Elan Microelectronics Corporation v. Apple, Inc.

Filing 384

Declaration of Nathan Greenblatt in Support of Apple's Opposition to Elan Microelectronic Corporation's Motion to Compel Discovery on Various Issues 357 filed byApple, Inc.. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7)(Greenblatt, Nathan) (Filed on 8/9/2011)

1
2
3
4
5
6
7
8
9
10
11

MATTHEW D. POWERS (Bar No. 104795)
[e-mail]
TENSEGRITY LAW GROUP LLP
201 Redwood Shores Parkway, Suite 401
Redwood Shores, CA 94065
Telephone: [phone]
Facsimile: [phone]
JARED BOBROW (Bar No. 133712)
[e-mail]
SONAL N. MEHTA (Bar No. 222086)
[e-mail]
DEREK C. WALTER (Bar. No. 246322)
[e-mail]
NATHAN GREENBLATT (Bar No. 262279)
[e-mail]
WEIL, GOTSHAL & MANGES LLP
Silicon Valley Office
201 Redwood Shores Parkway
Redwood Shores, CA 94065
Telephone: [phone]
Facsimile: [phone]

12
13

Attorneys for Defendant and Counterclaim Plaintiff
Apple Inc.

14

UNITED STATES DISTRICT COURT

15

NORTHERN DISTRICT OF CALIFORNIA

16

SAN FRANCISCO DIVISION

17
18

ELAN MICROELECTRONICS
CORPORATION,
Plaintiff and Counterclaim
Defendant,

19
20
21
22
23

v.
APPLE INC.,
Defendant and Counterclaim
Plaintiff.

24

Case No. C-09-01531 RS (PSG)
DECLARATION OF NATHAN
GREENBLATT IN SUPPORT OF
APPLE’S OPPOSITION TO ELAN
MICROELECTRONICS
CORPORATION’S MOTION TO
COMPEL DISCOVERY ON VARIOUS
ISSUES
DATE:
TIME:
JUDGE:
CTRM:

August 30, 2011
10:00 a.m.
Hon. Paul S. Grewal
5

25
26
27
28
GREENBLATT DECL. ISO APPLE’S
OPPOSITION TO MOTION TO COMPEL
DISCOVERY ON VARIOUS ISSUES

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

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27

I, Nathan Greenblatt, declare:
I am an attorney with the law firm of Weil, Gotshal & Manges LLP, counsel of
record for Defendant and Counterclaimant Apple Inc. (“Apple”) in the above-captioned matter. I
submit this declaration based on personal knowledge and following a reasonable investigation. If
called upon as a witness, I could competently testify to the truth of each statement herein.
1.

Attached as Exhibit 1 is a true and correct copy of an email chain between

Derek Walter (counsel for Apple) and Jane Bu (counsel for Elan) with the most recent email
dated Monday, July 25, 2011 7:58 AM.
2.

Attached as Exhibit 2 is a true and correct copy of excerpts from the

deposition transcript of Greg Marriott (former Apple engineer) dated July 26, 2011.
3.

Attached as Exhibit 3 is a true and correct copy of part of the webpage

http://www.apple.com/ipodclassic/features.html (last visited Aug. 9, 2011).
4.

Attached as Exhibit 4 is a true and correct copy of part of the webpage

http://www.apple.com/ipodtouch/ (last visited Aug. 9, 2011).
5.

Attached as Exhibit 5 is a true and correct copy of part of the webpage

http://www.apple.com/ipodtouch/features/ (last visited Aug. 9, 2011).
6.

Attached as Exhibit 6 is a true and correct copy of part of the webpage

http://www.apple.com/ipod/ (last visited Aug. 9, 2011).
7.

Attached as Exhibit 7 is a true and correct copy of part of the webpage

http://www.apple.com/ipodshuffle/ (last visited Aug. 9, 2011).
8.

Attached as Exhibit 8 is a true and correct copy of portions of the

deposition transcript (rough draft) of Stephanie Cinereski (former Apple engineer) dated Aug. 7,
2011 (filed under seal).
9.

Attached as Exhibit 9 is a true and correct copy of an email chain between

Derek Walter (counsel for Apple) and Palani Rathinasamy (counsel for Elan) with the most recent
email dated Tuesday, July 26, 2011 8:03 PM (filed under seal, partially redacted copy lodged
with the Court).

28
GREENBLATT DECL. ISO APPLE’S
OPPOSITION TO MOTION TO COMPEL
DISCOVERY ON VARIOUS ISSUES

2

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

1
2
3
4
5

10.

Attached as Exhibit 10 is a true and correct copy of a document bearing

production numbers APEL0404758 – 59 that has been produced in this case (filed under seal).
I declare under the penalty of perjury under the laws of the United States of
America that the foregoing is true and correct.
Executed on August 9, 2011, at Redwood Shores, California.

6
7
8

/s/ Nathan Greenblatt
Nathan Greenblatt

9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
GREENBLATT DECL. ISO APPLE’S
OPPOSITION TO MOTION TO COMPEL
DISCOVERY ON VARIOUS ISSUES

3

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