Elan Microelectronics Corporation v. Apple, Inc.
Filing
408
Declaration of Jane H. Bu in Support of 406 Objection 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)(Related document(s) 406 ) (Bu, Jane) (Filed on 8/22/2011)
EXHIBIT D
Elan's Privilege Log 2010-10-25
ELAN MICROELECTRONICS CORPORATION'S PRIVILEGE LOG - OCTOBER 25, 2010
DATE
PRIVILEGE
ASSERTED
PORTION
WITHHELD
Document prepared by or at direction of Elan legal department
and/or counsel in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis
2/11/2004
WP
Entire document
Draco Wu
Document prepared by or at direction of Elan legal department
and/or counsel in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis
2/11/2004
WP
Entire document
3
Akin Gump (outside counsel)
Document prepared by Elan's outside counsel in anticipation of
litigation and/or for purposes of seeking/providing legal advice re
patent litigation
12/11/2006
WP
Entire document
4
Chao-Hui Hsu
Document prepared by or at direction of Elan legal department
and/or counsel in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent information
3/9/2005
WP
Entire document
5
Elan Legal Department
Document prepared by Elan legal department and/or counsel in
anticipation of litigation and/or for purposes of seeking/providing
legal advice.
9/17/2007
WP
Entire document
6
Wayne Chang (Elan Legal)
Document prepared by Elan for third parties having a common
legal interest with Elan, containing communications with counsel
regarding patent analysis in anticipation of litigation and/or for
purposes of seeking/providing legal advice.
8/4/2008
WP/Common
Interest
Portion withheld
7
Yitai Hu (Akin Gump)
Wayne Chang (Elan Legal)
Communications with Elan legal department and/or counsel in
anticipation of litigation and/or for purposes of seeking/providing
legal advice re patent analysis
6/30/2008
AC/WP
Entire document
8
JD Tsai
Wayne Chang (Elan Legal), Godwin Chiu, Charles
Pai, Hank Chen, Eliot Lin
Document reflecting communications with Wayne Chang (Elan
Legal) and/or counsel in anticipation of litigation and/or for
purposes of seeking/providing legal advice re patent litigation
3/26/2008
AC/WP
Entire document
9
Elan Legal Department
Document prepared by Elan legal department and/or counsel in
anticipation of litigation and/or for purposes of seeking/providing
legal advice re patent information
8/9/2007
WP
Entire document
10
Godwin Chiu
Wayne Chang (Elan Legal), I.H. Yeh, W.F. Lu
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re settlement negotiation
7/31/2007
AC
Entire document
11
Godwin Chiu
Wayne Chang (Elan Legal), I.H. Yeh, W.F. Lu, Ian
Chung
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent information
12/10/2007
AC
Entire document
NO.
AUTHOR
1
Draco Wu
2
RECIPIENT
Certain Electronic Devices with Multi-Touch Enabled Touchpads and Touchscreens
ITC Inv. No. 337-TA-714
COPY RECIPIENT
DESCRIPTION
Ian Chung
1
Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)
Elan's Privilege Log 2010-10-25
NO.
AUTHOR
RECIPIENT
12
Godwin Chiu
Jeff Cheng (Elan Legal)
Annie Jeong, DJ Seo, Michael Na
13
Godwin Chiu
DATE
PRIVILEGE
ASSERTED
PORTION
WITHHELD
Email communications with Elan legal department and/or counsel
Ian Chung, Wayne Chang (Elan
in anticipation of litigation and/or for purposes of
Legal)
seeking/providing legal advice re contract negotiation
1/28/2008
AC
Entire document
Email communications reflecting communication with Elan legal
department and containing attachment prepared by Elan's outside
Peggy Lin, Charles Pai, Ian Chung
counsel in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent litigation
2/20/2008
AC/WP
Entire document
Email communications reflecting communications with Wayne
Chang (Elan Legal) and/or counsel in anticipation of litigation
and/or for purposes of seeking/providing legal advice re patent
litigation
3/14/2008
AC
Entire document
COPY RECIPIENT
DESCRIPTION
14
Godwin Chiu
Charles Pai, Ian Chung
15
Godwin Chiu
Wayne Chang (Elan Legal), Ian Chung, hank Chen,
William Lee, Charles Pai, JD Tsai, Peggy Lin, Eliot
Lin
I.H. Yeh
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent litigation
3/20/2008
AC
Entire document
16
Godwin Chiu
I.H. Yeh, Ian Chung, Kuo-Lung Yen, Chun-An Tan,
Charles Pai, Ming-Shu Wang, Wayne Chang (Elan
Legal)
Chi-Tien Yeh
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent application
3/23/2008
AC
Entire document
Email communications with Elan legal department and containing
W.F. Lu, Ian Chung, Roven Lee, attachments prepared by Elan legal department and/or counsel in
Wayne Chang (Elan Legal)
anticipation of litigation and/or for purposes of seeking/providing
legal advice re patent analysis and patent litigation
4/16/2008
AC/WP
Entire document
Email communications with Elan legal department and containing
attachments prepared by Elan legal department and/or counsel in
anticipation of litigation and/or for purposes of seeking/providing
legal advice re patent analysis and patent litigation
4/17/2008
AC/WP
Entire document
17
Godwin Chiu
I.H. Yeh, Bill Tsai (Elan Legal)
Wayne Chang (Elan Legal), Bill
Tsai (Elan Legal)
18
Godwin Chiu
I.H. Yeh, Ian Chung, W.F. Lu, Godwin Chiu
19
Godwin Chiu
I.H. Yeh, Wayne Chang (Elan Legal), Roven Lee,
Charlie Huang
Email communications with Elan legal department and/or counsel
Eliot Lin, Ian Chung, Eric Huang,
in anticipation of litigation and/or for purposes of
Maco Tang, Charles Pai
seeking/providing legal advice re patent analysis
4/27/2008
AC
Entire document
20
Godwin Chiu
Chi-Tien Yeh, WenJun Chen, Charles Pai, Roven
Lee, Ian Chung
Email communications with Elan legal department and/or counsel
Wayne Chang (Elan Legal), I.H.
in anticipation of litigation and/or for purposes of
Yeh
seeking/providing legal advice re patent analysis
6/3/2008
AC
Entire document
8/4/2008
AC/WP
Entire document
8/11/2008
AC
Entire document
21
Godwin Chiu
Ian Chung
22
Godwin Chiu
Wayne Chang (Elan Legal), Ian Chung, Charles
Chen
Email communications reflecting communications with Bill Tsai
(Elan Legal) and containing attachments prepared by Elan's
outside counsel in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis.
Certain Electronic Devices with Multi-Touch Enabled Touchpads and Touchscreens
ITC Inv. No. 337-TA-714
Email communications with Elan legal department and/or counsel
I.H. Yeh, Jeff Cheng (Elan Legal) in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis
2
Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)
Elan's Privilege Log 2010-10-25
NO.
AUTHOR
RECIPIENT
COPY RECIPIENT
DESCRIPTION
DATE
PRIVILEGE
ASSERTED
PORTION
WITHHELD
23
I.H. Yeh
Wayne Chang (Elan Legal), Godwin Chiu, W.F. Lu
Ian Chung
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re settlement negotiation
7/31/2007
AC
Entire document
24
I.H. Yeh
Ian Chung, Godwin Chiu, Wayne Chang (Elan Legal)
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis
11/10/2007
AC
Entire document
25
I.H. Yeh
12/1/2007
AC
Entire document
26
I.H. Yeh
12/8/2007
AC
Entire document
27
I.H. Yeh
12/8/2007
AC
Entire document
28
I.H. Yeh
12/25/2007
AC
Entire document
29
I.H. Yeh
12/28/2007
AC
Entire document
30
I.H. Yeh
Ian Chung
Email communications with Elan legal department and/or counsel
Dai-Min Liu, Wayne Chang (Elan
in anticipation of litigation and/or for purposes of
Legal), Godwin Chiu, Charles Pai
seeking/providing legal advice re patent information
12/31/2007
AC
Entire document
31
I.H. Yeh
I.H. Yeh, Ian Chung, Kuo-Lung Yen, Chun-An Tang,
Godwin Chiu, Charles Pai, Ming-Shu Wang, Wayne
Chang (Elan Legal)
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent application
3/22/2008
AC
Entire document
I.H. Yeh
Wayne Chang (Elan Legal), Kuo-Lung Yen, Ian
Chung, Godwin Chiu, W.F. Lu
Email communications with Elan legal department and containing
attachments prepared by Elan legal department and/or counsel in
anticipation of litigation and/or for purposes of seeking/providing
legal advice re patent litigation and settlement
7/31/2008
AC/WP
Entire document
Catherine Pai
Email communications reflecting communications with Wayne
Chang (Elan Legal) and containing attachments prepared by Elan
legal department and/or counsel in anticipation of litigation and/or
for purposes of seeking/providing legal advice re patent analysis
and patent litigation.
