Elan Microelectronics Corporation v. Apple, Inc.

Filing 325

Letter from Jane Bu regarding July 5, 2011 Hearing on Apple's Motion to Compel and Supplemental Exhibits in Support of Elan's Opposition to Motion to Compel. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D)(Bu, Jane) (Filed on 7/6/2011)

EXHIBIT A

Elan's Privilege Log - July 1, 2010 (2nd Revision)
Revised July 1, 2011
ELAN MICROELECTRONICS CORPORATION'S PRIVILEGE LOG - JULY 1, 2010 (SECOND REVISION)
NO.

NEW
NO.

AUTHOR

RECIPIENT

COPY RECIPIENT

DESCRIPTION

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Irrelevant and non-responsive

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PORTION
WITHHELD

Elan will produce

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PRIVILEGE
ASSERTED

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Elan will produce

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DATE

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Irrelevant and non-responsive
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1

Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)

NO.

NEW
NO.

AUTHOR

RECIPIENT

COPY RECIPIENT

DESCRIPTION

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Elan's Privilege Log - July 1, 2010 (2nd Revision)
Revised July 1, 2011
PRIVILEGE
PORTION
DATE
ASSERTED
WITHHELD

Already produced
Elan will produce
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Elan will produce
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Elan will produce
Elan will produce
Irrelevant and non-responsive
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Irrelevant and non-responsive
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Irrelevant and non-responsive
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Already produced
2

Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)

NO.

NEW
NO.

AUTHOR

RECIPIENT

COPY RECIPIENT

DESCRIPTION

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Elan's Privilege Log - July 1, 2010 (2nd Revision)
Revised July 1, 2011
PRIVILEGE
PORTION
DATE
ASSERTED
WITHHELD

Already produced
Already produced
Already produced
Already produced
Already produced
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Already produced
Already produced
Irrelevant and non-responsive
Irrelevant and non-responsive
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Irrelevant and non-responsive
Already produced
3

Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)

NO.

NEW
NO.

AUTHOR

RECIPIENT

COPY RECIPIENT

DESCRIPTION

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1

Bill Tsai (Elan Legal)

Wen-Kai Lee, Samuel Hsu,
Alfie Tsai, Jan Chen

I.H. Yeh, Wayne Chang (Elan
Legal), WF Lu, Ji-Han Liu (Elan
Legal), Nick Lin (Elan Legal)

167

168

Elan's Privilege Log - July 1, 2010 (2nd Revision)
Revised July 1, 2011
PRIVILEGE
PORTION
DATE
ASSERTED
WITHHELD

Elan internal communication with work product
prepared by U.S. counsel for purposes of
providing legal advice re U.S. patent
prosecution.

11/28/2008

AC/WP

Entire
Document

Elan internal communication with attachment(s)
prepared under the instruction of U.S. counsel
11/24/2008
for purposes of seeking legal advice re U.S.
patent prosecution.

AC/WP

Entire
Document

Already produced

2

Jan Chen

Samuel Hsu, Ji-Han Liu (Elan
Legal)

Phoenix Lin, Alfie Tsai, WF Lu

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Irrelevant and non-responsive
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Elan will produce
Elan will produce
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4

Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)

NO.

NEW
NO.

AUTHOR

RECIPIENT

COPY RECIPIENT

DESCRIPTION

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Elan's Privilege Log - July 1, 2010 (2nd Revision)
Revised July 1, 2011
PRIVILEGE
PORTION
DATE
ASSERTED
WITHHELD

Already produced
Already produced
Already produced
Already produced
Already produced
Already produced
Already produced
Already produced
Already produced
Already produced
Already produced
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Already produced

Document prepared under the instruction of
U.S. counsel and to provide to U.S. counsel for 11/19/2009
purposes of the Elan v. Apple litigation.

211

3

Elan Legal Department

212

4

Bill Tsai (Elan Legal)

Core Far Intellectual Property
Office (Outside Counsel)

Eve Chang (Elan Legal)

213

5

Bill Tsai (Elan Legal)

Core Far Intellectual Property
Office (Outside Counsel)

Eve Chang (Elan Legal)

214

6

Bill Tsai (Elan Legal)

Core Far Intellectual Property
Office (Outside Counsel)

Eve Chang (Elan Legal)

215

7

Bill Tsai (Elan Legal)

Core Far Intellectual Property
Office (Outside Counsel)

Eve Chang (Elan Legal)

216

8

Bill Tsai (Elan Legal)

Core Far Intellectual Property
Office (Outside Counsel)

Eve Chang (Elan Legal)

217

9

Core Far Intellectual
Property Office (Outside
Counsel)

Eve Chang (Elan Legal), Bill
Tsai (Elan Legal)

218

10

Core Far Intellectual
Property Office (Outside
Counsel)

Eve Chang (Elan Legal), Bill
Tsai (Elan Legal)

Communication with outside counsel for
purposes of seeking legal advice re patent
prosecution.
Communication with outside counsel for
purposes of seeking legal advice re patent
prosecution.
Communication with outside counsel for
purposes of seeking legal advice re patent
prosecution.
Communication with outside counsel for
purposes of seeking legal advice re patent
prosecution.
Communication with outside counsel for
purposes of seeking legal advice re patent
prosecution.
Communication with outside counsel with work
product prepared by outside counsel for
purposes of providing legal advice re patent
prosecution.
Communication with outside counsel for
purposes of providing legal advice re patent
prosecution.

5

WP

Entire
Document

5/11/2009

AC

Entire
Document

9/13/2009

AC

Entire
Document

4/23/2009

AC

Entire
Document

7/29/2008

AC

Entire
Document

7/24/2008

AC

Entire
Document

7/29/2008

AC/WP

Entire
Document

7/24/2008

AC

Entire
Document

Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)

NO.

NEW
NO.

AUTHOR

RECIPIENT

219

11

Core Far Intellectual
Property Office (Outside
Counsel)

Eve Chang (Elan Legal), Bill
Tsai (Elan Legal)

220

12

221

13

222

14

Hsiao-Chang Lu (Outside
Counsel)

Elan Legal Department

223

15

Hsiao-Chang Lu (Outside
Counsel)

Elan Legal Department

224

16

Jia-Mei Long (Outside
Counsel)

Eve Chang (Elan Legal)

225

17

Vivian Fan (Outside
Counsel)

Eve Chang (Elan Legal)

226

18

227

19

Yang Wu (Outside
Counsel)

Elan Legal Department

228

20

Core Far Intellectual
Property Office (Outside
Counsel)

Eve Chang (Elan Legal)

229

21

Core Far Intellectual
Property Office (Outside
Counsel)

Wayne Chang (Elan Legal),
Eve Chang (Elan Legal)

230

22

Vivian Fan (Outside
Counsel)

Eve Chang (Elan Legal)

231

23

Vivian Fan (Outside
Counsel)

Eve Chang (Elan Legal)

232

24

Roven Lee

Elan Legal Department, Core
Far Intellectual Property
Office (Outside Counsel)

233

25

Core Far Intellectual
Property Office (Outside
Counsel)

Eve Chang (Elan Legal)

Core Far Intellectual
Property Office (Outside
Counsel)
Core Far Intellectual
Property Office (Outside
Counsel)

COPY RECIPIENT

DESCRIPTION
Communication with outside counsel with work
product prepared by outside counsel for
purposes of providing legal advice re patent
prosecution.
Communication with outside counsel for
purposes of providing legal advice re patent
prosecution.
Communication with outside counsel for
purposes of providing legal advice re patent
prosecution.
Communication with outside counsel for
purposes of providing legal advice re patent
prosecution.
Communication with outside counsel with work
product prepared by outside counsel for
purposes of providing legal advice re patent
prosecution.
Communication with outside counsel for
purposes of providing legal advice re patent
prosecution.
Communication with outside counsel for
purposes of providing legal advice re patent
prosecution.
Communication with outside counsel for
purposes of providing legal advice re patent
prosecution.
Communication with outside counsel for
purposes of providing legal advice re patent
prosecution.
Communication with outside counsel with work
product prepared by outside counsel for
purposes of providing legal advice re patent
prosecution.
Communication with outside counsel with work
product prepared by outside counsel for
purposes of providing legal advice re patent
prosecution.
Communication with outside counsel for
purposes of providing legal advice re patent
prosecution.
Communication with outside counsel with work
product prepared by outside counsel for
purposes of providing legal advice re patent
prosecution.

