Elan Microelectronics Corporation v. Apple, Inc.

Filing 210

Declaration of Palani P. Rathinasamy in Support of 209 MOTION to Compel Apple to Supplement Its Response to Elan's Interrogatory No. 13 filed byElan Microelectronics Corporation. (Attachments: # 1 Exhibit A, # 2 Exhibit B-MFN, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E-MFN, # 6 Exhibit F-MFN, # 7 Exhibit G-MFN, # 8 Exhibit H-MFN, # 9 Exhibit I-MFN, # 10 Exhibit J-MFN, # 11 Exhibit K, # 12 Exhibit L-MFN, # 13 Exhibit M-MFN)(Related document(s) 209 ) (Rathinasamy, Palani) (Filed on 5/24/2011)

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YITAI HU (SBN 248085)
[e-mail]
SEAN P. DEBRUINE (SBN 168071)
[e-mail]
ELIZABETH H. RADER (SBN 184963)
[e-mail]
JANE HAN BU (SBN 240081)
[e-mail]
JENNIFER LIU (SBN 268990)
[e-mail]
PALANI P. RATHINASAMY (SBN 269852)
[e-mail]
ALSTON & BIRD LLP
275 Middlefield Road, Suite 150
Menlo Park, CA 94025-4008
Telephone:
650-838-2000
Facsimile:
650-838-2001
Attorneys for Plaintiff and Counterdefendant
ELAN MICROELECTRONICS
CORPORATION

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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DECLARATION OF PALANI P.
RATHINASAMY IN SUPPORT OF
ELAN MICROELECTRONICS
CORPORATION’S MOTION TO
COMPEL APPLE TO SUPPLEMENT
ITS RESPONSE TO ELAN’S
INTERROGATORY NO. 13

Plaintiff,

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Case No. 09-cv-01531 RS (PSG)

ELAN MICROELECTRONICS
CORPORATION,

v.
APPLE, INC.,
Defendant.

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DATE: June 28, 2011
TIME: 10:00 a.m.
Courtroom 5
Hon. Paul S. Grewal

AND RELATED COUNTERCLAIMS

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DECL. OF PALANI P. RATHINASAMY ISO PL. ELAN’S MOT. TO
COMPEL APPLE TO SUPPLEMENT ITS RESPONSE TO ELAN’S
INTERROG. NO. 13

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Case No. 09-cv-01531 RS (PSG)

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I, Palani P. Rathinasamy, declare as follows:

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1.

I am an associate with the law firm of Alston & Bird LLP, counsel to Elan in this

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action. I have personal knowledge of the following facts and, if called to testify, I could and

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would testify competently to the matters stated herein.
2.

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Attached as Exhibit A is a true and correct copy of Plaintiff Elan Microelectronics

Corporation’s Second Set of Interrogatories to Defendant Apple Inc. [Nos. 13-15].
3.

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Attached as Exhibit B is a true and correct copy of Apple Inc.’s Responses and

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Objections to Elan Microelectronics Corporation’s Second Set of Interrogatories to Apple Inc.

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[Nos. 13-15] (filed under seal).
4.

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2011 from Elan’s Counsel, Palani P. Rathinasamy, to Apple’s Counsel, Nathan Greenblatt.
5.

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Attached as Exhibit C is a true and correct copy of an e-mail sent on March 15,

Attached as Exhibit D is a true and correct copy of an e-mail sent on March 24,

2011 from Apple’s Counsel, Nathan Greenblatt, to Elan’s Counsel, Palani P. Rathinasamy.
6.

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Attached as Exhibit E is a true and correct copy of an e-mail sent on March 29,

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2011 from Apple’s Counsel, Sonal Mehta, to Elan’s Counsel, Palani P. Rathinasamy (filed under

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seal).

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7.

Attached as Exhibit F is a true and correct copy of Apple Inc.’s Supplemental

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Response and Objections to Elan Microelectronics Corporation’s Interrogatory No. 13 (filed

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under seal).

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8.

Attached as Exhibit G is a true and correct copy of an e-mail sent on April 1, 2011

from Elan’s Counsel, Jane Bu, to Apple’s Counsel, Derek Walter (filed under seal).
9.

Attached as Exhibit H is a true and correct copy of an e-mail sent on May 11, 2011

from Elan’s Counsel, Palani P. Rathinasamy, to Apple’s Counsel, Derek Walter (filed under seal).
10.

Attached as Exhibit I is a true and correct copy of an e-mail sent on May 2, 2011

from Elan’s Counsel, Palani P. Rathinasamy to Apple’s Counsel, Derek Walter (filed under seal).
11.

Attached as Exhibit J is a true and correct copy of an e-mail sent on May 6, 2011

from Apple’s Counsel, Derek Walter, to Elan’s Counsel, Palani P. Rathinasamy (filed under seal).
12.

Attached as Exhibit K is a true and correct copy of a screenshot taken from Apple’s

DECL. OF PALANI P. RATHINASAMY ISO PL. ELAN’S MOT. TO
COMPEL APPLE TO SUPPLEMENT ITS RESPONSE TO ELAN’S
INTERROG. NO. 13

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Case No. 09-cv-01531 RS (PSG)

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website (http://support.apple.com/kb/SB12) on May 24, 2011.
13.

Attached as Exhibit L is a true and correct copy of Apple schematics bearing the

production range APEL1092555-57 (filed under seal).
14.

Attached as Exhibit M is a true and correct copy of an Apple internal e-mail

bearing the production number APEL0501275 (filed under seal).
15.

I conducted in good faith a telephonic meet and confer with Apple’s Derek Walter

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on April 5, 2011 and exchanged multiple e-mails with Apple’s counsel in an effort to obtain

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supplementation of Elan’s Interrogatory No.13 without Court action.

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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 this 24th day of May, 2011 at Menlo Park, California.

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DATED: May 24, 2011

Respectfully submitted,
ALSTON & BIRD LLP

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By:

/s/ Palani P. Rathinasamy
Palani P. Rathinasamy
Attorneys for Plaintiff
ELAN MICROELECTRONICS CORPORATION

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DECL. OF PALANI P. RATHINASAMY ISO PL. ELAN’S MOT. TO
COMPEL APPLE TO SUPPLEMENT ITS RESPONSE TO ELAN’S
INTERROG. NO. 13

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Case No. 09-cv-01531 RS (PSG)