8/4/2008
AC/WP
Entire document
32
33
I.H. Yeh
Email communications with Elan legal department and/or counsel
Wayne Chang (Elan Legal), Ian
in anticipation of litigation and/or for purposes of
Chung, Godwin Chiu, Charles Pai
seeking/providing legal advice re patent analysis
Email communications with Elan legal department and/or counsel
W.F. lu, Wayne Chang (Elan Legal), Godwin Chiu
Ian Chung
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis
Email communications with Elan legal department and/or counsel
W.F. Lu, Godwin Chiu, Wayne Chang (Elan Legal)
Phoenix Lin, Ian Chung
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis
Email communications with Elan legal department and/or counsel
Wayne Chang (Elan Legal), Charles Pai, Ian Chung,
in anticipation of litigation and/or for purposes of
Andy Wu, Godwin Chiu, W.F. Lu
seeking/providing legal advice re patent litigation and settlement
negotiation
Email communications with Elan legal department and/or counsel
W.F. Lu, Wayne Chang (Elan Legal), Charles Pai,
in anticipation of litigation and/or for purposes of
W.F. Lu
ian Chung, Andy Wu, Godwin Chiu
seeking/providing legal advice re patent litigation and settlement
negotiation
David Lin
Certain Electronic Devices with Multi-Touch Enabled Touchpads and Touchscreens
ITC Inv. No. 337-TA-714
Chi-Tien Yeh
Godwin Chiu, Ian Chung
3
Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)
Elan's Privilege Log 2010-10-25
NO.
34
35
DESCRIPTION
DATE
PRIVILEGE
ASSERTED
PORTION
WITHHELD
Ian Chung, Godwin Chiu, Dai-Min Liu, W.F. Lu,
Wayne Chang (Elan Legal)
Email communications with Elan legal department and containing
attachments prepared by Elan legal department and/or counsel in
anticipation of litigation and/or for purposes of seeking/providing
legal advice re patent litigation
11/19/2008
AC/WP
Entire document
Charles Pai, Godwin Chiu, Ian Chung, Ming-Shu
Wang, Maco Tang
Email communications reflecting communications with Wayne
Chang (Elan Legal), Bill Tsai (Elan Legal), JH Liu (Elan Legal)
and Nick Lin (Elan Legal) and containing attachments prepared by
11/28/2008
Elan legal department and/or counsel in anticipation of litigation
and/or for purposes of seeking/providing legal advice re patent
application and patent analysis.
AC/WP
Entire document
Email communications reflecting communications with Wayne
Chang (Elan Legal), Bill Tsai (Elan Legal), JH Liu (Elan Legal)
and Nick Lin (Elan Legal) and containing attachments prepared by
Elan legal department and/or counsel in anticipation of litigation
and/or for purposes of seeking/providing legal advice re patent
application and patent analysis.
12/1/2008
AC/WP
Entire document
AUTHOR
RECIPIENT
I.H. Yeh
Wen Kai Lee
COPY RECIPIENT
36
Wen Kai Lee
Maco Tang, Charles Pai, Ming-Shu Wang, Ian
Chung, Godwin Chiu
37
Roven Lee
Godwin Chiu, I.H. Yeh, Wayne Chang (Elan Legal),
Charlie Huang
Email communications with Elan legal department and/or counsel
Eliot Lin, Ian Chung, Eric Huang,
in anticipation of litigation and/or for purposes of
Maco Tang, Charles Pai
seeking/providing legal advice re patent analysis
4/28/2008
AC
Entire document
William Lee, David Lin, Charlie Huang, Ian Chung
Email communications reflecting communications with Wayne
Maco Tang, Roven Lee, Godwin Chang (Elan Legal) and/or counsel in anticipation of litigation
Chiu
and/or for purposes of seeking/providing legal advice re patent
analysis and patent litigation.
9/10/2007
AC
Entire document
11/11/2007
AC
Entire document
38
Chi-Tien Yeh
39
David Lin
Wayne Chang (Elan Legal)
Email communications with Elan legal department and/or counsel
Godwin Chiu, Ian Chung, I.H. Yeh, in anticipation of litigation and/or for purposes of
Peggy Lin
seeking/providing legal advice re patent analysis and patent
litigation
40
Charlie Huang
Godwin Chiu, I.H. Yeh, Wayne Chang (Elan Legal),
Roven Lee
Email communications with Elan legal department and/or counsel
Eliot Lin, Ian Chung, Eric Huang,
in anticipation of litigation and/or for purposes of
Maco Tang, Charles Pai
seeking/providing legal advice re patent analysis
4/28/2008
AC
Entire document
Eliot Lin
Godwin Chiu, Wayne Chang (Elan Legal), Ian
Chung, Hank Chen, William Lee, Charles Pai, JD
Tsai, Peggy Lin
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis and patent
litigation
3/24/2008
AC
Entire document
I.H. Yeh, Wayne Chang (Elan Legal)
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis and patent
litigation
12/17/2007
AC
Entire document
41
42
Charles Pai
Certain Electronic Devices with Multi-Touch Enabled Touchpads and Touchscreens
ITC Inv. No. 337-TA-714
Ian Chung, Godwin Chiu
4
Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)
Elan's Privilege Log 2010-10-25
NO.
43
44
45
46
AUTHOR
Charles Pai
Charles Pai
Charles Pai
RECIPIENT
Wayne Chang (Elan Legal), I.H. Yeh
Ian Chung
Daniel Chen
Charles Pai
Ian Chung, Wayne Chang (Elan Legal)
Hank Chen
wangyong@longcheertel.com;
yangrongsheng@longcheertel.com
48
Hank Chen
Godwin Chiu, Wayne Chang (Elan Legal), Ian
Chung, William Lee, Charles Pai, JD Tsai, Peggy Lin,
Eliot Lin
49
Hank Chen
50
JD Tsai
51
Pei Wang
William Lee, Chi-Tien Yeh
DESCRIPTION
DATE
PRIVILEGE
ASSERTED
PORTION
WITHHELD
Ian Chung, Godwin Chiu
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis and patent
litigation
12/17/2007
AC
Entire document
Email communications reflecting communications with Wayne
Chang (Elan Legal), Bill Tsai (Elan Legal) and Jeff Cheng (Elan
Legal) and containing attachments prepared by Elan legal
department and/or counsel in anticipation of litigation and/or for
purposes of seeking/providing legal advice re NDA agreement,
patent analysis and patent litigation.
2/27/2008
AC/WP
Entire document
2/27/2008
WP/Common
Interest
Entire document
3/21/2008
AC/WP
Entire document
1/31/2008
WP/Common
Interest
Entire document
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis and patent
litigation
3/21/2008
AC/WP
Entire document
Email communications containing attachments prepared by Elan
legal department and/or counsel in anticipation of litigation and/or
for purposes of seeking/providing legal advice re patent litigation
6/24/2008
WP
Entire document
3/25/2008
AC
Entire document
9/11/2007
AC
Entire document
Godwin Chiu
Document prepared by Elan for third parties having a common
Ming-Shu Wang, Eva Chen,
legal interest with Elan, containing communications with counsel
James Chen, Wayne Chang (Elan
regarding patent analysis in anticipation of litigation and/or for
Legal)
purposes of seeking/providing legal advice.
Godwin Chiu, Ming-Shu Wang,
Jeff Cheng (Elan Legal)
Godwin Chiu, Ian Chung, JD Tsai
Godwin Chiu, Wayne Chang (Elan Legal), Ian
Chung, Hank Chen, William Lee, Charles Pai, Peggy
Lin, Eliot Lin
COPY RECIPIENT
47
Certain Electronic Devices with Multi-Touch Enabled Touchpads and Touchscreens
ITC Inv. No. 337-TA-714
Email communications with Elan legal department and containing
attachments prepared by Elan legal department and/or counsel in
anticipation of litigation and/or for purposes of seeking/providing
legal advice re NDA agreement; patent analysis and patent
litigation
Document prepared by Elan for third parties having a common
Ian Chung, Godwin Chiu, Wayne legal interest with Elan, containing communications with counsel
Chang (Elan Legal)
regarding patent analysis in anticipation of litigation and/or for
purposes of seeking/providing legal advice.