Elan's Privilege Log - July 1, 2010 (2nd Revision)
Revised July 1, 2011
PRIVILEGE
PORTION
DATE
ASSERTED
WITHHELD

Hsiao-Chang Lu (Outside Core Far Intellectual Property
Counsel)
Office (Outside Counsel)

Ji-Han Liu (Elan Legal)
6

Entire
Document

3/27/2009

AC

Entire
Document

8/30/2009

AC

Entire
Document

12/23/2005

AC

Entire
Document

3/9/2006

AC/WP

Entire
Document

3/27/2009

AC

Entire
Document

7/25/2008

AC

Entire
Document

7/28/2008

AC

Entire
Document

5/30/2003

AC

Entire
Document

5/22/2006

AC/WP

Entire
Document

1/26/2006

AC/WP

Entire
Document

5/22/2006

AC

Entire
Document

1/26/2006

AC/WP

Entire
Document

2/24/2006

AC

Entire
Document

Communication with outside counsel for
purposes of providing legal advice re patent
prosecution.

Eve Chang (Elan Legal), Bill
Tsai (Elan Legal)

AC/WP

Communication with outside counsel for
purposes of seeking legal advice re patent
prosecution.

Eve Chang (Elan Legal), Bill
Tsai (Elan Legal)

5/7/2009

3/4/2007

AC

Entire
Document

Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)

NO.

NEW
NO.

AUTHOR

RECIPIENT

COPY RECIPIENT

234

26

Core Far Intellectual
Property Office (Outside
Counsel)

Eve Chang (Elan Legal)

Ji-Han Liu (Elan Legal)

235

27

Eve Chang (Elan Legal)

Ji-Han Liu (Elan Legal)

236

28

Eve Chang (Elan Legal)

Gracie Lo (Elan Legal)

237

29

Core Far Intellectual
Property Office (Outside
Counsel)

Eve Chang (Elan Legal)

238

30

Ji-Han Liu (Elan Legal)

Core Far Intellectual Property
Office (Outside Counsel)

Eve Chang (Elan Legal)

Wayne Chang (Elan Legal), Eve
Chang (Elan Legal)

239

Core Far Intellectual
Property Office (Outside
Counsel)
Core Far Intellectual
Property Office (Outside
Counsel)

31

Ji-Han Liu (Elan Legal)

Godwin Chiu

240

32

Core Far Intellectual
Property Office (Outside
Counsel)

33

Ji-Han Liu (Elan Legal)

Core Far Intellectual Property
Office (Outside Counsel)

Eve Chang (Elan Legal)

242

34

Ji-Han Liu (Elan Legal)

Core Far Intellectual Property
Office (Outside Counsel)

Eve Chang (Elan Legal)

243

35

Core Far Intellectual
Property Office (Outside
Counsel)

Eve Chang (Elan Legal)

Ji-Han Liu (Elan Legal)

244

36

Core Far Intellectual
Property Office (Outside
Counsel)

Eve Chang (Elan Legal)

245

37

Ji-Han Liu (Elan Legal)

Core Far Intellectual Property
Office (Outside Counsel)

Eve Chang (Elan Legal)

246

38

Ji-Han Liu (Elan Legal)

Core Far Intellectual Property
Office (Outside Counsel)

Eve Chang (Elan Legal)

247

39

Core Far Intellectual
Property Office (Outside
Counsel)

Ji-Han Liu (Elan Legal)

Communication with outside counsel with work
product prepared by outside counsel for
purposes of providing legal advice re patent
prosecution.
Communication with outside counsel for
purposes of providing legal advice re patent
prosecution.
Communication with outside counsel for
purposes of providing legal advice re patent
prosecution.
Communication with outside counsel with work
product prepared by outside counsel for
purposes of providing legal advice re patent
prosecution.
Communication with outside counsel for
purposes of seeking legal advice re patent
prosecution.

Eve Chang (Elan Legal),
Gracie Lo (Elan Legal)

241

DESCRIPTION

Eve Chang (Elan Legal)

Elan internal communication with work product
prepared by U.S. counsel for purposes of
providing legal advice re U.S. patent
prosecution.
Communication with outside counsel with work
product prepared by outside counsel for
purposes of providing legal advice re patent
prosecution.
Communication with outside counsel for
purposes of seeking legal advice re patent
prosecution.
Communication with outside counsel for
purposes of seeking legal advice re patent
prosecution.
Communication with outside counsel for
purposes of providing legal advice re patent
prosecution.
Communication with outside counsel with work
product prepared by outside counsel for
purposes of providing legal advice re patent
prosecution.
Communication with outside counsel with
attachment(s) prepared under the instruction of
outside counsel for purposes of seeking legal
advice re patent prosecution.
Communication with outside counsel with
attachment(s) prepared under the instruction of
outside counsel for purposes of seeking legal
advice re patent prosecution.
Communication with outside counsel for
purposes of providing legal advice re patent
prosecution.

7

Elan's Privilege Log - July 1, 2010 (2nd Revision)
Revised July 1, 2011
PRIVILEGE
PORTION
DATE
ASSERTED
WITHHELD
4/18/2007

AC/WP

Entire
Document

4/3/2007

AC

Entire
Document

5/16/2007

AC

Entire
Document

8/11/2006

AC/WP

Entire
Document

4/12/2007

AC

Entire
Document

4/18/2007

AC/WP

Entire
Document

5/3/2007

AC/WP

Entire
Document

1/10/2007

AC

Entire
Document

3/6/2007

AC

Entire
Document

3/7/2007

AC

Entire
Document

5/3/2007

AC/WP

Entire
Document

1/25/2007

AC/WP

Entire
Document

4/10/2007

AC/WP

Entire
Document

1/25/2007

AC

Entire
Document

Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)

NO.

NEW
NO.

AUTHOR

RECIPIENT

COPY RECIPIENT

DESCRIPTION

Elan's Privilege Log - July 1, 2010 (2nd Revision)
Revised July 1, 2011
PRIVILEGE
PORTION
DATE
ASSERTED
WITHHELD

Elan internal communication with attachment(s)
prepared under the instruction of U.S. counsel
10/10/2006
for purposes of seeking legal advice re U.S.
patent prosecution.

248

40

Ji-Han Liu (Elan Legal)

Eve Chang (Elan Legal)

249

41

Core Far Intellectual
Property Office (Outside
Counsel)

Eve Chang (Elan Legal)

250

42

Core Far Intellectual
Property Office (Outside
Counsel)

Eve Chang (Elan Legal)

251

43

Core Far Intellectual
Property Office (Outside
Counsel)

Eve Chang (Elan Legal)

Ji-Han Liu (Elan Legal)

252

44

Core Far Intellectual
Property Office (Outside
Counsel)

Eve Chang (Elan Legal)

Ji-Han Liu (Elan Legal)

253

45

Core Far Intellectual
Property Office (Outside
Counsel)

Eve Chang (Elan Legal)

Ji-Han Liu (Elan Legal)

254

46

Yu-Wei Wang (Outside
Counsel)

Eve Chang (Elan Legal)

255

47

Yu-Wei Wang (Outside
Counsel)

Eve Chang (Elan Legal)

256

48

Rosenberg Klein & Lee
(Outside Counsel)

257

49

Yu-Wei Wang (Outside
Counsel)

Eve Chang (Elan Legal)

258

50

Vivian Fan (Outside
Counsel)

Eve Chang (Elan Legal)

259

51

Vivian Fan (Outside
Counsel)

Eve Chang (Elan Legal)

260

52

Elan Legal Department

Communication with outside counsel for
purposes of providing legal advice re patent
prosecution.
Communication with outside counsel with work
product prepared by outside counsel for
purposes of providing legal advice re patent
prosecution.
Communication with outside counsel with work
product prepared by outside counsel for
purposes of providing legal advice re patent
prosecution.
Communication with outside counsel for
purposes of providing legal advice re patent
prosecution.
Communication with outside counsel with work
product prepared by outside counsel for
purposes of providing legal advice re patent
prosecution.
Communication with outside counsel for
purposes of providing legal advice re patent
prosecution.
Communication with outside counsel for
purposes of providing legal advice re patent
prosecution.
Communication with U.S. counsel with work
product prepared by U.S. counsel for purposes
of providing legal advice re U.S. patent
prosecution.
Communication with outside counsel for
purposes of providing legal advice re patent
prosecution.
Communication with outside counsel with work
product prepared by outside counsel for
purposes of providing legal advice re patent
prosecution.
Communication with outside counsel for
purposes of providing legal advice re patent
prosecution.

Document prepared under the instruction of
U.S. counsel for purposes of seeking legal
advice re the Elan v. Apple litigation.

8

AC/WP

Entire
Document

9/21/2006

AC

Entire
Document

7/16/2006

AC/WP

Entire
Document

3/27/2007

AC/WP

Entire
Document

12/19/2006

AC

Entire
Document

4/10/2007

AC/WP

Entire
Document

3/28/2007

AC

Entire
Document

12/19/2006

AC

Entire
Document

10/22/2009

AC/WP

Entire
Document

12/19/2006

AC

Entire
Document

6/12/2006

AC/WP

Entire
Document

7/19/2007

AC

Entire
Document

4/14/2009

WP

Entire
Document

Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)

NO.

