Elan Microelectronics Corporation v. Apple, Inc.

Filing 251

Declaration of Palani P. Rathinasamy in Support of 249 MOTION to Compel Apple, Inc. to Produce Testing Tool (Public Version) filed byElan Microelectronics Corporation. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P, # 17 Exhibit Q)(Related document(s) 249 ) (Rathinasamy, Palani) (Filed on 6/7/2011)

EXHIBIT H

Browder, Sissel
From:
Sent:
To:
Cc:
Subject:

Rathinasamy, Palani P.
Tuesday, April 12, 2011 7:41 AM
[e-mail]
Apple Elan WGM Service; Elan Apple Team

Derek,
We have re-reviewed the documents you identified during the meet and confer last Tuesday,
April 5, regarding the
tool. As we discussed during the call, although
we are agreeable to the method Sonal proposed for the inspection of the tool, without seeing
or using the actual tool, we cannot meaningfully propose a test protocol as requested. As
such, for a starting point, we propose to have an initial inspection of the tool, at the
facility of Apple's choice, subject to the source code provision of the protective order, for
our outside counsel and/or expert to simply get familiar with the operation of the tool.
After the initial inspection, the parties then can meet and confer to agree upon the contour
and details of the live testing and the related document production resulted from such tests.
Please let us know by Friday, April 15, whether you are agreeable to this proposal.
Thanks,
Palani

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