Elan Microelectronics Corporation v. Apple, Inc.

Filing 320

Declaration of Jane H. Bu in Support of 319 Opposition/Response to Motion to Compel Elan Witness Depositions in the Northern District of California filed byElan Microelectronics Corporation. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5)(Related document(s) 319 ) (Bu, Jane) (Filed on 7/1/2011)

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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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ELAN MICROELECTRONICS
CORPORATION,

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v.

Plaintiff and Counterdefendant,

APPLE, INC.,
Defendant and Counterplaintiff.

Case No. 09-cv-01531 RS (PSG)
DECLARATION OF JANE H. BU IN
SUPPORT OF ELAN
MICROELECTRONICS
CORPORATION’S OPPOSITION TO
APPLE, INC.’S MOTION TO COMPEL
ELAN WITNESS DEPOSITIONS IN THE
NORTHERN DISTRICT OF
CALIFORNIA

AND RELATED COUNTERCLAIMS

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DECL. OF JANE H. BU ISO ELAN’S OPP’N TO APPLE’S MOTION
TO COMPEL

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

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I, Jane H. Bu, declare as follows:

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1.

I am an attorney with the law firm of Alston & Bird LLP, counsel to Plaintiff Elan

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Microelectronics Corporation (“Elan”) in this action. I have personal knowledge of the following

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facts and, if called to testify, I could and would testify competently to the matters stated herein.

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2.

On May 23, 2011, Apple issued nine individual deposition notices to Elan’s

employees in Taiwan for the NDCA case.
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On May 27, 2011, Apple issued its first 30(b)(6) Deposition Notice to Elan in the

NDCA case.
4.

On June 9, 2011, after Elan had a chance to investigate and search for the most

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suitable 30(b)(6) designees, Elan served its responses and objections to the 30(b)(6) deposition

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notice to Apple . Attached as Exhibit 1 is a true and correct copy of the June 9, 2011 Responses

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and Objections to Apple’s 30(b)(6) Deposition Notice.

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5.

Attached as Exhibits 2 and 3 are true and correct copies of the First and Second Set

of 30(b)(6) Deposition Notices issued by Apple in the parallel ITC Case.
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Attached as Exhibit 4 is a true and correct copy of Elan’s Fourth Supplemental

Response to Apple’s Interrogatories 5, 7, and 11 dated June 23, 2011.
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Attached as Exhibit 5 is a true and correct copy of Apeldyn Corp. v Au Optronics

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Corp, Civil Action No. 08-568-SLR, Dtk 380, December 13, 2010 Order Denying Motion to

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Compel Deposition in U.S.

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I swear under penalty of perjury under the laws of the United States that the foregoing is
true and correct. Executed this 1st day of July, 2011 at Menlo Park, California.

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/s/ Jane H. Bu
Jane H Bu

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LEGAL02/32716033v2

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DECL. OF JANE H. BU ISO ELAN’S OPP’N TO APPLE’S MOTION
TO COMPEL

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