NEW
NO.

AUTHOR

RECIPIENT

COPY RECIPIENT

261

53

Wayne Chang (Elan
Legal)

Ming-Tao Yang (Outside
Counsel)

Yitai Hu (Outside Counsel)

262

54

A2E Technologies

Akin Gump (Outside Counsel)

Wayne Chang (Elan Legal)

264

55

A2E Technologies

265

56

A2E Technologies

266

57

Wayne Chang (Elan
Legal)

Roven Lee

Godwin Chiu

267

58

Sean DeBruine (Outside
Counsel)

Wayne Chang (Elan Legal)

Akin Gump (Outside Counsel)

268

59

A2E Technologies

Elan Legal Department

273

60

Chipworks, Inc.

Elan Legal Department

274

61

Chipworks, Inc.

Elan Legal Department

275

62

Chipworks, Inc.

Elan Legal Department

276

63

Chipworks, Inc.

Elan Legal Department

DESCRIPTION

263

Elan Legal Department

Communication with U.S. counsel for purposes
of seeking legal advice re the Elantech v.
Synaptics litigation.
Document prepared under the instruction of
U.S. counsel and to provide to U.S. counsel for
purpose of seeking legal advice in anticipation
of the Elan v. Apple litigation.
Irrelevant and non-responsive
Document prepared under the instruction of
U.S. counsel and to provide to U.S. counsel for
purpose of seeking legal advice in anticipation
of the Elan v. Apple litigation.
Document prepared under the instruction of
U.S. counsel and to provide to U.S. counsel for
purpose of seeking legal advice in anticipation
of the Elan v. Apple litigation.

Elan's Privilege Log - July 1, 2010 (2nd Revision)
Revised July 1, 2011
PRIVILEGE
PORTION
DATE
ASSERTED
WITHHELD
11/3/2006

AC

Entire
Document

9/6/2007

AC/WP

Entire
Document

4/10/2008

WP

Entire
Document

10/7/2007

WP

Entire
Document

AC/WP

Entire
Document

Elan internal communication, with
attachment(s) prepared by under the instruction
of U.S. counsel, for purpose of seeking legal
10/24/2007
advice in anticipation of the Elan v. Apple
litigation.

269
270
271
272

9

Communication with U.S. counsel for purposes
Entire
of providing legal advice re the Elantech v.
11/16/2007
AC
Document
Synaptics litigation.
Document prepared under the instruction of
U.S. counsel and to provide to U.S. counsel for
Entire
10/8/2007
WP
purpose of seeking legal advice in anticipation
Document
of the Elan v. Apple litigation.
Irrelevant and non-responsive
Irrelevant and non-responsive
Irrelevant and non-responsive
Irrelevant and non-responsive
Document prepared under the instruction of
U.S. counsel and to provide to U.S. counsel for
Entire
purposes of conducting U.S. patent
3/31/2009
WP
Document
infringement analysis in anticipation of the Elan
v. Apple litigation.
Document prepared under the instruction of
U.S. counsel and to provide to U.S. counsel for
Entire
3/31/2009
WP
purpose of seeking legal advice in anticipation
Document
of the Elan v. Apple litigation.
Document prepared under the instruction of
U.S. counsel and to provide to U.S. counsel for
Entire
4/1/2009
WP
purpose of seeking legal advice in anticipation
Document
of the Elan v. Apple litigation.
Document prepared under the instruction of
U.S. counsel and to provide to U.S. counsel for
Entire
6/2/2009
WP
purpose of seeking legal advice re the Elan v.
Document
Apple litigation.
Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)

NO.

NEW
NO.

AUTHOR

RECIPIENT

COPY RECIPIENT

DESCRIPTION

277
278
279
280

64

Chipworks, Inc.

Elan Legal Department

281

65

Chipworks, Inc.

Elan Legal Department

287

66

Chipworks, Inc.

Elan Legal Department

288

67

Chipworks, Inc.

Irrelevant and non-responsive
Irrelevant and non-responsive
Irrelevant and non-responsive
Document prepared under the instruction of
U.S. counsel and to provide to U.S. counsel for
purpose of seeking legal advice re the Elan v.
Apple litigation.
Document prepared under the instruction of
U.S. counsel and to provide to U.S. counsel for
purpose of seeking legal advice re the Elan v.
Apple litigation.
Irrelevant and non-responsive
Irrelevant and non-responsive
Irrelevant and non-responsive
Irrelevant and non-responsive
Irrelevant and non-responsive
Document prepared under the instruction of
U.S. counsel and to provide to U.S. counsel for
purpose of seeking legal advice re the Elan v.
Apple litigation.
Document prepared under the instruction of
U.S. counsel and to provide to U.S. counsel for
purpose of seeking legal advice re the Elan v.
Apple litigation.
Irrelevant and non-responsive

Elan Legal Department

282
283
284
285
286

289

290

68

Draco Wu

Document prepared under the instruction of
U.S. counsel and to provide to U.S. counsel for
purpose of seeking legal advice re the Elan v.
Apple litigation.

Elan Legal Department

Elan's Privilege Log - July 1, 2010 (2nd Revision)
Revised July 1, 2011
PRIVILEGE
PORTION
DATE
ASSERTED
WITHHELD

5/26/2009

WP

Entire
Document

6/2/2009

WP

Entire
Document

3/30/2009

WP

Entire
Document

4/1/2009

WP

Entire
Document

8/9/2007

WP

Entire
Document

291

Irrelevant and non-responsive

292

Wayne Chang (Elan Legal)

Communication between Elan and Chipworks
reflecting U.S. attorney-client communication
and prepared under the instruction of U.S.
counsel and to provide to U.S. counsel in
anticipation of the Elan v. Apple litigation.

9/1/2007

AC

Entire
Document

Richard Wu

Communication between Elan and Chipworks
reflecting U.S. attorney-client communication
and prepared under the instruction of U.S.
counsel and to provide to U.S. counsel in
anticipation of the Elan v. Apple litigation.

4/8/2008

AC

Entire
Document

293

69

70

Richard Wu

Wayne Chang (Elan
Legal)

294
295

Irrelevant and non-responsive
Irrelevant and non-responsive

10

Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)

NO.

NEW
NO.

AUTHOR

RECIPIENT

COPY RECIPIENT

296

71

Richard Wu

Wayne Chang (Elan Legal)

Ed Sheng

297

72

Chipworks, Inc.

Elan Legal Department

298

73

Sean DeBruine (Outside
Counsel)

Wayne Chang (Elan Legal)

74

Wayne Chang (Elan
Legal)

299

DESCRIPTION

Communication between Elan and Chipworks,
with attachments prepared under the instruction
2/19/2008
of U.S. counsel and to provide to U.S. counsel
in anticipation of the Elan v. Apple litigation.

Yitai Hu (Outside Counsel)

75

Richard Wu

301

76

Richard Wu

Elan Legal Department

302

77

Richard Wu

Elan Legal Department

303

78

Richard Wu

Elan Legal Department

304

79

Richard Wu

Elan Legal Department

305

80

Richard Wu

Elan Legal Department

306

81

Richard Wu

Elan Legal Department

307

82

Richard Wu

Document prepared under the instruction of
U.S. counsel and to provide to U.S. counsel for
purpose of providing legal advice in anticipation
of the Elan v. Apple litigation.
Document prepared under the instruction of
U.S. counsel and to provide to U.S. counsel for
purpose of providing legal advice in anticipation
of the Elan v. Apple litigation.
Document prepared under the instruction of
U.S. counsel and to provide to U.S. counsel for
purpose of providing legal advice in anticipation
of the Elan v. Apple litigation.
Document prepared under the instruction of
U.S. counsel and to provide to U.S. counsel for
purpose of providing legal advice in anticipation
of the Elan v. Apple litigation.
Document prepared under the instruction of
U.S. counsel and to provide to U.S. counsel for
purpose of providing legal advice in anticipation
of the Elan v. Apple litigation.
Document prepared under the instruction of
U.S. counsel and to provide to U.S. counsel for
purpose of providing legal advice in anticipation
of the Elan v. Apple litigation.
Document prepared under the instruction of
U.S. counsel and to provide to U.S. counsel for
purpose of providing legal advice in anticipation
of the Elan v. Apple litigation.
Document prepared under the instruction of
U.S. counsel and to provide to U.S. counsel for
purpose of providing legal advice in anticipation
of the Elan v. Apple litigation.
Irrelevant and non-responsive

Elan Legal Department

Elan Legal Department

308
11

AC

Entire
Document

WP

Entire
Document

AC/WP

Entire
Document

11/4/2008

AC

Entire
Document

9/21/2007

WP

Entire
Document

7/31/2007

WP

Entire
Document

7/31/2007

WP

Entire
Document

7/31/2007

WP

Entire
Document

7/31/2007

WP

Entire
Document

7/31/2007

WP

Entire
Document

7/31/2007

WP

Entire
Document

9/21/2007

AC/WP

Entire
Document

Document prepared under the instruction of
U.S. counsel and to provide to U.S. counsel in 8/20/2008
anticipation of the Elan v. Apple litigation.
Communication with U.S. counsel for purposes
of seeking legal advice in anticipation of the
10/30/2008
Elan v. Apple litigation.
Email reflecting communication between Elan
and U.S. counsel for purposes of seeking legal
advice in anticipation of the Elan v. Apple
litigation.

