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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EXHIBIT D Browder, Sissel From: Sent: To: Cc: Subject: Greenblatt, Nathan [nathan.greenblatt@weil.com] Thursday, March 24, 2011 2:11 PM Rathinasamy, Palani P. Elan Apple Team; Apple Elan WGM Service RE: Interrogatory No. 13 Palani, As your email below notes, Apple has provided model names and internal development code names for the accused products, which is more than sufficient to allow Elan to review our document production and source code for information relevant to the design, development, function, structure and operation of the accused functionalities. It is unclear how Elan believes external model numbers would be relevant to the issues in the case, but as you note, they are available from Apple's website by searching for each product at http://support.apple.com/specs. To the extent there is some external model number information that you believe is missing from the website, please let us know specifically what it is and why you believe you need it and we will consider your request. Best, Nathan Nathan A. Greenblatt Weil, Gotshal & Manges LLP 201 Redwood Shores Parkway Redwood Shores, CA 94065-1134 nathan.greenblatt@weil.com +1 650 802 3251 Direct +1 650 802 3100 Fax From: Rathinasamy, Palani P. [mailto:Palani.Rathinasamy@alston.com] Sent: Tuesday, March 15, 2011 7:00 PM To: Greenblatt, Nathan Cc: Elan Apple Team; Apple Elan WGM Service Subject: Interrogatory No. 13 Nathan, I write regarding deficiencies in Apple's response to Elan's Interrogatory No. 13. Interrogatory No. 13 requires that Apple: "Identify by each unique product name, product code, product model and/or any other product nomenclatures each Apple Product designed, made, used, sold, offered for sale, imported, or distributed by Apple." While Apple has identified products by broad model name (e.g. PowerBook) and by internal development code, it has not provided the full model names or the external product numbers it used to differentiate among version of those products. For example, Apple's web site lists three different specification sheets for PowerBook computers released in April of 2004. Those include the PowerBook G4 12 Inch, 17 inch and 15 inch versions. Those specifications further refer to various model numbers, for example M9183LL/A, M9184LL/A, M9421LL/A, M9422LL/A and M9462LL/A. However, Interrogatory No. 13 requests all product model names/numbers used to identify these products. As Apple did not identify at least the aforementioned model numbers, Apple has 1 not provided a complete response and should immediately update these responses to include all external model names and numbers used to identify the Accused Products. I am available this Thursday, 1:00 PM PST, to meet and confer regarding this issue. Best Regards, Palani Palani P. Rathinasamy, Esq. Alston + Bird LLP 275 Middlefield Road Suite 150 Menlo Park, CA 94025 Tel: 650-838-2027 | Fax: 650-838-2001 palani.rathinasamy@alston.com http://www.alston.com/palani_rathinasamy/ ******************************************************* IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS and other taxing authorities, we inform you that any tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties that may be imposed on any taxpayer or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. ______________________________________________________ NOTICE: This e-mail message and all attachments transmitted with it may contain legally privileged and confidential information intended solely for the use of the addressee. If the reader of this message is not the intended recipient, you are hereby notified that any reading, dissemination, distribution, copying, or other use of this message or its attachments is strictly prohibited. If you have received this message in error, please notify the sender immediately by telephone (404881-7000) or by electronic mail (postmaster@alston.com), and delete this message and all copies and backups thereof. Thank you. The information contained in this email message is intended only for use of the individual or entity named above. If the reader of this message is not the intended recipient, or the employee or agent responsible to deliver it to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please immediately notify us by email (postmaster@weil.com), and destroy the original message. Thank you. 2

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