I.H. Yeh
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis and patent
litigation
Email communications reflecting communications with Wayne
David Lin, Charlie Huang, Ian
Chang (Elan Legal) and/or counsel in anticipation of litigation
Chung, Maco Tang, Roven Lee,
and/or for purposes of seeking/providing legal advice re patent
Godwin Chiu
litigation
5
Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)
Elan's Privilege Log 2010-10-25
NO.
AUTHOR
RECIPIENT
DATE
PRIVILEGE
ASSERTED
PORTION
WITHHELD
Email communications reflecting communications with Wayne
Chi-Tien Yeh, David Lin, Charlie
Chang (Elan Legal) and/or counsel in anticipation of litigation
Huang, Ian Chung, Maco Tang,
and/or for purposes of seeking/providing legal advice re patent
Roven Lee, Godwin Chiu
litigation.
9/12/2007
AC
Entire document
COPY RECIPIENT
DESCRIPTION
52
Pei Wang
William Lee
53
Jeff Cheng (Elan Legal)
David Lin
Email communications with Elan legal department and/or counsel
Godwin Chiu, Ian Chung, Wayne
in anticipation of litigation and/or for purposes of
Chang (Elan Legal)
seeking/providing legal advice re NDA agreement
12/21/2007
AC/WP
Entire document
54
Jeff Cheng (Elan Legal)
Godwin Chiu
Email communications with Elan legal department and/or counsel
Ian Chung, Wayne Chang (Elan
in anticipation of litigation and/or for purposes of
Legal)
seeking/providing legal advice re NDA agreement
1/28/2008
AC
Entire document
Godwin Chiu, I.H. Yeh, W.F. Lu
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re NDA agreement and patent
litigation
7/6/2007
AC
Entire document
Godwin Chiu, I.H. Yeh, W.F. Lu
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re NDA agreement and patent
litigation
7/6/2007
AC
Entire document
Godwin Chiu, I.H. Yeh
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis and patent
litigation
7/9/2007
AC
Entire document
7/10/2007
AC/WP
Entire document
55
56
57
Wayne Chang (Elan Legal)
Wayne Chang (Elan Legal)
Wayne Chang (Elan Legal)
Ian Chung
Ian Chung
Ian Chung
58
Wayne Chang (Elan Legal)
Ian Chung
Godwin Chiu, I.H. Yeh
Email communications with Elan legal department and containing
attachments prepared by Elan legal department and/or counsel in
anticipation of litigation and/or for purposes of seeking/providing
legal advice re patent information
59
Wayne Chang (Elan Legal)
I.H. Yeh, Godwin Chiu, W.F. Lu
Ian Chung
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent litigation and settlement
7/31/2007
AC
Entire document
60
Wayne Chang (Elan Legal)
Godwin Chiu, I.H. Yeh, W.F. Lu
Ian Chung
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent litigation and settlement
8/2/2007
AC
Entire document
Godwin Chiu
Email communications with Elan legal department and containing
attachments prepared by Elan legal department and/or counsel in
anticipation of litigation and/or for purposes of seeking/providing
legal advice re patent information
8/22/2007
AC/WP
Entire document
61
Wayne Chang (Elan Legal)
Ian Chung
Certain Electronic Devices with Multi-Touch Enabled Touchpads and Touchscreens
ITC Inv. No. 337-TA-714
6
Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)
Elan's Privilege Log 2010-10-25
NO.
62
63
AUTHOR
Wayne Chang (Elan Legal)
Wayne Chang (Elan Legal)
RECIPIENT
Terial Lu
Godwin Chiu, Ian Chung
DATE
PRIVILEGE
ASSERTED
PORTION
WITHHELD
Ian Chung
Document prepared by Elan for third parties having a common
legal interest with Elan, containing communications with counsel
regarding patent analysis in anticipation of litigation and/or for
purposes of seeking/providing legal advice.
10/4/2007
WP/Common
Interest
Entire document
I.H. Yeh
Email communications with Elan legal department and containing
attachments prepared by Elan legal department and/or counsel in
anticipation of litigation and/or for purposes of seeking/providing
legal advice re indemnification agreement
11/6/2007
AC/WP
Entire document
11/6/2007
AC/WP
Entire document
COPY RECIPIENT
DESCRIPTION
64
Wayne Chang (Elan Legal)
Ian Chung
Email communications with Elan legal department and containing
attachments prepared by Elan legal department and/or counsel in
anticipation of litigation and/or for purposes of seeking/providing
legal advice re indemnification agreement
65
Wayne Chang (Elan Legal)
I.H. Yeh, W.F. Lu, Godwin Chiu, Ian Chung
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis
12/9/2007
AC
Entire document
66
Wayne Chang (Elan Legal)
Charles Pai, I.H. Yeh
Ian Chung, Godwin Chiu
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis
12/17/2007
AC
Entire document
67
Wayne Chang (Elan Legal)
Charles Pai, I.H. Yeh
Ian Chung, Godwin Chiu
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis
12/17/2007
AC
Entire document
68
Wayne Chang (Elan Legal)
I.H. Yeh, Charles Pai, Ian Chung, Andy Wu, Godwin
Chiu, W.F. Lu
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis and patent
litigation
12/25/2007
AC
Entire document
69
Wayne Chang (Elan Legal)
I.H. Yeh, Ian Chung, Godwin Chiu, Dai-Min Liu, W.F.
Lu
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent litigation
11/19/2008
AC
Entire document
70
Jason Oung
Ian Chung
Email communications containing attachments prepared by Elan
legal department and/or counsel in anticipation of litigation and/or
for purposes of seeking/providing legal advice re patent litigation.
8/5/2008
WP
Portion withheld
Email communications containing attachment prepared by Elan
legal department and/or counsel in anticipation of litigation and/or
for purposes of seeking/providing legal advice re patent analysis
and patent litigation
6/16/2008
WP
Portion withheld
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis
6/13/2007
AC
Entire document
71
Ivy Chen
Ian Chung
72
Daisuke Shudo
Godwin Chiu, Ocean Chen, I.H. Yeh, Wayne Chang
(Elan Legal)
Godwin Chiu
Certain Electronic Devices with Multi-Touch Enabled Touchpads and Touchscreens
ITC Inv. No. 337-TA-714
Ian Chung, Rich Tan, Fumiaki
Karasawa, Denny Huang, W.F.
Lu, Draco Wu
7
Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)
Elan's Privilege Log 2010-10-25
NO.
AUTHOR
DATE
PRIVILEGE
ASSERTED
PORTION
WITHHELD
Ian Chung, Rich Tan, Fumiaki
Karasawa, Denny Huang, W.F.
Lu, Godwin Chiu, Ocean Chen,
I.H. Yeh, Wayne Chang (Elan Email communications with Elan legal department and/or counsel
Legal), Jacky Wu, Eric Yang, Alan in anticipation of litigation and/or for purposes of
Tsai, Saturn Tu, Alex Lee, Darren seeking/providing legal advice re patent analysis
Chen, Miller Wang, Peter He, Ago
Lin, Jim Huang, Jane Chen,
Jimmy Liu, Leo Chen
RECIPIENT
6/27/2007
AC
Entire document
COPY RECIPIENT
DESCRIPTION
73
Draco Wu
Daisuke Shudo
74
W.F. Lu
Godwin Chiu, Wayne Chang (Elan Legal), I.H. Yeh
Phoenix Lin, Ian Chung
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis
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W.F. Lu
I.H. Yeh, Wayne Chang (Elan Legal), Charles Pai,
Ian Chung, Andy Wu, Godwin Chiu
W.F. Lu
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent litigation and settlement
12/28/2007
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in anticipation of litigation and/or for purposes of
Godwin Chiu, Ian Chung, Rich Tan
seeking/providing legal advice re patent application and patent
analysis
5/29/2008
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Ji-Han Liu (Elan Legal)
Wayne Chang (Elan Legal), I.H. Yeh, W.F. Lu
77
I.H. Yeh
Wayne Chang (Elan Legal), Kuo-Lung Yen, Ian
Chung, Steven Tsai, Godwin Chiu, Charles Pai,
Venny Lin
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent litigation and settlement
8/14/2008
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I.H. Yeh
W.F. Lu, Venny Lin, Charles Pai, Godwin Chiu,
Steven tsai, Ian Chung, Kuo-Lung Yen, Wayne
Chang (Elan Legal)
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in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent litigation and settlement
8/27/2008
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I.H. Yeh
Nick Lin (Elan Legal), Wayne Chang (Elan Legal),
Bill Tsai (Elan Legal), Ian Chung, Godwin Chiu, KuoLung Yen, Charles Pai
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent information
2/3/2009
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Ian Chung
Email communications reflecting communications with Bill Tsai
(Elan Legal) and Eve Chang (Elan Legal) and containing
attachments prepared by Elan legal department and/or counsel in
anticipation of litigation and/or for purposes of seeking/providing
legal advice re patent application information
11/18/2008
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Ian Chung
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Godwin Chiu, Kuo-Lung Yen, I.H.