Wayne Chang (Elan Legal)

300

Elan's Privilege Log - July 1, 2010 (2nd Revision)
Revised July 1, 2011
PRIVILEGE
PORTION
DATE
ASSERTED
WITHHELD

Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)

NO.

NEW
NO.

AUTHOR

RECIPIENT

COPY RECIPIENT

DESCRIPTION

309
310
311
312
313

Elan's Privilege Log - July 1, 2010 (2nd Revision)
Revised July 1, 2011
PRIVILEGE
PORTION
DATE
ASSERTED
WITHHELD

Irrelevant and non-responsive
Irrelevant and non-responsive
Elan will produce
Elan will produce
Elan will produce
Document prepared by U.S. counsel for
purposes of providing legal advice re U.S.
00/00/0000
patent litigation.
Document prepared by U.S. counsel for
purposes of providing legal advice re U.S.
00/00/0000
patent litigation.
Communication with U.S. counsel for purposes
of providing legal advice in anticipation of the
6/8/2008
Elan v. Apple litigation.
Communication with U.S. counsel for purposes
of providing legal advice in anticipation of the
6/30/2008
Elan v. Apple litigation.
Communication with U.S. counsel with work
product prepared by U.S. counsel for purposes
6/30/2008
of providing legal advice in anticipation of the
Elan v. Apple litigation.

314

83

Alston & Bird (Outside
Counsel)

Wayne Chang (Elan Legal)

AC/WP

Entire
Document

315

84

Alston & Bird (Outside
Counsel)

Wayne Chang (Elan Legal)

AC/WP

Entire
Document

316

85

Yitai Hu (Outside Counsel)

Ji-Han Liu (Elan Legal)

AC

Entire
Document

317

86

Yitai Hu (Outside Counsel)

Wayne Jong (Elan Legal)

AC

Entire
Document

318

87

Yitai Hu (Outside Counsel)

Wayne Jong (Elan Legal)

AC/WP

Entire
Document

319

88

Yitai Hu (Outside Counsel)

Wayne Chang (Elan Legal)

Sean DeBruine (Outside Counsel), Communication with U.S. counsel for purposes
10/25/2006
Ming-Tao Yang (Outside Counsel) of providing legal advice re patent licensing.

AC

Entire
Document

320

89

Yitai Hu (Outside Counsel)

Wayne Chang (Elan Legal)

Communication with U.S. counsel with work
product prepared by U.S. counsel for purposes 10/23/2006
of providing legal advice re patent licensing.

AC/WP

Entire
Document

321

90

Yitai Hu (Outside Counsel)

Wayne Chang (Elan Legal)

Communication with U.S. counsel with work
product prepared by U.S. counsel for purposes 10/20/2006
of providing legal advice re patent licensing.

AC/WP

Entire
Document

322

91

Wayne Chang (Elan
Legal)

Yitai Hu (Outside Counsel)

Communication with U.S. counsel with work
product prepared by U.S. counsel for purposes
of providing legal advice re patent licensing.

9/19/2006

AC

Entire
Document

323

92

Wayne Chang (Elan
Legal)

Godwin Chiu, Ocean Chen,
Daisuke Shudo

10/23/2006

AC

Entire
Document

324

93

Alston & Bird (Outside
Counsel)

4/18/2009

AC/WP

Entire
Document

Elan internal communication for purposes of
seeking legal advice from outside counsel re
patent licensing

I.H. Yeh

Document prepared by U.S. counsel providing
legal advice re the Elan v. Apple litigation.

12

Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)

NO.

NEW
NO.

AUTHOR

325

94

Alston & Bird (Outside
Counsel)

RECIPIENT

COPY RECIPIENT

DESCRIPTION
Document prepared by U.S. counsel providing
legal advice re the Elan v. Apple litigation.

326
327

328

95

Document prepared under the instruction of
U.S. counsel and to provide to U.S. counsel re
the Elan v. Apple litigation.

Elan Legal Department

AC/WP

Entire
Document

11/19/2009

WP

Entire
Document

11/18/2009

AC

Entire
Document

9/9/2008

AC/WP

Entire
Document

8/20/2008

AC/WP

Entire
Document

8/19/2008

AC/WP

Entire
Document

8/18/2008

AC

Entire
Document

Irrelevant and non-responsive

96

Nick Lin (Elan Legal)

Elan internal communication reflecting
instruction of U.S. counsel to transmit work
product prepared under the instruction of U.S.
counsel re the Elan v. Apple litigation.

Wayne Chang (Elan Legal)

331
332
333
334
335
336
337

338

6/2/2009

Elan will produce
Elan will produce

329

330

Elan's Privilege Log - July 1, 2010 (2nd Revision)
Revised July 1, 2011
PRIVILEGE
PORTION
DATE
ASSERTED
WITHHELD

Produced as ELN1312136-ELN1312137
Already produced
Already produced
Elan will produce
Already produced
Already produced
Already produced

97

Draco Wu

Jason Liu

339
340
341

98

Roven Lee

Draco Wu, Wayne Chang
(Elan Legal)

342

99

Roven Lee

Wayne Chang (Elan Legal),
Jason Liu, Draco Wu

Wayne Chang (Elan
Legal)

Jason Liu, Draco Wu, Roven
Lee

343

344 100

Wayne Chang (Elan Legal)

Elan internal communication with attachment(s)
prepared under the instruction of U.S. counsel
in anticipation of the Elan v. Apple litigation.

Elan will produce
Elan will produce
Communication with U.S. counsel with work
Sean DeBruine (Outside Counsel),
product prepared under the instruction of U.S.
Richard Chae (Outside Counsel),
counsel in anticipation of the Elan v. Apple
Jason Liu
litigation.
Communication with U.S. counsel with work
Sean DeBruine (Outside Counsel), product prepared under the instruction of U.S.
Richard Chae (Outside Counsel) counsel in anticipation of the Elan v. Apple
litigation.
Communication with U.S. counsel for purposes
of seeking legal advice in anticipation of the
Elan v. Apple litigation.
Communication with U.S. counsel with work
Sean DeBruine (Outside Counsel), product prepared under the instruction of U.S.
Richard Chae (Outside Counsel) counsel in anticipation of the Elan v. Apple
litigation.
13

Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)

NEW
NO.

AUTHOR

RECIPIENT

345 101

Debby Yu

Jason Liu

NO.

346
347 102
348
349
350
351
352
353
354
355
356
357
358
359
360
361
362
363
364
365
366
367
368
369
370
371
372
373
374
375
376
377
378
379
380
381
382
383

Wayne Chang (Elan
Legal)

Draco Wu, Jason Liu

COPY RECIPIENT

DESCRIPTION

Elan's Privilege Log - July 1, 2010 (2nd Revision)
Revised July 1, 2011
PRIVILEGE
PORTION
DATE
ASSERTED
WITHHELD

Elan internal communication with attachment(s)
prepared under the instruction of U.S. counsel 8/17/2008
in anticipation of the Elan v. Apple litigation.

Elan will produce
Communication with U.S. counsel with work
Sean DeBruine (Outside Counsel), product prepared under the instruction of U.S.
Richard Chae (Outside Counsel) counsel in anticipation of the Elan v. Apple
litigation.
Elan will produce
Elan will produce
Elan will produce
Elan will produce
Elan will produce
Already produced
Already produced
Already produced
Already produced
Already produced
Already produced
Already produced
Already produced
Already produced
Already produced
Already produced
Already produced
Already produced
Irrelevant and non-responsive
Irrelevant and non-responsive
Irrelevant and non-responsive
Irrelevant and non-responsive
Irrelevant and non-responsive
Irrelevant and non-responsive
Already produced
Already produced
Elan will produce
Elan will produce
Elan will produce
Already produced
Already produced
Already produced
Already produced
Already produced
Already produced
Already produced

384

Elan will produce
14

8/13/2008

AC/WP

Entire
Document

AC/WP

Entire
Document

Entire
Document
Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)

NO.

