Elan Microelectronics Corporation v. Apple, Inc.
Filing
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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)
yitai.hu@alston.com
SEAN P. DEBRUINE (SBN 168071)
sean.debruine@alston.com
ELIZABETH H. RADER (SBN 184963)
elizabeth.rader@alston.com
JANE HAN BU (SBN 240081)
jane.bu@alston.com
JENNIFER LIU (SBN 268990)
celine.liu@alston.com
PALANI P. RATHINASAMY (SBN 269852)
palani.rathinasamy@alston.com
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).
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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).
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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).
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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.
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Attached as Exhibit L is a true and correct copy of Apple schematics bearing the
production range APEL1092555-57 (filed under seal).
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Attached as Exhibit M is a true and correct copy of an Apple internal e-mail
bearing the production number APEL0501275 (filed under seal).
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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)
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