attachments prepared by Elan legal department and/or counsel in
Yeh, Bill Tsai (Elan Legal), Nick
anticipation of litigation and/or for purposes of seeking/providing
Lin (Elan Legal)
legal advice re patent analysis
2/4/2009
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Vivian Yang
Wayne Chang (Elan Legal)
Certain Electronic Devices with Multi-Touch Enabled Touchpads and Touchscreens
ITC Inv. No. 337-TA-714
8
Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)
Elan's Privilege Log 2010-10-25
DESCRIPTION
DATE
PRIVILEGE
ASSERTED
PORTION
WITHHELD
I.H. Yeh, Ian Chung, Godwin Chiu
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in anticipation of litigation and/or for purposes of
seeking/providing legal advice re NDA agreement
11/10/2008
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Godwin Chiu
Wayne Chang (Elan Legal), I.H. Yeh, Ian Chung
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in anticipation of litigation and/or for purposes of
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11/10/2008
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I.H. Yeh
Wayne Chang (Elan Legal), Godwin Chiu
Email communications with Elan legal department and/or counsel
Charles Pai, Ian Chung, Kuo-Lung
in anticipation of litigation and/or for purposes of
Yen
seeking/providing legal advice re NDA agreement
12/5/2008
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Godwin Chiu
I.H. Yeh, Wayne Chang (Elan Legal)
Email communications with Elan legal department and/or counsel
Charles Pai, Ian Chung, Kuo-Lung
in anticipation of litigation and/or for purposes of
Yen
seeking/providing legal advice re NDA agreement
12/5/2008
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I.H. Yeh
Godwin Chiu, Wayne Chang (Elan Legal)
Email communications with Elan legal department and/or counsel
Charles Pai, Ian Chung, Kuo-Lung
in anticipation of litigation and/or for purposes of
Yen
seeking/providing legal advice re NDA agreement
12/5/2008
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Wayne Chang (Elan Legal)
I.H. Yeh, Godwin Chiu
Email communications with Elan legal department and/or counsel
Charles Pai, Ian Chung, Kuo-Lung
in anticipation of litigation and/or for purposes of
Yen
seeking/providing legal advice re NDA agreement
12/5/2008
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Ian Chung
Wayne Chang (Elan Legal)
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent litigation
7/9/2007
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Ian Chung
Terial Lu
Email communications with Elan legal department and/or counsel
Huang Lee, Odin Chang, Godwin
in anticipation of litigation and/or for purposes of
Chiu, Wayne Chang (Elan Legal)
seeking/providing legal advice re patent information
7/27/2007
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Wayne Chang (Elan Legal)
83
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Godwin Chiu, I.H. Yeh, W.F. Lu
90
Ian Chung
Odin Chang
Email communications with Elan legal department and/or counsel
Godwin Chiu, Wayne Chang (Elan in anticipation of litigation and/or for purposes of
Legal), Peggy Wen, Jennifer Hung seeking/providing legal advice re patent litigation and indemnity
agreement
91
Ian Chung
I.H. Yeh
Email communications with Elan legal department and/or counsel
Dai-Min Liu, Wayne Chang (Elan
in anticipation of litigation and/or for purposes of
Legal), Godwin Chiu, Charles Pai
seeking/providing legal advice re patent information
92
Ian Chung
Wayne Chang (Elan Legal)
93
Ian Chung
Eva Chen
Certain Electronic Devices with Multi-Touch Enabled Touchpads and Touchscreens
ITC Inv. No. 337-TA-714
Godwin Chiu, Charles Pai, I.H.
Yeh, Bill Tsai (Elan Legal)
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent information
1/4/2008
AC
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Godwin Chiu, Charles Pai
Email communications reflecting communications with Wayne
Chang (Elan Legal) and Jeff Cheng (Elan Legal) and containing
attachments prepared by Elan legal department and/or counsel in
anticipation of litigation and/or for purposes of seeking/providing
legal advice re NDA agreement and patent information
3/21/2008
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Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)
Elan's Privilege Log 2010-10-25
NO.
AUTHOR
94
Nick Lin (Elan Legal)
95
Akin Gump (outside counsel)
96
Akin Gump (outside counsel)
97
Charles Pai
RECIPIENT
COPY RECIPIENT
Document prepared by Elan legal department and/or counsel in
anticipation of litigation and/or for purposes of seeking/providing
legal advice re patent information
Document prepared by Elan's outside counsel in anticipation of
litigation and/or for purposes of seeking/providing legal advice re
patent analysis
Document prepared by Elan's outside counsel in anticipation of
litigation and/or for purposes of seeking/providing legal advice re
patent litigation
PRIVILEGE
ASSERTED
PORTION
WITHHELD
2/24/2009
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Kuo-Lung Yen, W.F. Lu, Bill Tsai Email communications with Elan legal department and/or counsel
(Elan Legal), Godwin Chiu, Ji-Han in anticipation of litigation and/or for purposes of
Liu (Elan Legal)
seeking/providing legal advice re patent information
2/13/2009
AC/WP
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Email communications reflecting communications with Wayne
Chang (Elan Legal), Bill Tsai (Elan Legal), JH Liu (Elan Legal)
and Nick Lin (Elan Legal) and containing attachment prepared by
Elan legal department and/or counsel in anticipation of litigation
and/or for purposes of seeking/providing legal advice re patent
information
3/2/2009
AC/WP
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Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent litigation
9/19/2008
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Charles Pai
Ming-Shu Wang , Roven Lee, WenJun Chen, Maco
Tang, Chi-Tien Yeh
99
Richard Chae (Akin Gump)
Roven Lee, Wayne Chang (Elan Legal)
100
Bill Tsai (Elan Legal)
Jimmy Wang, Ming-Shu Wang, Roven Lee, Tokui
Tsai
101
Nick Lin (Elan Legal)
Jimmy Wang, Roven Lee, Jesse Lin, Vincent Tao,
Chun-Chung Huang, Rong-Shou Huang, Chi-Tien
Yeh, Bill Tsai (Elan Legal)
102
Bill Tsai (Elan Legal)
Roven Lee
Nick Lin (Elan Legal)
DATE
Nick Lin (Elan Legal), Wayne Chang (Elan Legal),
I.H. Yeh
98
103
DESCRIPTION
Elantech Team
Email communications with Elan legal department and containing
Charles Pai, Godwin Chiu, Rongattachments prepared by Elan legal department and/or counsel in
Shou Huang, Chi-Tien Yeh, Nick
anticipation of litigation and/or for purposes of seeking/providing
Lin (Elan Legal), Eve Chang
legal advice re patent information
Email communications with Elan legal department and containing
Kuo-Lung Yen, Godwin Chiu,
attachments prepared by Elan legal department and/or counsel in
Wayne Chang (Elan Legal)
anticipation of litigation and/or for purposes of seeking/providing
legal advice re patent information
Email communications with Elan legal department and containing
attachments prepared by Elan legal department and/or counsel in
anticipation of litigation and/or for purposes of seeking/providing
legal advice re patent information
Email communications with Elan legal department and containing
Ming-Shu Wang, Chi-Tien Yeh, WJ Hsu, Venny Lin,
Kuo-Lung Yen, Wayne Chang attachments prepared by Elan legal department and/or counsel in
Chun-Chung Huang, James Chen, Roven Lee, TH
(Elan Legal), Bill Tsai (Elan Legal) anticipation of litigation and/or for purposes of seeking/providing
Liu, Vincent Tao
legal advice re patent and patent analysis
Certain Electronic Devices with Multi-Touch Enabled Touchpads and Touchscreens
ITC Inv. No. 337-TA-714
10
Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)
Elan's Privilege Log 2010-10-25
NO.