NEW
NO.

AUTHOR

RECIPIENT

COPY RECIPIENT

DESCRIPTION

385

Elan will produce

386

Elan will produce

387

Elan will produce

388 103

Document prepared under the instruction of
U.S. counsel for purposes of seeking legal
advice re the Elan v. Apple litigation.

Elan Legal Department

389 104

Chipworks, Inc.

Chipworks, Inc.

Elan Legal Department

391
392
393
394
395
396
397
398
399
400
401
402
403

404 106

405 107

Draco Wu

Wayne Chang (Elan
Legal)

11/18/2009

Document prepared under the instruction of
U.S. counsel and to provide to U.S. counsel for
7/11/2008
purposes in anticipation of the Elan v. Apple
litigation.
Document prepared under the instruction of
U.S. counsel and to provide to U.S. counsel for
4/1/2009
purposes in anticipation of the Elan v. Apple
litigation.
Duplicate to other entries on the logs
Duplicate to other entries on the logs
Duplicate to other entries on the logs
Duplicate to other entries on the logs
Duplicate to other entries on the logs
Elan will produce
Elan will produce
Already produced
Irrelevant and non-responsive
Already produced as ELN1312136ELN1312137
Duplicate to other entries on the logs
Elan will produce
Elan will produce
Document prepared under the instruction of
U.S. counsel for purposes of conducting
infringement analysis on Synaptics' U.S.
1/29/2004
patents in anticipation of the Elantech v.
Synaptics litigation.
Elan internal communication with attachment(s)
reflecting instruction of U.S. counsel to transmit
work product prepared by U.S. counsel
11/18/2009
providing legal advice re the Elan v. Apple
litigation.
Elan will produce
Already produced
Elan will produce

Elan Legal Department

390 105

Elan's Privilege Log - July 1, 2010 (2nd Revision)
Revised July 1, 2011
PRIVILEGE
PORTION
DATE
ASSERTED
WITHHELD
Entire
Document
Entire
Document
Entire
Document

Yen-Jung Eve Chang (Elan
Legal), Mark Yen, Bill Tsai
(Elan Legal), Ian Chung, Lx
Lai, Maco Tang, Roven Lee,
Charles Pai

406
407
408

15

WP

Entire
Document

WP

Entire
Document

WP

Entire
Document

WP

Entire
Document

AC/WP

Entire
Document

Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)

NO.

NEW
NO.

COPY RECIPIENT

DESCRIPTION

Elan's Privilege Log - July 1, 2010 (2nd Revision)
Revised July 1, 2011
PRIVILEGE
PORTION
DATE
ASSERTED
WITHHELD

AUTHOR

RECIPIENT

409 108

Wayne Chang (Elan
Legal)

Roven Lee, Wen-Kai Lee,
Phoenix Lin, Eric Yang, Ian
Chung

Elan internal communication reflecting
instruction of U.S. counsel for purposes of
providing legal advice re the Elan v. Apple
litigation.

8/3/2009

AC

Entire
Document

410 109

Wen-Kai Lee

Phoenix Lin, Roven Lee,
Wayne Chang (Elan Legal),
Eric Yang, Ian Chung

Elan internal communication reflecting
instruction of U.S. counsel for purposes of
providing legal advice re the Elan v. Apple
litigation.

7/31/2009

AC

Entire
Document

411 110

Phoenix Lin

Roven Lee, Wayne Chang
(Elan Legal), Wen Kai Lee,
Eric Yang, Ian Chung

Elan internal communication reflecting
instruction of U.S. counsel for purposes of
providing legal advice re the Elan v. Apple
litigation.

7/31/2009

AC

Entire
Document

412 111

Wayne Chang (Elan
Legal)

Roven Lee, Wen Kai Lee,
Phoenix Lin, Eric Yang, Ian
Chung

Elan internal communication reflecting
instruction of U.S. counsel for purposes of
providing legal advice re the Elan v. Apple
litigation.

7/30/2009

AC

Entire
Document

413 112

Wayne Chang (Elan
Legal)

Liz Lai, Roven Lee, Maco
Tang, Jackson Chao, LX Lai,
Cruise Teng

Elan internal communication reflecting
Charles Pai, Ian Chung, Peggy Lin instruction of U.S. counsel re the Elan v. Apple
litigation.

7/15/2009

AC

Entire
Document

414 113

Liz Lai

Roven Lee, Maco Tang,
Elan internal communication reflecting
Wayne Chang (Elan Legal), Charles
Jackson Chao, Lx Lai, Cruise
instruction of U.S. counsel re the Elan v. Apple
Pai, Ian Chung, Peggy Lin
Teng
litigation.

7/15/2009

AC

Entire
Document

415
416
417

Elan will produce
Elan will produce
Duplicate to other entries on the logs
16

Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)

NO.

NEW
NO.

AUTHOR

RECIPIENT

COPY RECIPIENT

418
419

420 114

421 115

Elan will produce
Elan will produce

Nick Lin (Elan Legal)

Godwin Chiu, Vincent Tao,
Tsun-Min Wang, Charles Pai,
Kuo-Lung Yen, Wayne Chang (Elan
Roven Lee, Jesse Lin, ChunLegal), Bill Tsai (Elan Legal), JH Liu
Chung Huang, Rong Huang,
(Elan Legal)
Chi-Tien Yeh, TH Liu, James
Chen, Min-Shu Wang

Elan internal communication with attachment(s)
prepared under the instruction of U.S. counsel
4/20/2009
for purposes of seeking legal advice re the Elan
v. Apple litigation.

AC/WP

Entire
Document

Nick Lin (Elan Legal)

Min-Shu Wang, Chi-Tien Yeh,
WJ Hsu, Hsi-Kun Lin, ChunKuo-Lung Yen, Wayne Chang (Elan
Chung Huang, James Chen,
Legal), Bill Tsai (Elan Legal)
Roven Lee, TH Liu, Vincent
Tao

Elan internal communication with attachment(s)
prepared under the instruction of U.S. counsel
for purposes of seeking legal advice re the Elan
v. Apple litigation.

AC/WP

Entire
Document

AC

Entire
Document

422
423
424
425
426
427
428
429

4/5/2009

Elan will produce
Already produced
Already produced
Elan will produce
Elan will produce
Already produced
Already produced
Already produced

430 116

Wayne Chang (Elan
Legal)

Yen-Jung (Eve) Chang (Elan
Legal), Mark Yen, Bill Tsai
(Elan Legal), Ian Chung, LX
Lai, Maco Tang, Roven Lee,
Charles Pai

431 117

Wayne Chang (Elan
Legal)

Roven Lee, Sean DeBruine
(Outside Counsel), Richard
Chae (Outside Counsel), Yitai
Hu (Outside Counsel)

432 118

Wayne Chang (Elan
Legal)

Roven Lee

433 119

Wayne Chang (Elan
Legal)

434
435
436

DESCRIPTION

Elan's Privilege Log - July 1, 2010 (2nd Revision)
Revised July 1, 2011
PRIVILEGE
PORTION
DATE
ASSERTED
WITHHELD

Roven Lee

Elan internal communication reflecting
instruction of U.S. counsel re the Elan v. Apple 11/19/2009
litigation.
Communications with U.S. counsel with
attachment prepared under the instruction of
U.S. counsel for purposes of seeking legal
advice in anticipation of the Elan v. Apple
litigation.

8/13/2008

AC/WP

Entire
Document

Elan internal communication reflecting
instruction of U.S. counsel re the Elan v. Apple
litigation.

8/13/2008

AC

Entire
Document

8/13/2008

AC/WP

Entire
Document

Communications with U.S. counsel with
attachment prepared under the instruction of
Sean DeBruine (Outside Counsel),
U.S. counsel for purposes of seeking legal
Richard Chae (Outside Counsel)
advice in anticipation of the Elan v. Apple
litigation.
Elan will produce
Elan will produce
Elan will produce
17

Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)

NO.

NEW
NO.

AUTHOR

RECIPIENT

COPY RECIPIENT

DESCRIPTION

437
438

439 120

Elan will produce
Elan will produce

Wayne Chang (Elan
Legal)

Elan internal communication for purposes of
seeking legal advice re the Elan v. Apple
litigation.

I.H. Yeh, Charles Pai, Ian
Chung

440
441
442
443
444

445 121

10/20/2009

AC

Entire
Document

7/15/2009

AC

Entire
Document

7/20/2008

AC

Entire
Document

Elan will produce
Irrelevant and non-responsive
Irrelevant and non-responsive
Irrelevant and non-responsive
Irrelevant and non-responsive

Wayne Chang (Elan
Legal)

Liz Lai, Roven Lee, Maco
Tang, Jackson Chao, LX Lai,
Cruise Teng

Elan internal communication reflecting
Charles Pai, Ian Chung, Peggy Lin instruction of U.S. counsel re the Elan v. Apple
litigation.

446
447
448
449

450 122

Elan's Privilege Log - July 1, 2010 (2nd Revision)
Revised July 1, 2011
PRIVILEGE
PORTION
DATE
ASSERTED
WITHHELD

Elan will produce
Duplicate to other entries on the logs
Already produced
Produced as ELN1017473-ELN1017476

I.H. Yeh

Wayne Chang (Elan Legal)

Elan internal communication for purposes of
Kuo-Lung Yen, Ian Chung, WF Lu,
seeking legal advice in anticipation of the Elan
Godwin Chiu, Charles Pai
v. Apple litigation.

451
452

Elan will produce
Irrelevant and non-responsive

453 123

Wayne Chang (Elan
Legal)

Roven Lee, Godwin Chi,
Charles Pai, Chi-Tien Yeh

Elan internal communication for purposes of
seeking legal advice in anticipation of the Elan
v. Apple litigation.

4/8/2008

AC

Entire
Document

454 124

Wayne Chang (Elan
Legal)

Godwin Chiu, Charles Pai,
Chi-Tien Yeh, Roven Lee

Elan internal communication with attachment(s)
prepared under the instruction of U.S. counsel
for purposes of seeking legal advice in
anticipation of the Elan v. Apple litigation.

4/8/2008

AC/WP

Entire
Document

I.H. Yeh

18

Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)

NO.

NEW
NO.

AUTHOR

RECIPIENT

COPY RECIPIENT

DESCRIPTION

455
456
457

Elan's Privilege Log - July 1, 2010 (2nd Revision)
Revised July 1, 2011
PRIVILEGE
PORTION
DATE
ASSERTED
WITHHELD

Elan will produce
Elan will produce
Irrelevant and non-responsive

458 125

Charles Pai

Min-Shu Wang, Wen-Kai Lee,
Roven Lee, Wen Jun Chen,
Maco Tang, Alan Tsai, ChiTien Yeh

459 126

Charles Pai

460 127

Godwin Chiu

Elan internal communication for purposes of
seeking legal advice in anticipation of the Elan
v. Apple litigation.

12/2/2007

AC

Entire
Document

Godwin Chiu, Wayne Chang
(Elan Legal)

Elan internal communication for purposes of
Bill Tsai (Elan Legal), I.H. Yeh, WF
seeking legal advice in anticipation of the Elan
Lu, Chi-Tien Yeh
v. Apple litigation.

12/2/2007

AC

Entire
Document

Charles Pai, Bill Tsai (Elan
Legal), I.H. Yeh, WF Lu,
Wayne Chang (Elan Legal)

Elan internal communication for purposes of
seeking legal advice in anticipation of the Elan
v. Apple litigation.

12/2/2007

AC

Entire
Document

6/30/2008

AC/WP

Entire
Document

Ian Chung, Godwin Chiu

461
462
463

Irrelevant and non-responsive
Irrelevant and non-responsive
Elan will produce
Document reflecting attorney-client privilege
communication and attorney work product for
purposes of providing legal advice in
anticipation of the Elan v. Apple litigation.

464 128 Yitai Hu (Outside Counsel)
19

Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)

NO.

NEW
NO.

AUTHOR

RECIPIENT

COPY RECIPIENT

DESCRIPTION

465
466
467
468
469
470
471
472
473
474
475
476
477
478
479
480

481 129

Elan will produce
Duplicate to other entries on the logs
Already produced
Already produced
Already produced
Already produced
Elan will produce
Elan will produce
Already produced
Elan will produce
Elan will produce
Duplicate to other entries on the logs
Elan will produce
Elan will produce
Elan will produce
Elan will produce

I.H. Yeh

I.H. Yeh, Wayne Chang (Elan
Legal), Kuo-Lung Yen, Ian
Chung, Godwin Chiu, WF Lu

Elan internal communication, reflecting U.S.
counsel communication re the Elantech v.
Synaptics litigation.

482

483 130

Elan's Privilege Log - July 1, 2010 (2nd Revision)
Revised July 1, 2011
PRIVILEGE
PORTION
DATE
ASSERTED
WITHHELD

7/31/2008

AC

Entire
Document

5/28/2008

AC

Entire
Document

Elan will produce

Wayne Chang (Elan
Legal)

I.H. Yeh, WF Lu, Bill Tsai
Elan internal communication for purposes of
(Elan Legal), Ji-Han Liu (Elan Godwin Chiu, Ian Chung, Rich Tan seeking legal advice re U.S. patent
Legal)
prosecution.

484

Elan will produce

20

Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)

NO.

NEW
NO.

485 131

AUTHOR

RECIPIENT

COPY RECIPIENT

Wayne Chang (Elan
Legal)

I.H. Yeh, WF Lu

DESCRIPTION

Godwin Chiu, Ian Chung

Elan internal communication for purposes of
seeking legal advice on Synaptics' U.S. patent
re the Elantech v. Synaptics litigation.

486
487
488
489
490
491
492
493
494
495

496 132

Elan's Privilege Log - July 1, 2010 (2nd Revision)
Revised July 1, 2011
PRIVILEGE
PORTION
DATE
ASSERTED
WITHHELD

5/28/2008

AC

Entire
Document

12/2/2007

AC

Entire
Document

Elan will produce
Duplicate to other entries on the logs
Duplicate to other entries on the logs
Irrelevant and non-responsive
Irrelevant and non-responsive
Irrelevant and non-responsive
Irrelevant and non-responsive
Irrelevant and non-responsive
Irrelevant and non-responsive
Irrelevant and non-responsive

Charles Pai

Min-Shu Wang, Wen-Kai Lee,
Roven Lee, Wen-Jun Chen,
Maco Tang, Alan Tsai, ChiTien Yeh

Elan internal communication for purposes of
seeking legal advice in anticipation of the Elan
v. Apple litigation.

Ian Chung, Godwin Chiu

497
498
499
500
501
502
503
504
505
506
507

Elan will produce
Elan will produce
Elan will produce
Elan will produce
Elan will produce
Elan will produce
Elan will produce
Elan will produce
Elan will produce
Elan will produce
Elan will produce

21

Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)

NO.

NEW
NO.

508 133

AUTHOR

Wayne Chang (Elan
Legal)

RECIPIENT

I.H. Yeh

COPY RECIPIENT

DESCRIPTION

Elan internal communication with work product
prepared by U.S. counsel for purposes of
providing legal advice re the Elan v. Apple
litigation.

Ian Chung

509

510 134

Elan's Privilege Log - July 1, 2010 (2nd Revision)
Revised July 1, 2011
PRIVILEGE
PORTION
DATE
ASSERTED
WITHHELD

9/10/2009

AC

Entire
Document

9/10/2009

AC/WP

Entire
Document

Irrelevant and non-responsive

Wayne Chang (Elan
Legal)

I.H. Yeh

Elan internal communication with work product
prepared by U.S. counsel for purposes of
providing legal advice re the Elan v. Apple
litigation.

Ian Chung

511

Elan will produce

22

Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)

NEW
NO.

AUTHOR

RECIPIENT

512 135

Roven Lee

Wayne Chang (Elan Legal),
Lee Wen Kai, Phoenix Lin,
Eric Yang, Ian Chung

NO.

COPY RECIPIENT

DESCRIPTION

Elan internal communication reflecting
instruction of U.S. counsel for purposes of
providing legal advice re the Elan v. Apple
litigation.

513
514
515
516

517 136

7/31/2009

AC

Entire
Document

4/9/2009

AC

Entire
Document

9/5/2007

AC

Entire
Document

Elan will produce
Elan will produce
Elan will produce
Elan will produce

I.H. Yeh

Jason Oung, Min-Shu Wang,
Charles Pai, Ian Chung, Kuo-Lung
WF Lu, Godwin Chiu, Dennis Yen, Jeff Cheng (Elan Legal), Shu- Elan internal communication reflecting
Liu, Wayne Chang (Elan
Hsin (Elsa) Tsai (Elan Legal), Bill instruction of U.S. counsel re the Elan v. Apple
Legal)
Tsai, Ji-Han Liu (Elan Legal), Yen- litigation.
Jung (Eve) Chang (Elan Legal), Nick
Lin (Elan Legal)

518
519
520
521
522
523
524

525 137

Elan's Privilege Log - July 1, 2010 (2nd Revision)
Revised July 1, 2011
PRIVILEGE
PORTION
DATE
ASSERTED
WITHHELD

Irrelevant and non-responsive
Duplicate to other entries on the logs
Elan will produce
Already produced
Elan will produce
Already produced
Duplicate to other entries on the logs

Wayne Chang (Elan
Legal)

I.H. Yeh

Elan internal communication for purposes of
seeking legal advice re licensing negotiation
with Apple and in anticipation of the Elan v.
Apple litigation.

