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

Filing 145

EXHIBITS re 144 Declaration in Support, Exhibits 15-25 to Declaration of Heather H. Martin filed byGoogle Inc.. (Attachments: # 1 Exhibit 16, # 2 Exhibit 17, # 3 Exhibit 18, # 4 Exhibit 19, # 5 Exhibit 20, # 6 Exhibit 21, # 7 Exhibit 22, # 8 Exhibit 23, # 9 Exhibit 24, # 10 Exhibit 25)(Related document(s) 144 ) (Candido, Amy) (Filed on 4/28/2012)

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EXHIBIT 15 quinn emanuel trial lawyers | washington, dc 1299 Pennsylvania Avenue NW, Suite 825, Washington, District of Columbia 20004-2400 | TEL: (202) 538-8000 FAX: (202) 538-8100 WRITER'S DIRECT DIAL NO. (202) 538-8126 WRITER'S EMAIL ADDRESS heathermartin@quinnemanuel.com April 23, 2012 VIA ELECTRONIC MAIL Jason Lo Gibson Dunn & Crutcher LLP 333 South Grand Avenue Los Angeles, California 90071-3197 jlo@gibsondunn.com Re: Apple Inc. v. Samsung Electronics Co., Ltd.. et al., No 12-630 (N.D. Cal.) Dear Mr. Lo: I write to finalize plans regarding the deposition of Ken Wakasa. As we discussed today, Mr. Wakasa lives and works in Tokyo, Japan, as does the team responsible for Android Keyboard, which Apple has accused of infringing the '172 patent. For unrelated reasons, however, Mr. Wakasa is in Mountain View for the rest of this week. Next week is Golden Week in Japan when, as I'm sure you know, the country essentially shuts down. For the two weeks after that, business and family commitments prevent Mr. Wakasa from leaving Japan; again, as you know, it would be illegal to depose him there. For all these reasons, we offered Mr. Wakasa on Thursday, April 26. In response, you said Apple could not be ready in time for this deposition, because it fell too soon after Samsung's opposition brief. In light of your statements, Mr. Wakasa has rearranged his schedule so he can be deposed a day later, Friday, April 27, 2012. The deposition will commence at 8:00 a.m. PDT, and will have a hard stop at 4:00 p.m. PDT, so that Mr. Wakasa can make his flight back to Japan in time for Golden Week. quinn emanuel urquhart & sullivan, llp LOS ANGELES | 865 South Figueroa Street, 10th Floor, Los Angeles, California 90017-2543 | TEL (213) 443-3000 FAX (213) 443-3100 51 Madison Avenue, 22nd Floor, New York, New York 10010-1601 | TEL (212) 849-7000 FAX (212) 849-7100 SAN FRANCISCO | 50 California Street, 22nd Floor, San Francisco, California 94111-4788 | TEL (415) 875-6600 FAX (415) 875-6700 SILICON VALLEY | 555 Twin Dolphin Drive, 5th Floor, Redwood Shores, California 94065-2139 | TEL (650) 801-5000 FAX (650) 801-5100 CHICAGO | 500 W. Madison Street, Suite 2450, Chicago, Illinois 60661-2510 | TEL (312) 705-7400 FAX (312) 705-7401 LONDON | 16 Old Bailey, London EC4M 7EG, United Kingdom | TEL +44 20 7653 2000 FAX +44 20 7653 2100 TOKYO | NBF Hibiya Building, 25F, 1-1-7, Uchisaiwai-cho, Chiyoda-ku, Tokyo 100-0011, Japan | TEL +81 3 5510 1711 FAX +81 3 5510 1712 MANNHEIM | Mollstra├če 42, 68165 Mannheim, Germany | TEL +49 621 43298 6000 FAX +49 621 43298 6100 MOSCOW | Voentorg Building, 3rd Floor, 10 Vozdvizhenka Street, Moscow 125009, Russia | TEL +7 495 797 3666 FAX +7 495 797 3667 NEW YORK | Jason Lo April 23, 2012 Page 2 We expect Apple to depose Mr. Wakasa on Friday. As you know, Apple's notice of deposition sought testimony that day on all four preliminary injunction patents. If you cannot actually take a deposition on only one of those patents, then we question the urgency of your case. Very truly yours, /s/ Heather H. Martin 01980.51871/4719710.1