104
105
AUTHOR
Jimmy Wang
Roven Lee
DATE
PRIVILEGE
ASSERTED
PORTION
WITHHELD
Rong-Shou Huang, Roven Lee,
Email communications with Elan legal department and/or counsel
Chi-Tien Yeh, Vincent Tao, Kuoin anticipation of litigation and/or for purposes of
Lung Yen, Wayne Chang (Elan
seeking/providing legal advice re patent and patent analysis
Legal), Chun-Chung Huang
4/6/2009
AC
Entire document
Ian Chung
Email communications reflecting communications with Eve Chang
(Elan Legal) and containing attachments prepared by Elan legal
department and/or counsel in anticipation of litigation and/or for
purposes of seeking/providing legal advice re patent application
5/20/2005
AC/WP
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attachments prepared by Elan legal department and/or counsel in
anticipation of litigation and/or for purposes of seeking/providing
legal advice re patent information
4/1/2009
AC/WP
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Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent and patent analysis
3/29/2006
AC
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RECIPIENT
Bill Tsai (Elan Legal), Nick Lin (Elan Legal)
COPY RECIPIENT
DESCRIPTION
106
Roven Lee
Bill Tsai (Elan Legal)
107
Roven Lee
Clark Jablon (Outside Counsel )
108
Chipworks, Inc.
Elan Legal Department
Document prepared at direction of Elan legal department and/or
counsel in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis
7/11/2008
AC/WP
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109
Akin Gump (outside counsel)
Wayne Chang (Elan Legal)
Document prepared by Elan's outside counsel in preparation of
litigation and/or for purposes of providing legal advice re patent
analysis
4/20/2006
AC/WP
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110
Chipworks, Inc.
Elan Legal Department
Document prepared at direction of Elan legal department and/or
counsel in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis
4/1/2009
AC/WP
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111
Chipworks, Inc.
Elan Legal Department
Document prepared at direction of Elan legal department and/or
counsel in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis
4/1/2009
AC/WP
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112
Chipworks, Inc.
Elan Legal Department
Document prepared at direction of Elan legal department and/or
counsel in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis
8/20/2008
AC/WP
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113
Elan Legal Department
Document prepared by Elan legal department and/or counsel in
anticipation of litigation and/or for purposes of seeking/providing
legal advice re patent litigation.
10/31/2007
AC/WP
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114
Godwin Chiu; Ting-Hao Yeh;
Yung-Lieh Chien; Shih-Chi Lin
Document prepared at direction of Elan legal department and/or
counsel in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent application
2/12/2003
AC/WP
Entire document
Wayne Chang (Elan Legal),
Godwin Chiu
Elan Legal Department
Certain Electronic Devices with Multi-Touch Enabled Touchpads and Touchscreens
ITC Inv. No. 337-TA-714
11
Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)
Elan's Privilege Log 2010-10-25
AUTHOR
RECIPIENT
115
Phoenix Lin
Ji-Han Liu (Elan Legal)
117
Phoenix Lin
Herod Gong
PRIVILEGE
ASSERTED
PORTION
WITHHELD
3/25/2009
WP
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Alfie Tsai, Eric Yang, W.F. Lu
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent and patent analysis
1/18/2008
AC
Entire document
Matt You
Email communications containing information prepared by Elan
legal department and/or counsel in anticipation of litigation and/or
for purposes of seeking/providing legal advice re patent analysis
6/17/2008
AC/WP
Portion withheld
Email communications with Elan legal department and containing
attachments prepared by Elan legal department and/or counsel in
anticipation of litigation and/or for purposes of seeking/providing
legal advice re patent analysis
9/4/2008
AC/WP
Entire document
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent litigation
10/3/2008
AC
Entire document
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis
12/1/2008
AC
Entire document
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis
2/4/2009
AC
Entire document
9/5/2008
AC/WP
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Elan Legal Department
116
DATE
Document prepared by Elan legal department and/or counsel in
anticipation of litigation and/or for purposes of seeking/providing
legal advice re patent information
NO.
118
Phoenix Lin
Ji-Han Liu (Elan Legal)
119
Phoenix Lin
Wayne Chang (Elan Legal)
120
Phoenix Lin
Wayne Chang (Elan Legal)
121
Phoenix Lin
Ji-Han Liu (Elan Legal)
COPY RECIPIENT
W.F. Lu
Eric Yang, W.F. Lu, Violet Yeh,
Liyu Chan
DESCRIPTION
122
W.F. Lu
Phoenix Lin, Ji-Han Liu (Elan Legal)
Email communications with Elan legal department and containing
attachments prepared by Elan legal department and/or counsel in
anticipation of litigation and/or for purposes of seeking/providing
legal advice re patent analysis
123
Ji-Han Liu (Elan Legal)
Ji-Han Liu (Elan Legal), Phoenix Lin
Daisuke Shudo, Rich Tan, Ocean Email communications with Elan legal department and/or counsel
Chen, Eric Yang, W.F. Lu, Jenny in anticipation of litigation and/or for purposes of
Chang
seeking/providing legal advice re patent information
7/10/2007
AC
Entire document
Ocean Chen, W.F. Lu, Phoenix
Lin, Lina Kao, Eddie Wei, Jack
Chang, Jan Chen, Stober Chen,
Rich Tan, Daisuke Shudo
Email communications with Elan legal department and containing
attachments prepared by Elan legal department and/or counsel in
anticipation of litigation and/or for purposes of seeking/providing
legal advice re OEM agreement
10/16/2007
AC/WP
Entire document
Eve Chang (Elan Legal), Wayne Email communications with Elan legal department and/or counsel
Chang (Elan Legal), Rich Tan, in anticipation of litigation and/or for purposes of
W.F. Lu
seeking/providing legal advice re Trademark application
1/12/2009
AC
Entire document
124
Ji-Han Liu (Elan Legal)
KL Chen
125
Ji-Han Liu (Elan Legal)
Eric Yang, Alfie Tsai, Phoenix Lin
Certain Electronic Devices with Multi-Touch Enabled Touchpads and Touchscreens
ITC Inv. No. 337-TA-714
12
Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)
Elan's Privilege Log 2010-10-25
NO.
126
127
128
129
130
131
132
AUTHOR
RECIPIENT
DATE
PRIVILEGE
ASSERTED
PORTION
WITHHELD
Email communications containing information prepared at the
Chia-Miao Wu, Eric Yang, Phoenix direction of Elan legal department and/or counsel in anticipation of
Lin, Ocean Chen
litigation and/or for purposes of seeking/providing legal advice re
patent litigation and settlement negotiation
8/30/2007
AC
Entire document
COPY RECIPIENT
DESCRIPTION
W.F. Lu
I.H. Yeh
W.F. Lu
Ji-Han Liu (Elan Legal), Eric Yang, Alfie Tsai, Jacky
Wu, Phoenix Lin
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis and patent
information
4/16/2008
AC
Entire document
Ji-Han Liu (Elan Legal), Phoenix Lin, Alfie Tsai
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent litigation and cease and
desist letter
4/18/2008
AC
Entire document
Wayne Chang (Elan Legal)
I.H. Yeh, Phoenix Lin
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent litigation and cease and
desist letter
6/6/2008
AC
Entire document
I.H. Yeh, Phoenix Lin
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent litigation and cease and
desist letter
6/6/2008
AC
Entire document
I.H. Yeh, Phoenix Lin
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent litigation and cease and
desist letter
6/6/2008
AC
Entire document
I.H. Yeh, Phoenix Lin
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent litigation and cease and
desist letter
6/6/2008
AC
Entire document
6/6/2008
AC
Entire document
W.F. Lu
W.F. Lu
Wayne Chang (Elan Legal)
W.F. Lu
W.F. Lu
W.F. Lu
Wayne Chang (Elan Legal)
Wayne Chang (Elan Legal)
133
Wayne Chang (Elan Legal)
W.F. Lu
I.H. Yeh, Phoenix Lin
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent litigation and cease and
desist letter
134
W.F. Lu
Wayne Chang (Elan Legal), Ji-Han Liu (Elan Legal)
I.H. Yeh, Alfie Tsai, Phoenix Lin
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent information
7/15/2008
AC
Entire document
Ji-Han Liu (Elan Legal)
Liyu Chan, Ocean Chen, W.F. Lu,
KL Chen, Phoenix Lin, Lina Kao,
Eddie Wei, Jack Chang, Jan
Chen, Stober Chen
Email communications with Elan legal department and containing
attachments prepared by Elan legal department and/or counsel in
anticipation of litigation and/or for purposes of seeking/providing
legal advice re OEM agreement
9/5/2007
AC
Entire document
135
Rich Tan
Certain Electronic Devices with Multi-Touch Enabled Touchpads and Touchscreens
ITC Inv. No. 337-TA-714
13
Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)
Elan's Privilege Log 2010-10-25
NO.