Godwin Chiu

526

Elan will produce

23

Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)

NO.

NEW
NO.

527 138

AUTHOR

RECIPIENT

Wayne Chang (Elan
Legal)

COPY RECIPIENT

DESCRIPTION

I.H. Yeh, Godwin Chiu, W.F.
Lu

Elan internal communication and attachment(s)
prepared for purposes of seeking legal advice
3/13/2007
in anticipation of the Elan v. Apple litigation.

528
529
530

531 139

AC

Entire
Document

11/14/2007

AC

Entire
Document

8/16/2006

AC

Entire
Document

2/8/2007

AC

Entire
Document

1/14/2010

AC

Entire
Document

Elan will produce
Elan will produce
Irrelevant and non-responsive

Wayne Chang (Elan
Legal)

Elan internal communication for purposes of
seeking legal advice in anticipation of the Elan
v. Apple litigation.

I.H. Yeh, WF Lu

532

Irrelevant and non-responsive

533 140

Wayne Chang (Elan
Legal)

Godwin Chiu

I.H. Yeh, Draco Wu, Ian Chung,
Roven Lee

534 141

Wayne Chang (Elan
Legal)

Godwin Chiu

I.H. Yeh

Wayne Chang (Elan
Legal)

Yitai Hu (Outside Counsel),
Sean DeBruine (Outside
Counsel)

Elan internal communication for purposes of
seeking legal advice in anticipation of the Elan
v. Apple litigation.

Elan internal communication for purposes of
seeking legal advice in anticipation of the Elan
v. Apple litigation.

535
536 142

Elan's Privilege Log - July 1, 2010 (2nd Revision)
Revised July 1, 2011
PRIVILEGE
PORTION
DATE
ASSERTED
WITHHELD

Elan will produce
Communication with U.S. counsel for purposes
of seeking legal advice re the Elan v. Apple
litigation.
Elan will produce
Elan will produce

I.H. Yeh, Fernando Yeh

537
538
24

Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)

NO.

NEW
NO.

AUTHOR

RECIPIENT

539 143

Wayne Chang (Elan
Legal)

I.H. Yeh

540 144

Wayne Chang (Elan
Legal)

Fernando Yeh

COPY RECIPIENT

DESCRIPTION

WF Lu

Elan internal communication with work product
prepared by U.S. counsel for purposes of
6/21/2008
providing legal advice in anticipation of the Elan
v. Apple litigation.

AC/WP

Entire
Document

I.H. Yeh

Elan internal communication reflecting
communication with U.S. counsel re the Elan v. 1/21/2010
Apple litigation.

AC

Entire
Document

1/24/2008

AC

Entire
Document

2/26/2008

AC

Entire
Document

541

542 145

Already produced

Wayne Chang (Elan
Legal)

Elan internal communication re for the
purposes of seeking legal advice, in
anticipation of the Elan v. Apple litigation.

I.H. Yeh

543

544 146

Elan's Privilege Log - July 1, 2010 (2nd Revision)
Revised July 1, 2011
PRIVILEGE
PORTION
DATE
ASSERTED
WITHHELD

Elan will produce

I.H. Yeh

Bill Tsai (Elan Legal)

Wayne Chang (Elan Legal)

25

Elan internal communication for purposes of
seeking legal advice re U.S. patent
prosecution.

Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)

NO.

NEW
NO.

AUTHOR

RECIPIENT

COPY RECIPIENT

DESCRIPTION

Elan's Privilege Log - July 1, 2010 (2nd Revision)
Revised July 1, 2011
PRIVILEGE
PORTION
DATE
ASSERTED
WITHHELD

Elan internal communication with work product
prepared by U.S. counsel for purposes of
providing legal advice re the Elan v. Apple
litigation.

I.H. Yeh

546 148

Wayne Chang (Elan
Legal)

Godwin Chiu

I.H. Yeh, Ocean Chen, Daisuke
Shudo

547 149

Wayne Chang (Elan
Legal)

Chi-Tien Yeh, Godwin Chiu,
Roven Lee

I.H. Yeh

548 150

Nick Lin (Elan Legal)

I.H. Yeh

2/1/2010

AC/WP

Entire
Document

Elan internal communication with work product
prepared by U.S. counsel for purposes of
providing legal advice re the Elan v. Apple
litigation.

3/22/2007

AC/WP

Entire
Document

Elan internal communication with attachment(s)
prepared under the instruction of U.S. counsel
5/15/2008
and to provide to U.S. counsel in anticipation of
the Elan v. Apple litigation.

545 147

Wayne Chang (Elan
Legal)

AC/WP

Entire
Document

AC

Entire
Document

Elan internal communication reflecting
Wayne Chang (Elan Legal), Bill Tsai
instruction of U.S. counsel in anticipation of the 12/25/2008
(Elan Legal)
Elan v. Apple litigation.

549
550
551
552
553

Elan will produce
Elan will produce
Elan will produce
Elan will produce
Irrelevant and non-responsive

26

Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)

NO.

NEW
NO.

AUTHOR

RECIPIENT

COPY RECIPIENT

DESCRIPTION

W.F. Lu

Elan internal communication reflecting
instruction of U.S. counsel for purposes of
6/24/2008
providing legal advice in anticipation of the Elan
v. Apple litigation.

AC

Entire
Document

Chi-Tien Yeh

I.H. Yeh

Elan internal communication reflecting the
instruction of U.S. counsel in anticipation of the
Elan v. Apple litigation.

5/15/2008

AC

Entire
Document

Wayne Chang (Elan Legal),
Godwin Chiu, Roven Lee

I.H. Yeh

Elan internal communication reflecting the
instruction of U.S. counsel in anticipation of the
Elan v. Apple litigation.

5/15/2008

AC

Entire
Document

8/27/2008

AC

Entire
Document

554 151

Wayne Chang (Elan
Legal)

I.H. Yeh

555 152

Wayne Chang (Elan
Legal)

556 153

Chi-Tien Yeh

557

558 154

Elan's Privilege Log - July 1, 2010 (2nd Revision)
Revised July 1, 2011
PRIVILEGE
PORTION
DATE
ASSERTED
WITHHELD

Already produced

I.H. Yeh

WF Lu, Hsi-Kun Lin, Charles
Pai, Godwin Chiu, Steven
Tsai, Ian Chung, Kuo-Lung
Yen, Wayne Chang (Elan
Legal)

Elan internal communication, reflecting U.S.
counsel communication and for purposes of
seeking legal advice re the Elantech v.
Synaptics litigation.

27

Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)

NO.

NEW
NO.

559 155

AUTHOR

RECIPIENT

I.H. Yeh

COPY RECIPIENT

DESCRIPTION

Wayne Chang (Elan Legal),
Kuo-Lung Yen, Ian Chung,
Steven Tsai, Godwin Chiu,
Charles Pai, Hsi-Kun Lin

Elan internal communication, reflecting U.S.
counsel communication and for purposes of
seeking legal advice re the Elantech v.
Synaptics litigation.

560
561

562 156

8/14/2008

AC

Entire
Document

2/2/2010

AC

Entire
Document

4/7/2009

AC

Entire
Document

Irrelevant and non-responsive
Elan will produce

Wayne Chang (Elan
Legal)

Elan internal communication reflecting
communication with U.S. counsel re the Elan v.
Apple litigation.

I.H. Yeh

563

564 157

Elan's Privilege Log - July 1, 2010 (2nd Revision)
Revised July 1, 2011
PRIVILEGE
PORTION
DATE
ASSERTED
WITHHELD

Already produced

WF Lu

Elan internal communication for purposes of
seeking legal advice re the Elan v. Apple
litigation.

Wayne Chang (Elan Legal),
I.H. Yeh

565
566
567
568
569

Irrelevant and non-responsive
Elan will produce
Elan will produce
Duplicate to other entries on the logs
Irrelevant and non-responsive

28

Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)

NO.

NEW
NO.

570 158

AUTHOR

RECIPIENT

COPY RECIPIENT

Wayne Chang (Elan
Legal)

I.H. Yeh

DESCRIPTION

WF Lu

Elan internal communication for purposes of
seeking legal advice re the Elantech v.
Synaptics litigation.

Elan's Privilege Log - July 1, 2010 (2nd Revision)
Revised July 1, 2011
PRIVILEGE
PORTION
DATE
ASSERTED
WITHHELD

Entire
Document

Elan internal communication reflecting
communication with U.S. counsel and for the
2/16/2007
purposes of seeking legal advice in anticipation
of the Elan v. Apple litigation.

AC

Entire
Document

Elan internal communication reflecting
instruction of U.S. counsel re the Elan v. Apple
litigation.

571
572
573
574
575
576

AC/WP

AC

Entire
Document

AC/WP

Entire
Document

6/25/2008

Elan will produce
Already produced
Elan will produce
Already produced
Already produced
Irrelevant and non-responsive

577 159

Wayne Chang (Elan
Legal)

WF Lu

578 160

Eve Chang (Elan Legal)

Eric Yang

Godwin Chiu, I.H. Yeh

3/17/2010

Elan internal communication with attachment(s)
prepared under the instruction of U.S. counsel
3/10/2010
and to provide to U.S. counsel re the Elan v.
Apple litigation.

579 161

Eric Yang

Eve Chang (Elan Legal)

580 162

Eve Chang (Elan Legal)

Eric Yang

Elan internal communication reflecting the
instruction of U.S. counsel re the Elan v. Apple
litigation.

3/9/2010

AC

Entire
Document

581 163

Eve Chang (Elan Legal)

Eric Yang

Elan internal communication reflecting the
instruction of U.S. counsel re the Elan v. Apple
litigation.

3/4/2010

AC

Entire
Document

29

Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)

Elan's Privilege Log - July 1, 2010 (2nd Revision)
Revised July 1, 2011
PRIVILEGE
PORTION
DATE
ASSERTED
WITHHELD

NEW
NO.

AUTHOR

RECIPIENT

582 164

Leo Chen

Eric Yang

Elan internal communication with attachment(s)
prepared under the instruction of U.S. counsel
11/17/2009
and to provide to U.S. counsel re the Elan v.
Apple litigation.

AC/WP

Entire
Document

AC/WP

Entire
Document

AC

Entire
Document

AC/WP

Entire
Document

3/10/2010

AC/WP

Entire
Document

3/10/2010

AC/WP

Entire
Document

NO.

COPY RECIPIENT

DESCRIPTION

583 165

Wayne Chang (Elan
Legal)

Eric Yang

Phoenix Lin

Elan internal communication with attachment(s)
reflecting the instruction of U.S. counsel to
transmit work product prepared by U.S. counsel 11/15/2009
for purposes of providing legal advice re the
Elan v. Apple litigation.

584 166

Wayne Chang (Elan
Legal)

WF Lu, Charles Pai

I.H. Yeh, Roven Lee, Eric Yang,
Stober Chen

Elan internal communication reflecting the
instruction of U.S. counsel re the Elan v. Apple 10/14/2009
litigation.

585
586

587 167

Elan will produce
Already produced

Alfie Tsai

Elan internal communication with attachment(s)
prepared under the instruction of U.S. counsel
9/25/2008
for purposes of seeking legal advice re U.S.
patent prosecution.

Eric Yang

588
589
590
591
592
593
594
595
596
597
598
599 168

Helen Su (Outside
Counsel)

600 169

Already produced
Elan will produce
Already produced
Elan will produce
Already produced
Already produced
Already produced
Already produced
Elan will produce
Elan will produce
Elan will produce
Document prepared by outside counsel for
purposes of providing legal advice re the Elan
v. Apple litigation.
Document prepared by outside counsel for
purposes of providing legal advice re the Elan
v. Apple litigation.
Elan will produce
Elan will produce

Helen Su (Outside
Counsel)

601
602
30

Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)

NO.

NEW
NO.

AUTHOR

RECIPIENT

COPY RECIPIENT

DESCRIPTION

603
604
605
606
607
608
609
610
611
612

613 170

Elan's Privilege Log - July 1, 2010 (2nd Revision)
Revised July 1, 2011
PRIVILEGE
PORTION
DATE
ASSERTED
WITHHELD

Already produced
Already produced
Already produced
Elan will produce
Already produced
Already produced
Already produced
Elan will produce
Elan will produce
Elan will produce

Godwin Chiu

Elan internal communication with work product
prepared by U.S. counsel for purposes of
providing legal advice in anticipation of the Elan
v. Apple litigation.

Ian Chung

614
615
616
617
618
619
620
621
622
623
624
625
626
627
628
629
630
631
632
633
634
635
636
637
638
639
640
641
642
643
644
645
646
647

8/3/2008

AC/WP

Entire
Document

Elan will produce
Already produced
Already produced
Already produced
Already produced
Already produced
Elan will produce
Already produced
Elan will produce
Elan will produce
Already produced
Already produced
Elan will produce
Already produced
Already produced
Already produced
Already produced
Already produced
Already produced
Already produced
Already produced
Already produced
Already produced
Already produced
Already produced
Already produced
Elan will produce
Irrelevant and non-responsive
Elan will produce
Elan will produce
Elan will produce
Already produced
Already produced
Already produced
31

Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)

NO.

NEW
NO.

AUTHOR

RECIPIENT

648

649 171

Godwin Chiu

Annie Jeong, Dong Jun Seo,
Michael Na

650 172

Godwin Chiu

Ji-Han Liu (Elan Legal), W.F.
Lu

COPY RECIPIENT

DESCRIPTION

Already produced
Communication between Elan and S&J, a third
party having a common legal interest with Elan,
with work product prepared by U.S. counsel for
Peggy Lin, Charles Pai, Ian Chung
2/20/2008
purposes of providing legal advice on
Synaptics' U.S. patent, re the Elantech v.
Synaptics litigation.

I.H. Yeh, Ian Chung, Kuo-Lung Yen, Elan internal communication for purposes of
Charles Pai, Wayne Chang (Elan seeking legal advice on Synaptics' U.S. patent
Legal), Jacky Wu, Eric Yang
re the Elantech v. Synaptics litigation.

651
652
653
654
655
656
657
658
659
660
661
662
663
664
665
666
667

668 173

Elan's Privilege Log - July 1, 2010 (2nd Revision)
Revised July 1, 2011
PRIVILEGE
PORTION
DATE
ASSERTED
WITHHELD

AC/WP/Common
Interest

Entire
Document

2/11/2008

AC

Entire
Document

7/31/2007

AC

Entire
Document

Already produced
Already produced
Already produced
Already produced
Elan will produce
Already produced
Already produced
Already produced
Already produced
Elan will produce
Elan will produce
Already produced
Elan will produce
Elan will produce
Elan will produce
Elan will produce
Already produced

Godwin Chiu

Wayne Chang (Elan Legal), I.
H. Yeh, W.F. Lu

Elan internal communication, reflecting U.S.
counsel privileged communication and for
purposes of seeking legal advice re the
Elantech v. Synaptics litigation.

Ian Chung

32

Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)

NO.

NEW
NO.

669 174

AUTHOR

RECIPIENT

COPY RECIPIENT

DESCRIPTION

Godwin Chiu

W.F. Lu, Wayne Chang (Elan
legal), Roven Lee

Ian Chung, I.H. Yeh

Elan internal communication for purposes of
seeking legal advice re the Elantech v.
Synaptics litigation.

670
671
672
673
674
675
676
677
678
679
680
681
682
683
684
685
686
687
688
689
690
691
692
693
694
695
696
697
698
699
700
701
702
703
704
705
706
707

Elan's Privilege Log - July 1, 2010 (2nd Revision)
Revised July 1, 2011
PRIVILEGE
PORTION
DATE
ASSERTED
WITHHELD

7/15/2007

AC

Entire
Document

Already produced
Irrelevant and non-responsive
Already produced
Already produced
Already produced
Elan will produce
Elan will produce
Already produced
Already produced
Already produced
Already produced
Already produced
Already produced
Already produced
Already produced
Already produced
Elan will produce
Elan will produce
Elan will produce
Elan will produce
Elan will produce
Already produced
Elan will produce
Elan will produce
Already produced
Already produced
Elan will produce
Elan will produce
Elan will produce
Elan will produce
Elan will produce
Elan will produce
Elan will produce
Elan will produce
Elan will produce
Elan will produce
Already produced
Already produced
33

Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)

NO.

NEW
NO.

AUTHOR

RECIPIENT

COPY RECIPIENT

DESCRIPTION

708
709
710
711
712
713
714
715
716
717
718
719
720
721
722
723
724
725
726
727
728
729
730

Elan's Privilege Log - July 1, 2010 (2nd Revision)
Revised July 1, 2011
PRIVILEGE
PORTION
DATE
ASSERTED
WITHHELD

Already produced
Elan will produce
Elan will produce
Already produced
Already produced
Already produced
Already produced
Already produced
Already produced
Elan will produce
Elan will produce
Elan will produce
Elan will produce
Already produced
Already produced
Elan will produce
Elan will produce
Elan will produce
Already produced
Already produced
Already produced
Already produced
Already produced

34

Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)