EDR 2.1 + EDR yes, version ? 3.0 3.0 

Sensors Accel, Compass, ALS Accel, Gyro, Accel, Gyro, Accel, Compass, Accel, Gyro, 

Accel Accel, ALS, Gyro Accel, ALS, Gyro, Accel, Gyro. Accel, Gyro, Accel, Gyro, Accel, ALS, ? ALS, Accel Accel, Gyro, 

GPS, Accel 

Compass, ALS compass, ALS GPS, Prox, ALS Compass, 

Compass, GPS Compass, ALS Compass, Proximity Compass, ALS 

Compass, Proximity 

Barometer, Prox, 

ALS 

Speakers mono mono Stereo Stereo speakers Stereo Speakers 3 speakers Stereo Speakers stereo, SRS WOW Stereo (surround) Stereo Stereo + SRS Stereo ? 

HD 

Connectors 30 pin 30 pin 30 pin (HDMI, USB, 30 pin, SD microUSB. miniHDMI, microUSB, uUSB, HDMI USB2.0 port, HDMI mini HDMI, micro microUSB 30 pin (HDMI, USB, microUSB USB, mini USB, 

USB2.0, uUSB, 3in1 USB, HDMI, SD/ 

charging) 

charging port and microHDMI, charging 

USB 

charging) 

HDMI, SD 

SD card, uHDMI SDHC. dock 

contacts 

contacts 

Dimensions 

242.8 x 189.7 x 241.27 x 185.77 x 190 x 120 x 199.9 x 119.8 x 249.1 x 167.8 x 193 x 130 x 243.8 x 149.8 x 

14mm 269 x 175 x 12.95 195.5 x 112.5 x13.2 256.6 x 172.9 x 241 x 190 x 13mm ? 167 x 205 x 12.2 230.9 x 157.8 x 180 x 144x 13mm ? 

13.4mm 

8.80mm 

11.98mm 

12.4mm 

12.9mm 

10.0mm 

12.7mm 

8.6mm 

8.6mm 

Weight 680g (730g K48M) 612g (K94) 380g 450g 730g 400g 620g 725g 675g 421g 565g 725g ? 544g 470g ? 771g (30GB ver) 380g ? 

GPS Yes Yes Yes Yes Yes No ? yes (incl wifi) Yes Yes (cellular) yes w/WWAN ? Yes Yes (cellular) yes 3G HSPA+ 

Cellular Options 

3G (HSPA or EVDO) 

3G (EVDO); free HW 4G (WiMAx) in Q2 4G w/T-Mobile 

3G cellular options 

WiMax 

Summer (WiFi only); 

3G (HSDPA) 3G (HSPA or EVDO) WiFi in Q1(?) 4G HSPA+ 

WiFi only 

HSPA+ (21Mbps) 

? HSPA+ (21Mbps) ? 3G 

upgrade to LTE (VzW) LTE/HSPA+ in 2H11 (HSPA+) 

available 

3G & 4G models later 

4G maybe in Q2? 

Battery life claim 

10h 10h 7h ? 10h 8h (20Whr) 9h pair of 3260mAh 9.5hrs (24.4Whr) 4h (14.8Whr) 10h (25.3Whr) 8h ? 10h 10h (22.2Whr) 8h 8h 19Whr ($729) 3500mAh (4.5hrs) 

8h 

(Whrs) 

batteries, 8hrs 

43Whr ($849) 

Other 

Getting a 5MP R/F 

3D capture but 

- includes ASUS - HTC Scribe (sold 

- “Touchstone” - replaceable battery - 4GB (2GB user - TouchWiz UI skin 

- 2 mics, 2 video chat - “quick and smooth - Playstation certified - pen and digitizer - fingerprint sensor 

- active pen support 

cam bump, new 

needs glasses for 

webstorage sep) HTC Sense - Exchange 

inductive charging - 5 colors (rear) avail) 

- Exchange 

windows 

UI” 

optional 

- dual NC mics 

processor & LTE in 

playback 

- Keyboard dock - Includes Onlive Activesync - cloud storage 

- built in IR blaster Activesync 

- Dell “stage 1.5” UI - “swift” browser 

v2 (Q2?) 

accessory- gaming 

- Quickoffice HD - Touch to share 

- multiple speakers - Quickoffice HD 

- IR remote 

- DLNA 

- dual mics for NC 

(x3) 

- DLNA 

Apps 

200,000 scaled 200,000 scaled 200,000 phone apps; Adobe AIR & Web 200,000 phone apps; 

200,000 phone apps; 200,000 scaled 200,000 phone apps; 350,000 apps; 

phone apps; handful phone apps; handful unknown 3.0 apps at Apps. Also supports unknown 3.0 apps at 

unknown 3.0 apps at phone apps; handful unknown 3.0 apps at unknown Tablet apps unknown 3.0 apps at 

unknown 3.0 apps at unknown Tablet apps 

>60,000 iPad apps >60,000 iPad apps 

of tablet apps of tablet apps 

launch Android 2.3 apps launch 

launch 

of tablet apps 

launch 

at launch 

launch 

launch 

at launch 

Availability Q2/2010 3G/WiFi Q2/2011 - 3G/WiFi Q4 2010 - 3G Feb 2nd, 2011 T- Feb 24th US - 3G April 19th - WiFi 20 Apr, 2011 (US T- April 24th, 2011 April via Best Buy - WiFi only in April WiFi - June 8th 7/1 for (WiFi) Jun 13, 2011 pre-order 7/1, “early summer” Sept 2011? ? Announced Apr, Announced Apr, ? preorder May 9th, 

Announced at Oct 1, 2011 

Q2 2011(?) - 4G Mobile 

Q2 2011 - 4G (LTE) Q2 11-4G (WiMax) Mobile) 

- Summer with Sprint 5k given out at 3G/4G later 

shipping 7/18 

available Fall 2011 available Fall 2011 

2011, ships June 

Computex 

March 27th -WiFi only 2H 11 - LTE/HSPA+ 

- 3G in Europe Google IO on 5/10 

Pricing $499 - $829 - $599 $450 $799 (32GB 3G/4G) $499 (16GB) 

$599 Wifi Only $599 (32GB) 

$699 (64GB) 

$529.99 (with 2yr 

contract and $100 

rebate) $750 no 

contract 

Shipping 

$449 (WiFi) $399 (16GB) (32GB) $499 (16GB) 

$599 (32GB) 

$499 (16GB) 

$599 (32GB) 

8 GB $429 

16GB $479 

32GB $579 

$379 (4GB) $469 (16GB) 

$569 (32GB) 

Announced 

? - $599? -$699 16GB, 32GB, 64GB $729 (30GB) 

$849 (62GB) 


APLNDC0001509495



APLNDC0001509496



APLNDC0001509497


EXHIBIT 16


Subject: Competitive Phone Tracker 02/25 

Date: Fri, 25 Feb 2011 22:54:28 +0000 

From: "Jason Lor" 

To: "NewTech XFunct" 

CC: "New Tech Core Team Core Team" 

Message-ID: 

Hi all, 

We've compiled a comprehensive list for all current and future flagship phones. We'll be adding new cellular competitors 

in an ongoing basis 

and will be extending this to other products in the future. 

Jason Lor 


c: 408.862.2680 

apple 

------ end message ------ 


APLNDC0002230186



State of Mobile 2011 


Apple Need-To-Know Confidential 


APLNDC0002230187


Current Flagship Phones 



APLNDC0002230188


HTC 



APLNDC0002230189

HTC 


EVO 4G June 2010 

Price & Carriers 

$199 w/ 2-year contract on Sprint 

Operating System Android 2.2 

SoC & Memory 

Network 

Battery & Charging 

Display 

Camera 

Qualcomm QSD 8650 (1.0GHz) 

512MB RAM, 1GB NAND plus microSD slot 

CDMA 800/1900 MHz EVDO Rev. A 

WiMAX 2.5 to 2.7GHz; 802.16e 

1500mAh 

microUSB 

4.3-inch LCD (480x800 pixel resolution) 

217ppi 

5MP auto-focus camera with LED flash, front VGA 

720p video recording 

Sensors 

Accelerometer, ambient light, proximity, compass 

Connectivity 

Dimensions 

Weight 

Wi-Fi (802.11 b/g), Bluetooth 2.1 + EDR w/ stereo A2DP 

GPS, A-GPS, micro-HDMI, Wi-Fi router for 8 devices, FM 

Width: 66mm (2.6 inches) 

Height: 122mm (4.8 inches) 

Thickness: 12.7mm (0.5 inches) 

170 grams (6 ounces) 



APLNDC0002230190

HTC 


G2 October 2010 


$99 w/ 2-year contract on T-Mobile 


SoC & Memory 

Network 


Display 

Camera 

Qualcomm MSM 7230 (800MHz); 


GSM: 850/900/1800/1900 MHz 

UMTS: Band IV (1700/2100) 

1300mAh 

microUSB 

3.7-inch LCD (480x800 pixel resolution), 

252ppi 

5MP auto-focus camera with LED flash 


Sensors 


Connectivity 

Dimensions 

Weight 

Wi-Fi (802.11b/g/n), Bluetooth 2.1 + EDR w/ A2DP Stereo 

GPS, A-GPS 




180 grams (6.3 ounces) 



APLNDC0002230191

HTC 


myTouch 4G November 2010 


$99 w/ 2-year contract on Sprint 


SoC & Memory 

Network 


Display 

Camera 

Qualcomm MSM 8255 Snapdragon (1.0GHz); 


GSM: 850/900/800/1900MHz 

UMTS: Band IV (1700/2100) 

1400mAh 

microUSB 


246ppi 



Sensors 


Connectivity 

Dimensions 

Weight 


GPS, A-GPS 







APLNDC0002230192

HTC 


HD7 November 2010 



Operating System Windows Phone 7 

SoC & Memory 

Network 


Display 

Camera 

Qualcomm QSD 8250 (1.0GHz) 

512MB RAM, 16GB internal microSD 

GSM: 850/900/800/1900 MHz; 

UMTS: Band I (2100), Band IV (1700/2100) 

1230mAh 

microUSB 


217ppi 



Sensors 


Connectivity 

Dimensions 

Weight 

Wi-Fi (802.11b/g/), Bluetooth 2.1 + EDR w/ stereo A2DP 

GPS, FM 







APLNDC0002230193


Motorola 



APLNDC0002230194

Motorola 


Droid X July 2010 


$150 w/ 2-year contract on Verizon 


SoC & Memory 

TI OMAP 3630 (1.0GHz) 


Network 

CDMA 800/1900, EVDO rev. A 


Display 

Camera 

1540mAh 

microUSB 


228ppi 



Sensors 

Accelerometer, ambient light, proximity, & compass 

Connectivity 

Dimensions 

Weight 

Wi-Fi (802.11b/g/n 5GHz), Bluetooth 2.1 + EDR w/ A2DP Stereo 

GPS, A-GPS, Wi-Fi router functionality, micro-HDMI 

Width: 65.5mm (2.58 inches) 






APLNDC0002230195

Motorola 


Droid 2 Global November 2010 


$199 w/ 2-year contract on Verizon 


SoC & Memory 

Network 


Display 

Camera 

TI OMAP 3640 (1.2GHz); 


GSM 850/900/1800/1900 

UMTS: 850/1900/2100, CDMA 800/1900 

HSDPA 10.2 Mbps, CDMA EV-DO Release A (World Phone) 

1420mAh 

microUSB 


265ppi 



Sensors 


Connectivity 

Dimensions 

Weight 


GPS, A-GPS 







APLNDC0002230196

Motorola 


Cliq2 January 2011 




SoC & Memory 

Network 


Display 

TI OMAP 3620 (1.0GHz) 


GSM 850/900/1800/1900 

UMTS: 850/1700/2100 

HSDPA 10.1 Mbps, HSUPA 5.76 Mbps 

1420mAh 

microUSB 


265ppi 

Camera 


Sensors 


Connectivity 

Dimensions 

Weight 


GPS, A-GPS, FM 







APLNDC0002230197


Samsung 



APLNDC0002230198

Samsung 

Galaxy S 


June 2010 

Price & Carrier 

$50-199 w/ 2-year contract on AT&T, Verizon, Sprint & T-Mobile 


SoC & Memory 

Network 


Display 

Camera 

1GHz Cortex A8 Hummingbird 


GSM/EDGE/GPRS 850/ 900/1800/1900 

HSUPA 900/1900/2100 

1500mAh 

microUSB 

4.0-inch AMOLED (480x800 pixel resolution), 

233ppi, 16-bit color 



Sensors 


Connectivity 

Dimensions 

Weight 



Height: 122.4mm (4.82 inches) 





APLNDC0002230199

Samsung 

Continuum 


November 2010 


$99 on Verizon w/ 2-year contract on Verizon 


SoC & Memory 



Network CDMA 800/1900 


Display 

Camera 

1500mAh 

microUSB 


1.8-inch ticker (480x96 pixel resolution) 

233ppi 


Sensors 

Accelerometer, ambient light, proximity 

Connectivity 

Dimensions 

Weight 




Thickness: 12mm (0.48 inches) 




APLNDC0002230200

Samsung 

Focus 



$99 w/ 2-year contract on AT&T 

November 2010 

Operating System Windows Phone 7 

SoC & Memory 

Network 


Display 

Camera 

Qualcomm Snapdragon MSM 8255 (1GHz) 

512MB RAM, 8GB NAND with microSD slot 

GSM/GPRS/EDGE 850/900/1800/1900MHz 

UMTS: 850/1900/2100MHz 

1500mAH 

microUSB 


233ppi 

5MP autofocus camera with LED flash 


Sensors 

Accelerometer, Compass, Proximity & Light Sensor 

Connectivity 

Dimensions 

Weight 

Wi-Fi (802.11b/g/n), Bluetooth 2.1, GPS, A-GPS, FM Radio 







APLNDC0002230201

Samsung / Google 

Nexus S 


December 2010 


$529 unlocked or $199 w/ 2-year contract on T-Mobile 


SoC & Memory 


512MB RAM, 16GB NAND 

Network GSM: 850/900/1800/1900, HSPA 900/2100/1900 


Display 

Camera 

1500mAh 

microUSB 


233ppi 



Sensors 


Connectivity 

Dimensions 

Weight 

Wi-Fi (802.11b/g/n), Bluetooth 2.1 + EDR w/ A2DP Stereo, NFC 







APLNDC0002230202


LG 



APLNDC0002230203

LG 


Optimus series November 2010 


Free to $149 on Sprint, T-Mobile, metroPCS, Virgine Mobile, US 

Cellular 


SoC & Memory 

(Sprint version) 

Network 


Display 

Camera 

Qualcomm MSM7627 (600 MHz); 

512MB RAM, microSD slot 

CDMA: 1.9 GHz PCS, 800 MHz 

GSM: 850/900/1800/1900 MHz, 1700/2100 MHz 

1500mAh 

microUSB 


180ppi 

3.2MP auto-focus camera 

VGA video recording 

Sensors 


Connectivity 

Dimensions 

(Sprint version) 

Weight 

Wi-Fi (802.11b/g), Bluetooth 2.1 + EDR w/ A2DP Stereo 

GPS, A-GPS, Wi-Fi router functionality (up to 5 devices) 







APLNDC0002230204


Nokia 



APLNDC0002230205

Nokia 

N8 



$399 unlocked 

October 2010 

Operating System Symbian 3 

SoC & Memory 

Network 


Display 

Camera 

OMAP 2420 680MHz, 256MB RAM 

16GB NAND with microSD slot 

GSM/EDGE 850/900/1800/1900 

WCDMA 850/900/1700/1900/2100 

1200mAh 

microUSB 

3.5” OLED display (640x360 pixel resolution) 

209ppi 

12MP auto-focus camera w/ Xenon flash, front-facing VGA 


Sensors 

Accelerometer, Compass, Proximity & Ambient light sensors 

Connectivity 

Dimensions 

Weight 

Wi-Fi (802.11b/g/n), Bluetooth 3.0, HDMI, FM Radio, GPS, A-GPS 







APLNDC0002230206


Research in Motion 



APLNDC0002230207

RIM 


Blackberry Storm 2 9550 

November 2009 


$99.99 on Verizon 

Operating System Blackberry OS 5.0 

SoC & Memory 

Network 


Display 

Camera 

processor unknown, 256MB RAM 

2GB eMMC plus microSD slot 


UMTS/HSPA 2100MHz 

CDMA: 800/1900MHz/EV-DO rev A 

1400mAh 


184ppi 

3.2MP auto-focus camera with LED flash 

Sensors 

Accelerometer, ambient light & proximity 

Connectivity 

Dimensions 

Weight 

Wi-Fi (802.11 b/g), Bluetooth 2.0, GPS 







APLNDC0002230208

RIM 

Blackberry Torch 


August 2010 


$499.99 USD on AT&T 

Operating System Blackberry OS 6.0 

SoC & Memory 

Network 

624MHz processor, 512MB RAM 

4GB eMMC plus microSD slot 

GSM/GPRS/EDGE 850/900/1800/1900 

UMTS 2100/1900/850/800 


1300mAh 

Display 

Camera 


188ppi 

5MP auto-focus camera w/ LED flash, front VGA 


Sensors 


Connectivity 

Dimensions 

Weight 


GPS, A-GPS 







APLNDC0002230209


Feature Highlights 



APLNDC0002230210

HTC 

Surround 


Feature 

Phone slides partially to reveal speaker grill 

Engadget 

“We don't think any amount of audio postprocessing can make 

tiny phone speakers sound good... On a more positive note, the 

speakers do get nicely loud without distortion” 

cnet 

“...the only thing its built-in speakers really add to the phone is 

weight.” 

Slashgear 

“It’s certainly loud, but it lacks clarity and sharpness; the 

surround sound mode, meanwhile, is audibly different from the 

default setting, but we wouldn’t say it was theater-like either.” 



APLNDC0002230211

Motorola 

Defy 


Feature 

Water-resistant and dustproof 

Engadget 

“Physically, the Defy is unusual in that it looks so... well, usual. 

Typically, ruggedized phones are overbuilt, over-engineered 

behemoths that are obviously designed to look tough, and 

that's just not the case with this one. 

cnet 

“The Motorola Defy is tough enough to withstand everyday 

hazards with its tough Gorilla glass and rugged exterior... its 

rough-and-tumble aesthetic isn't for everyone.” 

PC Magazine 

“I dunked the Defy in a foot of water with the MP3 player 

going, and it continued playing without a problem. I couldn't 

stop the playback, though, because capacitive touch screens 

don't work when they're wet.” 



APLNDC0002230212


Future Flagship Phones 



APLNDC0002230213


HTC 



APLNDC0002230214

HTC 


Incredible S Q2 2011 


Unannounced 


SoC & Memory 

Network 


Display 

Camera 

Qualcomm Snapdragon MSM8255 (1GHz), 768MB RAM 

1.1GB internal storage with microSD expansion 


HSPA/WCDMA: 900/AWS/2100MHz 

1450mAH 

microUSB 


233ppi 

8MP autofocus camera w/ dual LED flash, 1.3MP front-facing 


Sensors 

Accelerometer, Digital Compass, Proximity & Light Sensor 

Connectivity 

Dimensions 

Weight 

Wi-Fi 802.11b/g/n, Bluetooth 2.1 with FTP/OPP & A2DP 

GPS, A-GPS 




135.5grams (4.78 ounces) 



APLNDC0002230215

HTC 


Desire S Q2 2011 


Unannounced 


SoC & Memory 

Network 


Display 

Camera 

Qualcomm Snapdragon MSM8255 (1GHz), 768MB RAM 

1.1GB internal storage w/ microSD expansion 


HSPA/WCDMA: 900/2100MHz 

1450mAH 

microUSB 


252ppi 

5MP autofocus camera w/ LED flash, front-facing VGA 


Sensors 


Connectivity 

Dimensions 

Weight 

Wi-Fi (802.11b/g/n), Bluetooth 2.1 with FTP/OPP & A2DP 

GPS, A-GPS 




130.0grams (4.59 ounces) 



APLNDC0002230216

HTC 


Wildfire S Q2 2011 


Unannounced 


SoC & Memory 

Network 


Display 

Camera 

Qualcomm Snapdragon MSM 8255 (600MHz), 512MB RAM 

512MB ROM & microSD memory expansion 


HSPA/WCDMA 900/2100MHz 

1230mAH 

microUSB 


180ppi 

5MP autofocus camera w/ LED flash 

video recording 

Sensors 


Connectivity 

Dimensions 

Weight 

Wi-Fi (802.11b/g/n), Bluetooth 3.0 with FTP/OPP & A2DP 

GPS, A-GPS 




105grams (3.7 ounces) 



APLNDC0002230217


Motorola 



APLNDC0002230218

Motorola 


Motorola Atrix February 2011 


$199 w/ 2-year contract on AT&T 


SoC & Memory 

Network 


Display 

Camera 

NVIDIA Tegra 2 dual-core (1.0GHz) 

1GB RAM, 16GB NAND plus microSD slot 

GSM: 850/900/1800/1900 

UMTS: 850/1900/2100 

HSDPA+ 14Mbps 

1930mAh 

microUSB 


275ppi 



Sensors 

Accelerometer, ambient light, proximity & compass 

Connectivity 

Dimensions 

Weight 


GPS, A-GPS, micro-HDMI, HDMI & laptop docks (right image) 







APLNDC0002230219

Motorola 


Droid Bionic LTE 4G Q2 2011 


599 USD on Verizon Wireless 


SoC & Memory 

Network 


Display 

Camera 

NVIDIA Tegra 2 (dual-core) 1.0GHz, 512MB RAM 

2GB ROM w/ microSD expansion 

CDMA 800/1900, LTE 700 

CDMA2000 1xEV-DO / LTE 

1930mAH 

microUSB 



8MP camera w/ dual LED flash, 0.3MP front-facing 


Sensors 


Connectivity 

Dimensions 

Weight 

Wi-Fi 802.11b/g/n, Bluetooth 2.1 w/ EDR & A2DP, GPS, A-GPS 




158grams (5.57 ounces) 



APLNDC0002230220


Samsung 



APLNDC0002230221

Samsung 


Galaxy S II Q1 2011 


599 EUR ($814 USD) & unannounced 


SoC & Memory 

Network 


Display 

Camera 

1.0GHz dual-core, 1024MB RAM 

16GB internal storage w/ microSD slot 

GSM 800/900/1800/1900, UMTS 850/1900/2100, EDGE, 

UMTS/HSPA 800/850/1900/2100 

1600mAh 

microUSB 



8MP auto-focus camera w/ LED flash, 2MP front-facing 

720p video recording w/ video light 

Sensors 

Accelerometer, ambient light, gyroscope, proximity, & compass 

Connectivity 

Dimensions 

Weight 

Wi-Fi 802.11b/g/n, Bluetooth 3.0 w/ EDR & A2DP, GPS, A-GPS, FM 

Radio, NFC 







APLNDC0002230222

Samsung 


Infuse 4G Q1 2011 




SoC & Memory 

Network 


Display 

Camera 

1.2GHz Humming Bird, 1024MB RAM 

16GB internal storage w/ microSD slot 

GSM 800/900/1800/1900, UMTS 850/1900/2100, EDGE, 

UMTS/HSPA 800/850/1900/2100 

1750mAh 

microUSB 



8MP auto-focus camera w/ LED flash, 1.3MP front-facing 


Sensors 


Connectivity 

Wi-Fi, Bluetooth, GPS, A-GPS 

Dimensions 

Weight 



APLNDC0002230223


LG 



APLNDC0002230224

LG 


Optimus 2X April 2011 


499 EUR & unannounced 


SoC & Memory 

Network 


Display 

Camera 

NVIDIA Tegra 2 (dual-core) 1.0GHz 

512MB RAM 

GSM 800/900/1800/1900, EDGE, 

UMTS/HSPA 900/2100 

1500mAh 

microUSB 

4-inch LCD (480x800 pixel resolution), 


8MP camera w/ LED flash, 1.3MP front-facing 


Sensors 


Connectivity 

Dimensions 

Weight 








APLNDC0002230225

LG 


Optimus Black April 2011 




SoC & Memory 

Network 


Display 

Camera 

Texas Instruments OMAP 3630 (1GHz) 

512MB RAM 

GSM 800/900/1800/1900, EDGE, 


1500mAh 

microUSB 

4-inch LCD (480x800 pixel resolution), 700cd/m 2 brightness 

233ppi 

5MP camera w/ LED flash, 2MP front-facing 


Sensors 


Connectivity 

Dimensions 

Weight 








APLNDC0002230226

LG 


Optimus 3D April 2011 




SoC & Memory 

Network 


Display 

Camera 

Texas Instruments OMAP4 ARM Cortex-A9 dual-core (1GHz) 

512MB RAM 

GSM 800/900/1800/1900, EDGE, 


1500mAh 

microUSB 

4.3-inch autostereoscopic LCD (480x800 pixel resolution) 


5MP camera w/ LED flash, 1.3MP front-facing 

1080p 3D video recording 

Sensors 


Connectivity 

Dimensions 

Weight 








APLNDC0002230227


Sony Ericsson 



APLNDC0002230228

Sony Ericsson 


Xperia arc April 2011 




SoC & Memory 

Network 


Display 

Camera 

Qualcomm MSM8255 (1.0GHz); 

512MB RAM 

GSM 800/900/1800/1900, UMTS 850/1900/2100, EDGE, 

UMTS/HSPA 800/850/1900/2100 

1500mAh 

microUSB 


233ppi 

8.1MP auto-focus camera w/ LED flash 


Sensors 


Connectivity 

Dimensions 

Weight 

Wi-Fi, Bluetooth, GPS, A-GPS, FM Radio 



Thickness: 8.7mm (0.3 inches) (at thinnest point) 




APLNDC0002230229

Sony Ericsson 


Xperia neo March 2011 




SoC & Memory 

Network 


Display 

Camera 


512MB RAM 

GSM 800/900/1800/1900, UMTS 850/1900/2100, EDGE, 

UMTS/HSPA 800/850/1900/2100 

1500mAh 

microUSB 




720p video recording w/ video light 

Sensors 


Connectivity 

Dimensions 

Weight 

Wi-Fi, Bluetooth, GPS, A-GPS, FM Radio 







APLNDC0002230230

Sony Ericsson 


Xperia PLAY April 2011 


Operating System 

SoC & Memory 

Network 


Display 

Camera 

Sensors 


Android 2.3, plays PSP games 


512MB RAM 

GSM 800/900/1800/1900, UMTS 850/1900/2100, EDGE, 

UMTS/HSPA 800/850/1900/2100 

1500mAh 

microUSB 





Accelerometer, ambient light, proximity, & compass, dual-shock 

joysticks 

Connectivity 

Dimensions 

Weight 








APLNDC0002230231

Sony Ericsson 


Xperia Pro April 2011 


unannounced 


SoC & Memory 

Network 


Display 

Camera 


512MB RAM 

GSM 800/900/1800/1900, UMTS 850/1900/2100, EDGE, 

UMTS/HSPA 800/850/1900/2100 

1500mAh 

microUSB 


265ppi 

8.1MP auto-focus camera w/ LED flash, front VGA 


Sensors 


Connectivity 

Dimensions 

Weight 








APLNDC0002230232


HP/Palm 



APLNDC0002230233

HP 

Pre 3 



Unannounced 

Summer 2011 

Operating System webOS 3.0 

SoC & Memory 

Qualcomm MSM 8x55 single-core (1.4GHz); 

512MB RAM 

Network 

n/a 


Display 

Camera 

1230mAh 

microUSB & Inductive (Touchstone) 


261ppi 



Sensors 


Connectivity 

Dimensions 

Weight 

Wi-Fi (802.11a/b/g/n 5GHz), Bluetooth 2.1 + EDR w/ A2DP Stereo 

GPS, A-GPS, Wi-Fi router functionality (up to 5 devices) 







APLNDC0002230234

HP 

Veer 



Unannounced 

Spring 2011 

Operating System webOS 2.2 

SoC & Memory 

Network 


Display 

Camera 

Sensors 

Connectivity 

Dimensions 

Weight 

Qualcomm MSM7230 single-core SoC 800MHz 

512MB RAM 

GSM/EDGE 850/900/1800/1900 

HSDPA 7.2/HSUPA 5.76 

910mAh 

Inductive (Touchstone) 


197ppi 

5MP auto-focus camera 

video recording 


Wi-Fi (802.11a/b/g/n 5GHz), Bluetooth 2.1 + EDR w/ A2DP Stereo 

GPS, A-GPS, Wi-Fi router functionality (up to 5 devices), 

magnetic port for 3.5mm & microSD adapter 





HP Veer 



APLNDC0002230235


Analysis of Future Flagship Devices 



APLNDC0002230236


Comparison of battery capacity (mAh) 

HP Veer 

HP Pre 

HTC Wildfire S 

Apple iPhone 4 

HTC Incredible S 

HTC Desire S 

LG Optimus (3D/2X/Black) 

Sony Xperia (arc/neo/pro/PLAY) 

Samsung Galaxy S II 

Samsung Infuse 4G 

Motorola Droid Bionic LTE 4G 

Motorola Atrix 4G 

910 

1230 

1230 

1420 

1450 

1450 

1500 

1500 

1600 

1750 

1930 

1930 

0 200 400 600 800 1,000 1,200 1,400 1,600 1,800 2,000 

Battery Capacity (mAh) 



APLNDC0002230237


Comparison of device depth (mm) 

Sony Xperia PLAY 

HP Pre 

HP Veer 

Sony Xperia Pro 

Motorola Droid Bionic LTE 

Sony Xperia neo 


LG Optimus 3D 


HTC Desire S 

LG Optimus 2X 


9.3 

12.4 

11.9 

11.7 

11.63 

10.9 

13.3 

13 

13.7 

15.1 

16 

16 

LG Optimus Black 

9.2 

Sony Xperia arc 

8.7 


8.49 

0 2 3 5 7 9 10 12 14 15 17 

Depth (mm) 



APLNDC0002230238


Comparison of display pixel density 


HP Veer 



LG Optimus 3D 

LG Optimus 2X 





HTC Desire S 


HP Pre 

Sony Xperia pro 

Sony Xperia play 



180 

197 

207 

218 

218 

233 

233 

233 

233 

233 

252 

256 

261 

265 

265 

275 

326 

0 35 70 105 140 175 210 245 280 315 350 

Pixel Density (ppi) 



APLNDC0002230239


Comparison of screen size 

HP Veer 



HP Pre 

HTC Desire S 

Sony Xperia play 

Sony Xperia pro 

LG Optimus 2X 








LG Optimus 3D 


2.6 

3.2 

3.5 

3.58 

3.7 

3.7 

3.7 

4 

4 

4 

4 

4.2 

4.2 

4.3 

4.3 

4.3 

4.5 

0 1 2 3 3 4 5 

Depth (mm) 



APLNDC0002230240


Device Thickness (mm) 

16 

15 

14 

13 

12 

12 

11 

10 

Battery Capacity vs. Device Thickness 

HTC incredible S 

HTC Desire S 







Sony Xperia Play 

HP Pre 


9 

8 

7 

1,000 1,200 1,400 1,600 1,800 2,000 

Battery Capacity (mAh) 



APLNDC0002230241





APLNDC0002230242

Manufacturer 

Apple 

N90/N92 

Release Date June 2010 

Operating System iOS 4.2.1 

Processor 

RAM 

Internal Storage 

A4 (800MHz single-core) 

512MB 

16/32GB 

Memory Slot - 

LCD Diagonal (inch) 3.5 

LCD Resolution (w) 640 

LCD Resolution (h) 960 

LCD PPI 329.7 

2G GSM/GPRS/EDGE 850/900/1800/1900 

3G UMTS/HSDPA/HSUPA 850/900/1900/2100 

2G CDMA 800/1900 

3G CDMA2000 

1xEV-DO 

4G - 

R/F Camera 

R/F Flash 

F/F Camera 

Video Recording (max res) 

WiFi (802.11) 

Bluetooth 

Location 

5MP AF 

VGA 

LED 

720p 

b/g/n 

2.1 + EDR 

A-GPS, Compass 

Connectivity - 

Sensors 

Connectors 

Accelerometer, 

Gyroscope, Proximity 

Sensor, ALS 

30-pin, 3.5mm 

Connectors (other) - 

Width (mm) 58.66 

Height (mm) 115.2 

Depth (mm) 9.3 

Weight (grams) 137.0 

Battery Capacity (mAh) 1420 

Other 

j 

RIM HTC Samung Motorola RIM T-Mobile HTC T-Mobile Nokia Motorola Samsung Samsung LG Samsung Motorola Motorola Sony Ericsson Sony Ericsson Acer HTC HTC LG LG Sony Ericsson Samsung Samsung HP HP LG HTC Motorola Sony Ericsson 

Blackberry Storm 2 EVO 4G Galaxy S Series Droid X Blackberry Torch G2 HD7 myTouch 4G N8 Droid 2 Global Continuum Focus Optimus Series Google Nexus S Cliq2 ATRIX Xperia neo Xperia PLAY ICONIA SMART Incredible S Desire S Optimus 2X Optimus 3D Xperia arc Galaxy S II Infuse 4G Veer Pre3 Optimus Black Wildfire S Droid Bionic Xperia pro 

November 2009 March 2010 June 2010 July 2010 August 2010 September 2010 October 2010 October 2010 October 2010 November 2010 November 2010 November 2010 November 2010 December 2010 January 2011 February 2010 March 2011 March 2011 April 2011 April 2011 April 2011 April 2011 April 2011 April 2011 Q1 2011 Q1 2011 Q1 2011 Q2 2011 Q2 1011 Q2 2011 Q2 2011 Q2 2011 

Blackberry OS 5.0 Android 2.2 Android 2.1 Android 2.2 Blackberry OS 6.0 Android 2.2 Windows Phone 7 Android 2.2 Symbian3 Android 2.2 Android 2.1 Windows Phone 7 Android 2.2 Android 2.3 Android 2.2 Android 2.2 Android 2.3 Android 2.3 Android 2.3 Android 2.3 Android 2.3 Android 2.2 Android 2.2 Android 2.3 Android 2.3 Android 2.3 webOS 2.2 webOS 3.0 Android 2.2 Android 2.3 Android 2.2 Android 2.3 

unknown 

QSD8650 (1.0GHz 

single-core) 

Cortex A8 (1GHz 


OMAP3630 (1.0GHz 


unknown (624MHz 


MSM7230 (800MHz 


QSD8250 (1.0GHz 


MSM8255 (1.0GHz 


OMAP2420 (680MHz 






MSM8255 (1.0GHz 


MSM7627 (600MHz 






Tegra 2 (1.0GHz dualcore) 

MSM8255 (1.0GHz 


256MB 512MB 512MB 512MB 512MB 512MB 512MB 768MB 256MB 512MB 384MB 512MB 512MB 512MB 512MB 1024MB 512MB 512MB 512MB 768MB 768MB 512MB 512MB 512MB 1024MB 1024MB 512MB 512MB 512MB 512MB 512MB 512MB 

2GB 1GB 16GB 8GB 4GB 4GB 16GB 4GB 16GB 8GB 2GB 8GB - 16GB 1GB 16GB 320MB 400MB 512MB 1.1GB 1.1GB 8GB 8GB 320MB 16/32GB 16GB 8GB 8GB/16GB 2GB 512MB 2GB 320MB 

microSD microSD microSD microSD microSD microSD microSD microSD microSD microSD microSD microSD microSD - microSD microSD microSD microSD microSD microSD microSD microSD microSD microSD microSD microSD - - microSD microSD microSD microSD 

3.3 4.3 4.0 4.3 3.2 3.7 4.3 3.8 3.5 3.7 3.4 4.0 3.2 4.0 3.7 4.0 3.7 4.2 4.8 4.0 3.7 4.0 4.3 4.2 4.3 4.5 2.6 3.58 4.0 3.2 4.3 3.7 

360 480 480 480 360 480 480 480 360 480 480 480 320 480 480 540 480 480 480 480 480 480 480 480 480 480 320 480 480 320 540 480 

480 800 800 854 480 800 800 800 640 854 800 800 480 800 854 960 854 854 1024 800 800 800 800 854 800 800 400 800 800 480 960 854 

184.6 217.0 233.2 227.8 187.5 252.1 217.0 245.5 209.8 264.8 274.4 233.2 180.3 233.2 264.8 275.4 264.8 233.3 235.6 233.2 252.1 233.2 217.0 233.3 217.0 207.3 197.0 260.6 233.2 180.3 256.2 264.8 

850/900/1800/1900 - 850/900/1800/1900 - 850/900/1800/1900 850/900/1800/1900 850/900/1800/1900 850/900/1800/1900 850/900/1800/1900 850/900/1800/1900 - 850/900/1800/1900 850/900/1800/1900 850/900/1800/1900 850/900/1800/1900 850/900/1800/1900 850/900/1800/1900 850/900/1800/1900 850/900/1800/1900 850/900/1800/1900 850/900/1800/1900 850/900/1800/1900 850/900/1800/1900 850/900/1800/1900 850/900/1800/1900 850/900/1800/1900 850/900/1800/1900 850/900/1800/1900 850/900/1800/1900 850/900/1800/1900 - 850/900/1800/1900 

2100 - 900/1900/2100 - 800/850/1900/2100 1700/2100 1700/2100 1700/2100 800/850/1700/1900/2100 850/1900/2100 - 850/1900/2100 1700/2100 900/1900/2100 850/1700/2100 1850/1900/2100 850/900/1900/2100 850/900/1900/2100 900/1900/2100 900/1700/2100 900/2100 900/2100 900/1900/2100 850/900/1900/2100 850/900/1900/2100 850/900/1900/2100 850/900/1800/1900 850/900/1800/1900 900/2100 900/2100 - 850/900/1900/2100 

800/1900 800/1900 800/1900 800/1900 - - - - - 800/1900 800/1900 - 800/1900 - - - - - - - - - - - - - - 800/1900 - - 800/1900 - 

1xEV-DO Rev. A 1xEV-DO Rev. A 1xEV-DO Rev. A 1xEV-DO rev.A - - - - - 1xEV-DO rev.A 1xEV-DO Rev. A - - - - - - - - - - - - - - - 1xEV-DO - - 1xEV-DO Rev. A - 

- WiMAX 802.16e - - - - - - - - - - - - HSDPA 10.1 HSDPA+ 14Mbps - - HSDPA+ 14Mbps - - - HSDPA+ 14.4Mbps - HSDPA+ 21Mbps HSDPA (unknown) - - - - LTE - 

3.2MP AF 5MP AF 5MP AF 8MP 5MP AF 5MP AF 5MP AF 5MP AF 12MP AF 5MP AF 5MP AF 5MP AF 3.2MP 5MP AF 5MP AF 5MP AF 8.1MP AF 5.1MP AF 8MP AF 8MP AF 5MP AF 8MP AF 5MP AF 8.1MP AF 8MP AF 8MP AF 5MP AF 5MP AF 5MP AF 5MP AF 8MP AF 8.1MP AF 

- VGA VGA - VGA - - VGA VGA - VGA - - VGA - VGA VGA VGA 2MP 1.3MP VGA 1.3MP 1.3MP - 2MP 1.3MP - VGA 2MP - 0.3MP VGA 

LED LED LED LED LED LED LED LED Xenon LED LED LED LED LED LED LED Photo light LED dual-LED LED LED LED LED LED LED - LED LED LED - LED 

unknown 720p 720p 720p 720p 720p 720p 720p 720p 480p - 720p VGA 720p - 720p 720p - 720p 720p unannounced 1080p 1080p 3D 720p 720p 1080p - 720p 720p unannounced 720p 720p 

b/g b/g b/g/n b/g/n (5GHz) b/g/n b/g/n b/g b/g/n b/g/n b/g/n b/g/n b/g/n b/g b/g/n b/g/n b/g/n b/g/n b/g/n b/g/n b/g/n b/g/n b/g/n b/g/n b/g/n a/b/g/n, Direct b/g/n b/g/n a/b/g/n (5GHz) b/g/n, Direct b/g/n b/g/n b/g/n 

2.0 2.1 + EDR 3.0 + EDR 2.1 + EDR 2.1 + EDR 2.1 + EDR 2.1 + EDR 2.1 + EDR 3.0 2.1 + EDR 3.0 + EDR 2.1 2.1 + EDR 2.1 + EDR 2.1 + EDR 2.1 + EDR 2.1 2.1 2.1 + EDR 2.1 2.1 2.1 3.0 + HS 2.1 3.0 + HS 3.0 2.1 2.1 + EDR 2.1 + EDR 3.0 + HS 2.1 + EDR 2.1 

GPS A-GPS, Compass A-GPS, compass A-GPS, Compass A-GPS, Compass A-GPS, Compass A-GPS, Compass A-GPS, Compass A-GPS, Compass A-GPS, Compass A-GPS A-GPS, Compass A-GPS, Compass A-GPS, Compass A-GPS, Compass A-GPS, Compass A-GPS, Compass A-GPS, Compass A-GPS, Compass A-GPS, Compass A-GPS, Compass A-GPS, Compass A-GPS, Compass A-GPS, Compass A-GPS, Compass A-GPS, Compass A-GPS A-GPS, Compass A-GPS, Compass A-GPS, Compass A-GPS, Compass A-GPS, Compass 


Proximity Sensor, ALS 

FM Radio - - - - - - FM Radio - - FM radio - NFC FM Radio FM Radio FM Radio - - - FM Radio - FM Radio FM Radio FM Radio, NFC - - - - - - FM Radio 


Proximity Sensor, 

ALS 

Accelerometer. 


ALS 



ALS 

Acceleromter, 


ALS 



ALS 



ALS 



ALS 

Accelerometer. Proximity 

Sensor, ALS 



ALS 



ALS 



ALS 



ALS 



ALS 



ALS 





microUSB, 3.5mm microUSB, 3.5mm microUSB, 3.5mm microUSB, 3.5mm microUSB, 3.5mm microUSB, 3.5mm microUSB, 3.5mm microUSB, 3.5mm microUSB, 3.5mm microUSB, 3.5mm microUSB, 3.5mm microUSB, 3.5mm microUSB, 3.5mm microUSB, 3.5mm microUSB, 3.5mm microUSB, 3.5mm microUSB, 3.5mm microUSB, 3.5mm microUSB, 3.5mm microUSB, 3.5mm microUSB, 3.5mm microUSB, 3.5mm microUSB, 3.5mm microUSB, 3.5mm microUSB, 3.5mm microUSB, 3.5mm Magnetic/Charger microUSB, 3.5mm microUSB, 3.5mm microUSB, 3.5mm microUSB, 3.5mm microUSB, 3.5mm 

microHDMI - microHDMI - - - microHDMI, 2mm charging - - - - - - microHDMI microHDMI Dual-shock joysticks microHDMI - - microHDMI microHDMI microHDMI - - Magnetic Adapter - - - microHDMI microHDMI 

62 66.00 64 65.5 62 60.00 68 62 59 61 58 65 58 63 64.2 64.0 57 62 64.5 64.0 59.8 63.2 68.0 63 66.1 unannounced 54.5 64 64.0 59.4 66.9 57 

113 122.0 122 128 111 119.0 122 122 114 116 125 123 107 124 122.4 118.0 116 119 141.7 120.0 115.0 123.9 128.8 125 125.3 unannounced 84 111 122.0 101.3 125.9 120 

13.0 12.7 9.9 9.90 14.6 14.2 11.20 10.90 12.9 13.70 12.0 10.0 11.9 10.9 9.90 11.0 13 16 13.6 11.7 11.6 10.9 11.9 8.7 8.5 unannounced 15.1 16 9.2 12.4 13.3 13.5 

160 170.0 118 155.0 161 180.0 162.0 153.0 115 169.0 125 115 115 129 118.0 135.0 126 175 185.0 135.5 130.0 139.0 168.0 117 116.0 unannounced 103 156 109.0 105.0 158.0 140 

1400 1500 1500 1540 1300 1300 1230 1400 1200 1420 1500 1500 1500 1500 1500 1930 1500 1500 1500 1450 1450 1500 1500 1500 1600 unannounced 910 1230 1500 1230 1930 1500 

CDMA and GSM 

versions 

GSM and CDMA 

versions 


1.8-inch ticker LCD 

(480x96 pixel 

resolution) 

- CDMA and GSM 

versions 

NFC 

MSM8255 (1.0GHz 




MSM8255 (1.1GHz 




Sensor, ALS 

MSM8255 (1.0GHz 




MSM8255 (1.0GHz 







OMAP4 (1.0GHz dualcore) 



Autostereoscopic 3D 

Display 

MSM8255 (1.0GHz 




Exynos 4210 (1.0GHz 

dual-core) 



Sensor, ALS 

Hummingbird (1.2GHz 




Sensor, ALS 

MSM7230 (800MHz 




ALS 

MSM8655 (1.4GHz 




ALS 

OMAP 3630 (1.0GHz 




Touchstone Touchstone 700cd/m 2 brightness 

MSM8255 (1.0GHz 







MSM8255 (1.0GHz 





APLNDC0002230243


EXHIBIT 17


CONFIDENTIAL BUSINESS INFORMATION 

1 UNITED STATES INTERNATIONAL TRADE COMMISSION 

Page 1 

2 WASHINGTON, D.C. 

3 In the Matter of ) 

4 ) 

5 CERTAIN ELECTRONIC DEVICES, ) NO. 337-TA-794 

6 INCLUDING WIRELESS ) 

7 COMMUNICATION DEVICES, ) 

8 PORTABLE MUSIC AND DATA ) 

9 PROCESSING DEVICES AND ) 

10 TABLET COMPUTERS ) 

11 ---------------------------- 

12 

13 

14 *** 

15 CONFIDENTIAL BUSINESS INFORMATION 

16 *** 

17 

18 VIDEOTAPED DEPOSITION OF GREG JOSWIAK 

19 PALO ALTO, CALIFORNIA 

20 THURSDAY, FEBRUARY 23, 2012 

21 

22 

23 Reported By: 

24 Yvonne Fennelly, CCRR, CSR No. 5495 

25 JOB NO. 46686 

TSG Reporting - Worldwide - 877-702-9580



Page 118 

1 A. As far as an overall commodity? 

2 Q. Overall competitive strategy. 

3 A. Well, as I mentioned earlier, we 

4 certainly see Android as the key operating 

5 system competitor to our iOS devices. 12:25PM 

6 Q. What is the Android war room? 

7 A. Our marketing communications group, 

8 MarComm, as I referred to them earlier, has a 

9 room, a conference room, dedicated to 

10 understanding how Android handset makers are 12:25PM 

11 marketing themselves. 

12 Q. Does that conference room include a 

13 storage of documents? 

14 A. I have no idea. 

15 Q. Have you ever been to it? 12:26PM 

16 A. I have visited it, at least, on one 

17 occasion, and I don't recall documents, other 

18 than what is pasted on the walls, like, might 

19 show, you know, a print advertisement, for 

20 example, of the competitor. 12:26PM 

21 Q. So the room is decorated with the 

22 printing advertisements of competitors? 

23 MR. JACOBS: Objection to form. 

24 THE WITNESS: I don't know how it's 

25 decorated now. When I went to it again, there 12:26PM 




Page 119 

1 were certainly some things being presented in 

2 that way, but I have not visited that room in a 

3 very long time. 

4 BY MS. MAROULIS: 

5 Q. Are there regular meetings held in 12:26PM 

6 that room? 

7 A. I have no idea. 

8 As I said, I went to it at least 

9 once, but, perhaps, only once. 

10 Q. So the room functions as, 12:26PM 

11 essentially, a museum of other people's 

12 advertising? 

13 A. I don't think -- 


15 THE WITNESS: I don't think it's 12:26PM 

16 designed to be a museum. I think it's designed 

17 for our marketing people to understand how our 

18 competitor is marketing themselves. 


20 Q. And what is Apple's understanding of 12:27PM 

21 how its competitors market themselves? 


23 THE WITNESS: I don't think there is 

24 a way to generally answer that. I think they 

25 look at, again, specific advertisements, 12:27PM 




Page 120 

1 specific marketing, and draw the conclusions, 

2 I'm sure, based on each one of those. 


4 Q. Does the MarComm group generally 

5 report, based on their studies of how 12:27PM 

6 competitors present themselves in the 

7 marketplace? 

8 A. I'm unaware of any reports of that 

9 type. 

10 Q. Never seen one? 12:27PM 

11 A. Not that I can recall. 

12 Q. How does Apple track its performance 

13 against its competitors in terms of market 

14 share? 

15 MR. JACOBS: Objection; asked and 12:27PM 

16 answered. 

17 THE WITNESS: Yeah, I think it's 

18 exactly that answer. It's we look in market 

19 share. So we certainly look at the reports that 

20 I talked about earlier, for example, IDC and 12:27PM 

21 Gartner, to understand our market share and as 

22 that changes over time. 


24 Q. What is the current market share of 

25 Apple's iPhone products? 12:28PM 



EXHIBIT 18



NO. 649.001 



No. 11-CV-01846-LHK (PSG) 


Subject: Fwd: Sony Strives for Original Design (Business Week) 

Date: Wed, 22 Feb 2006 14:59:23 +0000 

From: "Tony Fadell" 

To: "Jony Ive" , "Steve Jobs" , "Greg (Joz) Jozwiak" 

, "Phil Schiller" 

Message-ID: 



FEBRUARY 22, 2006 

Newsmaker Q&A 

Sony Strives for Original Design 

A top strategist and designer from the electronics giant talk about the 

challenges of staying at the top of gearheads' wish lists 

Ever since former Chairman and Chief Executive Norio Ohga formed the 

company's first design team in 1961, Sony (SNE) has given geeky gadgets - 

from robot pets to video-game consoles -- a familiar cutting-edge coolness. 

Just pick up any Sony gizmo, and you'll see why the brand has so much cachet 

worldwide. 

But lately the competition has been whittling down Sony's edge. Plenty of 

onetime tech upstarts, from Samsung Electronics of Korea to China's Lenovo 

(LNVGF), have taken note of Sony's success and sought to copy it by setting 

up their own design shops. PC heavyweights such as Apple Computer (AAPL) are 

moving in as well: Since its debut in 2001, the iPod has far outsold Sony's 

Walkman in Japan, beating the electronics giant at its own game. 

These days, Sony designers aren't just eyeing the competition. They have had 

to cope with an internal organization in flux ever since last year's 

management shakeup, which was aimed at reinvigorating Sony's loss-making 

electronics division. The task of keeping the creative juices flowing falls 

partly on Takashi Ashida, 40. As the Creative Center's top strategist, he 

keeps tabs on a staff of 400, sprinkled across three continents -- in Tokyo, 

Los Angeles, London, Singapore, and, most recently, Shanghai. As Ashida puts 

it, designing is about "being original, not a copy." 

Fortunately for him, Sony has attracted plenty of young talent. Yujin 

Morisawa, 30, spent four years at New York-based design shop Karim Rashid, 

where he crafted perfume flasks and personal digital assistants, before 

joining Sony. He headed the team that redesigned the Walkman digital-music 

player, which was released in Japan last September and in Europe just last 

month. 

Ashida and Morisawa recently spoke with Business Week correspondent Kenji 


APLNDC0001207640



Hall in Tokyo about Sony's design process and the impact of last year's 

reorganization. Edited excerpts of the conversation follow: 

What is Sony's design philosophy? 

Ashida: The Sony spirit is about being original, not a copy. We generally 

don't rely on surveys, because we're always trying to make something that's 

never been done before. When Sony opened its first design center in 1961, 

the color theme was black and silver. The idea was to do away with excessive 

ornamentation. We're continuing that tradition. 

How has the environment changed for designers under the new management team 

headed by Chairman and CEO Howard Stringer? 

Ashida: There has been big change under Sir Howard and [President Ryoji] 

Chubachi. Before the Howard era, design teams were scattered into product 

groups. The disadvantage was you could lose touch of the overall Sony design 

strategy. 

Now we have a unified team of designers. They can freely talk with the 

software interface designer and the graphics designer without any 

limitations, without any walls. That's a big change over what we did for 

seven years. And designers now report directly to [Senior General Manager 

Keiji] Saito and [Senior Vice-President Masao] Morita, whereas before it was 

indirect reporting. 

Is the reorganization having the desired effect? 

Ashida: I think it's working. Morita is very much involved in the design 

process. We have weekly meetings on design confirmation. Previously, 

[Nobuyuki] Idei was the chairman and CEO, and was overseeing design, and 

obviously he was very busy. So we only had operational meetings once a 

month, but they weren't to cover design. 

Masao Morita also has a very important role in brand management. He's very 

active. His points are straightforward. His main concern is how to increase 

the visibility of the Sony brand. He's especially concerned about how the 

Sony logo is being treated, where it is on the product. And he's a very 

heavy user of products, so he's very strict on ease of use. 

Designers present to him, and there are tough discussions. Designers look at 

originality. But Morita will often ask, "How about the usability? What's the 

product concept? Who are you targeting?" You have to become the user when 

you design the products. He's going back to the basics of good product 

design. Some designers are good craftsmen, but you have to really think 

about the concept as well, how the product is being placed at home. Morita 

is challenging designers. 

The Walkman digital-music player recently got a makeover. Its corners have 

been rounded out, and its 20-gigabyte version can store 10,000 or more 

songs. [There's also an 8-gigabyte and 6-gigabyte type.] Released in Japan 

last September and in Europe in January, it's Sony's first product developed 


APLNDC0001207641



under the new management. Describe how you got started. 

Morisawa: There were five or six people from product planning and 

engineering already working on the Walkman when I joined last year. They 

asked me to design something that didn't look like any other music player. 

They said, "Do something new." These [photos of a trumpet, a flood-lighted 

concert stage, a darkened sky at dusk] are some of the images I showed to 

the team to get them to think about the concept. 

How much did the iPod influence your design? 

Morisawa: When I started this project, that was my concern. I looked at the 

first Walkman [which debuted in 1979]. Then I thought, "How can I give shape 

to the music?" Music doesn't have shape; it's flowing. I was listening to 

music and waving my hand in the air. I thought there shouldn't be an end to 

its lines. So I started drawing a round shape, and I kept moving the line. 

My team had shown me their sketch: It was a square with a screen and 

buttons. Most other players have a screen and buttons. My first mock-up 

didn't have buttons. I didn't want buttons. With any digital-music player, 

the hard disk drive and chips are similar. I thought, "How can we make the 

layout different?" I knew what would go inside, so I could start the design 

from the outside. I knew how big the hard disk drive would be, how many 

chips there would be. 

What challenges did you face in making sure the final product would look 

like your sketch? 

Morisawa: It's really tough to make something round. You can't really 

measure where the components are inside [the device] when using the CAD 

[computer-aided design] system. I didn't want the engineers to change the 

shape or the size. I didn't want something larger than this; it fits in your 

hand. 

I thought it had to be smooth on the back. The engineers wanted to make the 

back side flat. But I didn't want the flatness to bother you when you're 

listening to the music. I made two physical mock-ups for engineers so they 

could feel the difference. That's how I convinced them to keep working on 

this. Afterward, the engineers joked that they didn't want to work with me 

twice in a row. 

Are you satisfied with the design? 

Morisawa: Yes. 

What are you not satisfied with? 

Morisawa: The buttons. I want to say there's a way not to have buttons. 

The Walkman is bulkier than rivals' music players. The iPod nano, for 

instance, has been a hit among consumers who like its featherweight, compact 

size. How much was size a factor in the Walkman's new design? 

Morisawa: I told the project team, "It's not about the size." It's not a 

challenge for us to make it small. 


APLNDC0001207642



Ashida: In the past, the size of the media was important; it determined the 

size of the product. CD players could only be as small as the size of the 

CDs. Now there's no limitation. It's just silicon and components. I think 

the value has shifted to other things. For example, the Walkman has 

artificial intelligence [a feature called Artist Link that analyzes a 

consumer's tastes and suggests new songs], which the iPod doesn't have. 

------ end message ------ 


APLNDC0001207643

Apple Inc. v. Samsung Electronics Co. Ltd. et al, Docket No. 5:11-cv-01846 (N.D. Cal. Apr 15, 2011), Court Docket 

General Information 

Case Name 

Docket Number 

Court 

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

5:11-cv-01846 

United States District Court for the Northern District of California 

Primary Date 2011-04-15 00:00:00 

Nature of Suit 

Related Opinion(s) 

Property Rights: Patent 

2012 BL 165088 2012 BL 178771 2012 BL 205637 2012 BL 

263360 2012 BL 280780 2012 BL 330890 2013 BL 25223 2013 

BL 25225 2012 BL 56912 282 F.R.D. 259 2012 BL 92184 2012 

BL 100476 2012 BL 112507 2012 BL 119408 103 U.S.P.Q.2d 

1401 2012 BL 162535 2012 BL 173112 2012 BL 173061 881 

F. Supp. 2d 1132 2012 BL 209113 2012 BL 265144 2012 BL 

266278 2012 BL 273568 2012 BL 281306 2012 BL 258464 

2013 BL 25314 2013 BL 63524 2011 BL 304343 2012 BL 

238801 

© Bloomberg Finance L.P. All rights reserved. For terms of service see bloomberglaw.com // PAGE 1 

Document Link: http://www.bloomberglaw.com/ms/document/X1Q6LJBLEO82?documentName=1337.xml

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