136
137
138
139
140
AUTHOR
RECIPIENT
Wayne Chang (Elan Legal)
DESCRIPTION
DATE
PRIVILEGE
ASSERTED
PORTION
WITHHELD
Email communications with Elan legal department and containing
attachments prepared by Elan legal department and/or counsel in
anticipation of litigation and/or for purposes of seeking/providing
legal advice re patent and patent litigation
9/18/2008
AC/WP
Entire document
Email communications with Elan legal department and containing
I.H. Yeh, Wayne Chang (Elan
attachments prepared by Elan legal department and/or counsel in
Legal), W.F. Lu, Ji-Han Liu (Elan
anticipation of litigation and/or for purposes of seeking/providing
Legal), Nick Lin (Elan Legal)
legal advice re patent information
11/29/2008
AC/WP
Entire document
Email communications with Elan legal department and containing
attachments prepared by Elan legal department and/or counsel in
anticipation of litigation and/or for purposes of seeking/providing
legal advice re patent analysis and patent litigation
12/20/2007
AC/WP
Entire document
Email communications reflecting communications with Wayne
Chang (Elan Legal), Eve Chang (Elan Legal) and JH Liu (Elan
Legal) and containing attachments prepared by Elan legal
department and/or counsel in anticipation of litigation and/or for
purposes of seeking/providing legal advice re patent litigation
5/30/2008
AC/WP
Entire document
Email communication with Elan legal department and containing
document prepared at direction of Elan legal department and/or
counsel in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis
4/22/2008
AC/WP
Entire document
5/23/2008
AC/WP
Portion withheld
Alfie Tsai, Phoenix Lin, W.F. Lu, I.H. Yeh, Jeff Cheng
(Elan Legal)
Bill Tsai (Elan Legal)
Wayne Chang (Elan Legal)
Violet Yeh
Alfie Tsai
Wen Kai Lee, Samuel Hsu, Alfie Tsai, Jan Chen
Phoenix Lin
Alfie Tsai
COPY RECIPIENT
W.F. Lu
W.F. Lu, Phoenix Lin
Wayne Chang (Elan Legal), Phoenix Lin
141
Alfie Tsai
Phoenix Lin
Email communications containing attachment prepared by or at
direction of Elan legal department and/or counsel in anticipation of
litigation and/or for purposes of seeking/providing legal advice re
patent analysis
142
Liyu Chan
Elsa Tsai (Elan Legal), Phoenix Lin
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent and indemnity agreement
10/8/2008
AC
Entire document
143
Elsa Tsai (Elan Legal)
Phoenix Lin, Liyu Chang
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent and indemnity agreement
10/15/2008
AC
Entire document
144
Sophia Wang
Eric Yang
Email communications reflecting communications with Wayne
Chang (Elan Legal) in anticipation of litigation and/or for purposes
of seeking/providing legal advice re patent litigation.
7/9/2006
AC
Entire Document
Certain Electronic Devices with Multi-Touch Enabled Touchpads and Touchscreens
ITC Inv. No. 337-TA-714
Wayne Chang (Elan Legal)
14
Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)
Elan's Privilege Log 2010-10-25
NO.
145
146
AUTHOR
Daisuke Shudo
JH Liu (Elan Legal)
RECIPIENT
Duke Shudo; Ocean Chen; Rich Tan
COPY RECIPIENT
DESCRIPTION
Wayne Chang (Elan Legal);
Godwin Chiu; IH Yeh; Allen
Email communications with Elan legal department and/or counsel
Chang; Denny Huang; Draco Wu;
in anticipation of litigation and/or for purposes of
Eddie Wei; Eric Yang; Ian Chung;
seeking/providing legal advice re patent strategy.
Jack Chang; Jason Liu; Karasawa,
Fumiaki; Lina Kao; Stober Chen
DATE
PRIVILEGE
ASSERTED
PORTION
WITHHELD
10/29/2006
AC
Entire Document
Rich Tan, Daisuke Shudo
Jason Liu, Eric Yang, Liyu Chan,
Jan Chen, Debby Yu, Stober
Chen, Lina Kao, Ocean Chen,
Chung-Nan Chang
Email communications with Elan legal department and containing
attachment prepared by Elan legal department in anticipation of
litigation and/or for purposes of seeking/providing legal advice re
draft agreement.
6/14/2007
AC/WP
Entire Document
Ian Chung, Rich Tan, Karasawa
Fumiaki, Denny Huang, WF Lu,
Godwin Chiu, Ocean Chen,,IH
Yeh, Wayne Chang (Elan Legal),
Jacky Wu, Eric Yang, Alan Tsai,
Saturn Tu, Alex Lee, Darren Chen,
Miller Wang, Peter He
Email communications with Elan legal department and containing
attachment prepared at direction of Elan legal department in
anticipation of litigation and/or for purposes of seeking/providing
legal advice re patent analysis.
6/27/2007
AC/WP
Entire Document
Daisuke Shudo, Rich Tan, Ocean
Chen, Eric Yang, WF Lu, JH Liu
(Elan Legal)
Daisuke Shudo, Rich Tan, Ocean
Chen, Eric Yang, WF Lu, Jenny
Chang
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent search and analysis.
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent search and analysis.
7/9/2007
AC
Entire Document
7/9/2007
AC
Entire Document
Email communications reflecting communication with Wayne
Chang (Elan Legal) counsel in anticipation of litigation and/or for
purposes of seeking/providing legal advice re patent analysis.
7/30/2007
AC
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10/15/2007
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11/26/2007
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4/16/2008
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147
Draco Wu
Daisuke Shudo
148
JH Liu (Elan Legal)
Phoenix Lin
149
JH Liu (Elan Legal)
JH Liu (Elan Legal), Phoenix Lin
150
Rich Tan
Stober Chen, Eric Yang
Ocean Chen
Rich Tan, Ocean Chen, WF Lu,
Phoenix Lin
151
JH Liu (Elan Legal)
Eric Yang
152
Wayne Chang (Elan Legal)
WF Lu, Phoenix Lin, JH Liu (Elan Legal), Eric Yang,
IH Yeh, Bill Tsai (Elan Legal)
153
WF Lu
JH Liu (Elan Legal), Eric Yang, Alfie Tsai, Jacky Wu,
Phoenix Lin
Certain Electronic Devices with Multi-Touch Enabled Touchpads and Touchscreens
ITC Inv. No. 337-TA-714
15
Email communications with Elan legal department and containing
attachments prepared by Elan legal department in anticipation of
litigation and/or for purposes of seeking/providing legal advice re
patent analysis.
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis.
Email communications with Elan legal department and containing
attachments prepared by Elan legal department in anticipation of
litigation and/or for purposes of seeking/providing legal advice re
patent analysis.
Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)
Elan's Privilege Log 2010-10-25
NO.
AUTHOR
RECIPIENT
154
WF Lu
JH Liu (Elan Legal), Eric Yang
155
Draco Wu
Godwin Chiu
156
JH Liu (Elan Legal)
WF Lu
157
JH Liu (Elan Legal)
Eric Yang
158
JH Liu (Elan Legal)
Phoenix Lin, WF Lu, Eric Yang, Alfie Tsai, Wayne
Chang (Elan Legal), Bill Tsai (Elan Legal), IH Yeh,
Rich Tan, Draco Wu
159
Jenny Chang
Eric Yang
160
JH Liu (Elan Legal)
Eric Yang
161
Godwin Chiu
Daisuke Shudo
162
Wayne Chang (Elan Legal)
Daisuke Shudo
163
Wayne Chang (Elan Legal)
Daisuke Shudo
164
Roven Lee
Kelvin Chien, Wayne Chang (Elan
Legal), Kelvin Chien, Jacky Wu,
Hsiu-Yun Chen, Bill Tsai (Elan
legal), Rich Tan, Daisuke Shudo,
Eric Yang, Jacky
DATE
PRIVILEGE
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PORTION
WITHHELD
7/25/2008
AC
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Email communications with Elan legal department and containing
attachments prepared at the direction of Elan legal department in
anticipation of litigation and/or for purposes of seeking/providing
legal advice re patent analysis.
1/15/2004
AC/WP
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1/15/2008
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5/8/2008
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4/20/2005
AC
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3/6/2006
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6/20/2005
AC/WP
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2/23/2006
AC/WP
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Email communications with Elan legal department and containing
attachments prepared by Elan legal department in anticipation of
Eric Yang, Draco Wu
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patent analysis.
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis
Email communications with Elan legal department and containing
attachments prepared by Elan legal department in anticipation of
litigation and/or for purposes of seeking/providing legal advice re
patent analysis.
Email communications reflecting communication with JH Liu (Elan
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seeking/providing legal advice re patent search.
Email communications with Elan legal department and containing
Draco Wu, WF Lu, Wayne Chang attachments prepared by Elan's outside counsel in anticipation of
(Elan Legal), Bill Tsai (Elan Legal)' litigation and/or for purposes of seeking/providing legal advice re
patent analysis.
Email communications with Elan legal department and/or counsel
IH Yeh, Rich Tan, Ian Chung,
in anticipation of litigation and/or for purposes of
Wayne Chang (Elan Legal)
seeking/providing legal advice re settlement negotiation.
Email communications with Elan legal department and containing
attachment prepared by Elan's outside counsel in anticipation of
Draco Wu, Godwin Chiu, IH Yeh
litigation and/or for purposes of seeking/providing legal advice re
patent litigation.
Email communications with Elan legal department and containing
attachment prepared by Elan legal department in anticipation of
IH Yeh, Godwin Chiu
litigation and/or for purposes of seeking/providing legal advice re
settlement negotiation.
Email communications with Elan legal department and containing
attachments prepared at the direction of Elan legal department
and/or counsel in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis.
Wayne Chang (Elan Legal)
Certain Electronic Devices with Multi-Touch Enabled Touchpads and Touchscreens
ITC Inv. No. 337-TA-714
DESCRIPTION
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis.
COPY RECIPIENT
16
Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)
Elan's Privilege Log 2010-10-25
NO.
165
AUTHOR
Kelvin Chien
166
Kelvin Chien
167
Wayne Chang (Elan Legal)
168
Wayne Chang (Elan Legal)
169
Wayne Chang (Elan Legal)
170
Wayne Chang (Elan Legal)
171
Wayne Chang (Elan Legal)
172
IH Yeh
173
Wayne Chang (Elan Legal)
174
Godwin Chiu
175
Godwin Chiu
RECIPIENT
Ian Chung
COPY RECIPIENT
DESCRIPTION
DATE
PRIVILEGE
ASSERTED
PORTION
WITHHELD
Godwin Chiu
Email communications reflecting communication with Eve Chang
(Elan Legal) and containing attachments prepared by Elan legal
department and/or counsel in anticipation of litigation and/or for
purposes of seeking/providing legal advice re patent applications.
4/21/2005
AC/WP
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6/1/2005
WP
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11/6/2006
AC
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8/16/2006
AC
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11/17/2006
AC
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1/10/2007
AC
Entire Document
1/10/2007
AC
Entire Document
11/18/2006
AC
Entire Document
8/25/2006
AC/WP
Entire Document
6/21/2006
AC
Entire Document
7/25/2006
AC
Entire Document
Email communications containing attachment prepared by Elan
legal department and/or counsel in anticipation of litigation and/or
Draco Wu
for purposes of seeking/providing legal advice re patent
application.
Email communications with Elan legal department and/or counsel
Daisuke Shudo, Ian Chung
Godwin Chiu, IH Yeh, Rich Tan in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis.
Email communications with Elan legal department and/or counsel
IH Yeh, Draco Wu, Ian Chung,
Godwin Chiu
in anticipation of litigation and/or for purposes of
Roven Lee
seeking/providing legal advice re patent analysis.
Email communications with Elan legal department and/or counsel
IH Yeh, Godwin Chiu, Daisuke Shudo, Ocean Chen
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent litigation.
Email communications with Elan legal department and/or counsel
Ian Chung, Draco Wu
Alex Lee, Jacky Wu, Ocean Chen in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis.
Email communications with Elan legal department and/or counsel
Ian Chung, Draco Wu
Alex Lee, Jacky Wu, Ocean Chen in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis.
Email communications with Elan legal department and/or counsel
Wayne Chang (Elan Legal), Godwin Chiu, Daisuke
in anticipation of litigation and/or for purposes of
Shudo, Godwin Chiu, Ocean Chen
seeking/providing legal advice re patent litigation.
Email communications with Elan legal department and containing
attachments prepared by Elan legal department in anticipation of
Rich Tan, Daisuke Shudo
Godwin Chiu, Ian Chung, IH Yeh
litigation and/or for purposes of seeking/providing legal advice re
patent litigation.
Email communications containing communications with Wayne
Chang (Elan Legal) and/or counsel in anticipation of litigation
Ian Chung
and/or for purposes of seeking/providing legal advice re patent
analysis and patent litigation.
Email communications containing communications with Wayne
Chang (Elan Legal) and/or counsel in anticipation of litigation
Stober Chen, Rich Tan, Ocean Chen, Daisuke Shudo
and/or for purposes of seeking/providing legal advice re patent
litigation.
Certain Electronic Devices with Multi-Touch Enabled Touchpads and Touchscreens
ITC Inv. No. 337-TA-714
17
Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)
Elan's Privilege Log 2010-10-25
NO.
176
AUTHOR
Godwin Chiu
RECIPIENT
Godwin Chiu
Ian Chung
178
Godwin Chiu
Ian Chung
179
Godwin Chiu
IH Yeh, Li-Ling Lai
180
Godwin Chiu
Wayne Chang (Elan Legal)
181
Godwin Chiu
Wayne Chang (Elan Legal)
182
Godwin Chiu
Wayne Chang (Elan Legal), Duke Shudo, Godwin
Chiu
183
Wayne Chang (Elan Legal)
Wayne Chang (Elan Legal)
Godwin Chiu
185
Wayne Chang (Elan Legal)
Daisuke Shudo
186
Wayne Chang (Elan Legal)
Daisuke Shudo
Certain Electronic Devices with Multi-Touch Enabled Touchpads and Touchscreens
ITC Inv. No. 337-TA-714
PORTION
WITHHELD
4/11/2006
AC/WP
Entire Document
4/3/2006
WP
Entire Document
5/7/2006
AC/WP
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1/1/2007
AC
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8/17/2006
AC
Entire Document
4/13/2006
AC
Entire Document
5/22/2006
AC
Entire Document
12/11/2006
AC/WP
Entire Document
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis and litigation.
5/6/2006
AC
Entire Document
4/27/2006
AC
Entire Document
4/19/2006
AC
Entire Document
Email communications containing attachments prepared by Elan
legal department and/or counsel in anticipation of litigation and/or
for purposes of seeking/providing legal advice re trademark
applications.
Email communications containing communications with Wayne
Chang (Elan Legal) and containing attachments prepared by Elan
legal department and/or counsel in anticipation of litigation and/or
for purposes of seeking/providing legal advice re common interest
agreement.
Email communications with Elan legal department and/or counsel
Stober Chen, Wayne Chang (Elan
in anticipation of litigation and/or for purposes of
Legal)
seeking/providing legal advice re litigation.
Email communications with Elan legal department and/or counsel
IH Yeh, Draco Wu, Ian Chung,
in anticipation of litigation and/or for purposes of
Roven Lee
seeking/providing legal advice re patent litigation.
Email communications with Elan legal department and/or counsel
IH Yeh, Daisuke Shudo, Elsa Tsai
in anticipation of litigation and/or for purposes of
(Elan Legal), Ian Chung
seeking/providing legal advice re settlement negotiation.
Email communications with Elan legal department and/or counsel
IH Yeh
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent development strategy.
Draco Wu
184
PRIVILEGE
ASSERTED
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Email communications containing communications with Wayne
Chang (Elan Legal) and containing attachments prepared by
Elan's outside counsel in anticipation of litigation and/or for
purposes of seeking/providing legal advice re patent analysis.
Ian Chung
177
DATE
Email communications with Elan legal department and containing
attachment prepared by Elan's outside counsel in anticipation of
litigation and/or for purposes of seeking/providing legal advice re
patent analysis and litigation.
COPY RECIPIENT
IH Yeh, Daisuke Shudo
Email communications with Elan legal department and/or counsel
Ian Chung, Godwin Chiu, IH Yeh,
in anticipation of litigation and/or for purposes of
Rich Tan
seeking/providing legal advice re patent license.
