Elan Microelectronics Corporation v. Apple, Inc.
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)
Greenblatt, Nathan [firstname.lastname@example.org]
Thursday, March 24, 2011 2:11 PM
Rathinasamy, Palani P.
Elan Apple Team; Apple Elan WGM Service
RE: Interrogatory No. 13
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.
Nathan A. Greenblatt
Weil, Gotshal & Manges LLP
201 Redwood Shores Parkway
Redwood Shores, CA 94065-1134
+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
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
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.
Palani P. Rathinasamy, Esq.
Alston + Bird LLP
275 Middlefield Road Suite 150
Menlo Park, CA 94025
Tel: 650-838-2027 | Fax: 650-838-2001
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