Elan Microelectronics Corporation v. Apple, Inc.

Filing 342

Declaration of Jane H. Bu in Support of 341 MOTION to Compel Discovery Related to Apple iOS Applications for the Accused Products 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)(Related document(s) 341 ) (Bu, Jane) (Filed on 7/15/2011)

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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,
Plaintiff and Counterdefendant,

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v.
APPLE, INC.,
Defendant and Counterplaintiff.

Case No. 5:09-cv-01531 RS (PSG)
DECLARATION OF JANE H. BU IN
SUPPORT OF ELAN
MICROELECTRONICS
CORPORATION’S MOTION TO
COMPEL DISCOVERY RELATED TO
APPLE iOS APPLICATIONS FOR THE
ACCUSED PRODUCTS

AND RELATED COUNTERCLAIMS

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DECL. OF JANE H. BU ISO ELAN’S MOT. TO COMPEL
DISCOVERY RELATED TO APPLE iOS APPLICATIONS
FOR THE ACCUSED PRODUCTS

Case No. 5:09-cv-01531 RS (PSG)

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I, Jane H. Bu, declare as follows:

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I am an associate 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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1.

Attached as Exhibit A is a true and correct copy of relevant excerpts of Apple

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Inc.’s Objections and Responses to Elan Microelectronics Corporation’s Third Set of Requests for

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Production of Documents and Things to Defendant Apple, Inc. [Nos. 73-99], dated May 12, 2011.

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2.

Attached as Exhibit B is a true and correct copy of relevant excerpts of Apple Inc.’s

Objections and Responses to Elan Microelectronics Corporation’s Third Set of Interrogatories to
Apple, Inc. [Nos. 16-23], dated May 12, 2011.
3.

Attached as Exhibit C is a true and correct copy of a letter from me to Apple’s

counsel, Ms. Sonal Mehta, dated June 11, 2011.
4.

Attached as Exhibit D is a true and correct copy of email correspondences between

me and Apple’s counsel, Mr. Derek Walter, dated from June 10 to July 13, 2011.
5.

Attached as Exhibit E is a true and correct copy of the relevant excerpts of Apple’s

responses to Elan’s 30(b)(6) Deposition Topics dated June 24, 2011.
6.

Attached as Exhibit F is a true and correct copy of an email from me to Mr. Walter,

dated July 6, 2011.

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7.

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as APEL0033632.

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8.

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Attached as Exhibit G is a true and correct copy of Apple’s ad produced by Apple

Attached as Exhibit H is a true and correct copy of Apple’s website print out

available at http://www.apple.com/iphone/ios4.
9.

Attached as Exhibit I is a true and correct copy of Apple Insider’s website print out

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available at

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http://www.appleinsider.com/articles/11/07/11/ios_app_store_downloads_grow_61_average_app_

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price_up_14.html.

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I declare under penalty of perjury under the laws of the United States that the foregoing is
true and correct.
DECL. OF JANE H. BU ISO ELAN’S MOT. TO COMPEL
DISCOVERY RELATED TO APPLE iOS APPLICATIONS
FOR THE ACCUSED PRODUCTS

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Case No. 5:09-cv-01531 RS (PSG)

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Executed this 15th day of July, 2011 at Menlo Park, California.

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By:

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/s/ Jane H. Bu
Jane H Bu

LEGAL02/32743802v2

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DECL. OF JANE H. BU ISO ELAN’S MOT. TO COMPEL
DISCOVERY RELATED TO APPLE iOS APPLICATIONS
FOR THE ACCUSED PRODUCTS

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Case No. 5:09-cv-01531 RS (PSG)