Email communications with Elan legal department and/or counsel
Ian Chung, Godwin Chiu, IH Yeh,
in anticipation of litigation and/or for purposes of
Rich Tan
seeking/providing legal advice re patent license.
18
Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)
Elan's Privilege Log 2010-10-25
NO.
AUTHOR
187
Wayne Chang (Elan Legal)
188
Roven Lee
189
Violet Yeh
190
JH Liu (Elan Legal)
191
WF Lu
192
WF Lu
193
Charlie Huang
194
JH Liu (Elan Legal)
RECIPIENT
COPY RECIPIENT
DESCRIPTION
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent strategy and license.
Email communications with Elan legal department and containing
attachment prepared at the direction of Elan legal department in
Wayne Chang (Elan Legal), Ian Chung, Godwin Chiu
anticipation of litigation and/or for purposes of seeking/providing
legal advice re patent information.
Email communications with Elan legal department and containing
attachments prepared by Elan legal department and/or counsel in
Wayne Chang (Elan Legal)
Godwin Chiu
anticipation of litigation and/or for purposes of seeking/providing
legal advice regarding litigation
Email communications with Elan legal department and/or counsel
Wayne Chang (Elan Legal), IH Yeh, WF Lu
Godwin Chiu, Ian Chung, Rich Tan in anticipation of litigation and/or for purposes of
seeking/providing legal advice, regarding patent application.
Email communications with Elan legal department and/or counsel
WF Lu, Godwin Chiu, Wayne Chang (Elan Legal)
IH Yeh
in anticipation of litigation and/or for purposes of
seeking/providing legal advice, regarding patent analysis.
Email communications with Elan legal department and containing
attachments prepared by Elan legal department and/or counsel in
Goodwin Chiu, Wayne Chang (Elan Legal)
IH Yeh
anticipation of litigation and/or for purposes of seeking/providing
legal advice, regarding patent analysis.
Email communications with Elan legal department and/or counsel
Godwin Chiu, IH Yeh, Wayne Chang (Elan Legal),
Eliot Lin, Ian Chung, Eric Chung,
in anticipation of litigation and/or for purposes of
Roven Lee
Maco Tang, Charles Pai
seeking/providing legal advice, regarding patent analysis.
Duke Shudo, Godwin Chiu
IH Yeh
DATE
PRIVILEGE
ASSERTED
PORTION
WITHHELD
5/21/2006
AC
Entire Document
4/14/2006
AC/WP
Entire Document
5/29/2008
AC/WP
Entire Document
5/28/2008
AC
Entire Document
5/13/2008
AC
Entire Document
5/13/2008
AC/WP
Entire Document
4/27/2008
AC
Entire Document
Bill Tsai (Elan Legal)
IH Yeh, WF Lu, Wayne Chang
(Elan Legal), Godwin Chiu, Eve
Chang (Elan Legal)
Email communications with Elan legal department and containing
attachments prepared by Elan legal department and/or counsel in
anticipation of litigation and/or for purposes of seeking/providing
legal advice, regarding information on touch pad information.
4/11/2008
AC/WP
Entire Document
Email communications with Elan legal department and containing
attachments prepared by Elan legal department and/or counsel in
anticipation of litigation and/or for purposes of seeking/providing
legal advice re patent information.
4/2/2009
AC/WP
Entire Document
Email communications with Elan legal department and containing
attachments prepared by Elan legal department and/or counsel in
anticipation of litigation and/or for purposes of seeking/providing
legal advice re patent information.
1/7/2009
AC/WP
Entire Document
Email communication containing attachment prepared by Elan
IH Yeh, Chile Wang, Joseph
legal department and/or counsel in anticipation of litigation and/or
Wang, Mite Liang, Brad Rendell
for purposes of seeking/providing legal advice re patent analysis.
12/9/2008
WP
Portion Withheld
195
Nick Lin (Elan Legal)
IH Yeh, Wayne Chang
Kuo-Lung Yen, WF Lu, Godwin
Chiu, Charles Pai, Jimmy Wang,
Rove Lee, Jesse Lin, Vincent Tao,
CC Huang, Rong-Shou Huang
196
Wayne Chang (Elan Legal)
IH Yeh
Nick Lin (Elan Legal), Bill Tsai
(Elan Legal), Jason Oun, KuoLung Yen, Godwin Chiu
197
Ian Chung
Ian Chung, Jesse Huang, Godwin Chiu
Certain Electronic Devices with Multi-Touch Enabled Touchpads and Touchscreens
ITC Inv. No. 337-TA-714
19
Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)
Elan's Privilege Log 2010-10-25
DATE
PRIVILEGE
ASSERTED
PORTION
WITHHELD
8/27/2008
AC
Entire Document
8/4/2008
WP/Common
Interest
Portion Withheld
7/31/2008
AC
Entire Document
7/30/2008
AC
Entire Document
7/20/2008
AC
Entire Document
7/3/2008
AC
Entire Document
Annie Jeong
Email communications containing information prepared by Elan
Peggy Lin, Roven Lee, Dongjuns;
legal department and/or counsel in anticipation of litigation and/or
Michael Na, Smith Han, Annie
for purposes of seeking/providing legal advice, regarding litigation
Jeong
against Synaptics.
6/12/2008
WP
Entire Document
Wayne Chang (Elan Legal)
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
Godwin Chiu, Dai-Min Liu, WF Lu
seeking/providing legal advice, regarding litigation against
Synaptics.
5/30/2008
AC
Entire Document
5/28/2008
AC
Entire Document
5/28/2008
AC/WP
Entire Document
NO.
AUTHOR
RECIPIENT
198
IH Yeh
WF Lu, Venny Lin, Charles Pai, Godwin Chiu, Steven
Tsai, Ian Chung, Kuo-Lung Yen, Wayne Chang (Elan
Legal)
199
Ian Chung
200
IH Yeh
201
IH Yeh
202
IH Yeh
203
IH Yeh
204
Godwin Chiu
205
IH Yeh
206
Wayne Chang (Elan Legal)
207
Wayne Chang (Elan Legal)
COPY RECIPIENT
DESCRIPTION
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re settlement negotiation.
Email communication containing attachment prepared by Elan
legal department for third parties having a common legal interest
Charles Pai, Godwin Chiu, Eliot
Tom Tsai, Yuka Yeh
with Elan, containing communications with counsel regarding
Lin, CL Fu, Ian Chung
patent analysis in anticipation of litigation and/or for purposes of
seeking/providing legal advice.
Email communications with Elan legal department and/or counsel
IH Yeh, Wayne Chang (Elan Legal), Kuo-Lung Yen,
in anticipation of litigation and/or for purposes of
Ian Chung, Godwin Chiu, WF Lu
seeking/providing legal advice, regarding litigation involving
Synaptics.
Email communications with Elan legal department in anticipation
Wayne Chang (Elan Legal), Kuo-Lung Yen, Ian
of litigation and/or for purposes of seeking/providing legal advice,
Chung, Godwin Chiu, WF Lu
regarding litigation strategy.
Email communications with Elan legal department and/or counsel
Kuo-Lung Yen, Ian Chung, WF Lu, in anticipation of litigation and/or for purposes of
Wayne Chang (Elan Legal)
Godwin Chiu, Charles Pai
seeking/providing legal advice; regarding litigation/potential
litigation against Apple.
Wayne Chang (Elan Legal), Dai-Min Liu
Email communications with Elan legal department in anticipation
of litigation and/or for purposes of seeking/providing legal advice
regarding patented technology.
WF Lu, Godwin Chiu
Email communications Elan legal department and/or counsel in
IH Yeh, WF Lu, Bill Tsai (Elan Legal), JH Liu (Elan
Godwin Chiu, Ian Chung, Rich Tan anticipation of litigation and/or for purposes of seeking/providing
Legal)
legal advice; email communications containing patent analysis.
Email communications with Elan legal department and containing
attachments prepared by Elan legal department and/or counsel in
anticipation of litigation and/or for purposes of seeking/providing
legal advice, regarding certain court or administrative order.
WF Lu, IH Yeh, Dennis Liu, Godwin Chiu, Alfie Tsai,
Eve Chang (Elan Legal), JH Liu (Elan Legal)
Certain Electronic Devices with Multi-Touch Enabled Touchpads and Touchscreens
ITC Inv. No. 337-TA-714
20
Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)
Elan's Privilege Log 2010-10-25
NO.
AUTHOR
RECIPIENT
COPY RECIPIENT
208
Wayne Chang (Elan Legal)
IH Yeh, WF Lu, JH Liu (Elan Legal)
Godwin Chiu, