"The Apple iPod iTunes Anti-Trust Litigation"

Filing 334

Declaration of Beth Kellermann in Support of 332 Memorandum in Opposition To Plaintiffs' Motion To Compel filed byApple Inc.. (Related document(s) 332 ) (Kiernan, David) (Filed on 3/2/2010)

"The Apple iPod iTunes Anti-Trust Litigation"

Doc. 334

Case5:05-cv-00037-JW Document334

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Robert A. Mittelstaedt #60359 [e-mail] Craig E. Stewart #129530 [e-mail] David C. Kiernan #215335 [e-mail] Michael T. Scott #255282 [e-mail] JONES DAY 555 California Street, 26th Floor San Francisco, CA 94104 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant APPLE INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION

THE APPLE iPOD iTUNES ANTI-TRUST LITIGATION.

Case No. C 05-00037 JW (HRL) C 06-04457 JW (HRL) DECLARATION OF BETH KELLERMANN IN SUPPORT OF APPLE INC.'S OPPOSITION TO PLAINTIFFS' MOTION TO COMPEL Magistrate Judge Howard R. Lloyd Date: March 23, 2010 Time: 9:00 a.m. Courtroom 2, 5th Floor

I, Beth Kellermann, declare as follows: 1. I am the Litigation eDiscovery Manager at Apple Inc. and am familiar with how

Apple maintains inquiries it receives from customers relating to the iPod product line and the iTunes Store ("iTS"). The facts stated in this declaration are true and based upon personal knowledge or on information I gathered from employees of Apple Inc. and, if called to testify to them, I would competently do so. -1White Decl. ISO Defendant's Opposition To Motion To Compel C 05 00037 JW (HRL), C 06-04457 JW (HRL)

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Case5:05-cv-00037-JW Document334

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2.

Apple maintains inquiries it receives from its customers in the U.S. for the iPod

product line in its Global Customer Relationship Management Database ("GCRM"). Using criteria provided by counsel to search GCRM, there are approximately 191,000 inquiries that Apple received from June 1, 2007 through March 31, 2009 for the iPod product line to be reviewed. Each inquiry must still be manually reviewed to determine whether it is relevant to plaintiffs' request. 3. Apple maintains inquiries it receives from its customers regarding iTS in its Sonar

database. Using criteria provided by counsel to search Sonar, there are approximately 17,000 inquiries that Apple received between June 1, 2007 and March 31, 2009. Each inquiry must still be manually reviewed to determine whether it is relevant to plaintiffs' request. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed this 2nd day of March, 2010 in Cupertino, California.

/s/ Beth Kellermann________________ Beth Kellermann I, as filer, attest that Beth Kellermann has concurred in the filing of this document pursuant to General Order No. 45. /s/ David C. Kiernan_______________ David C. Kiernan
SFI-631004v2

20 21 22 23 24 25 26 27 28 -2Decl. ISO Defendant's Opposition To Motion To Compel C 05 00037 JW (HRL), C 06-04457 JW (HRL)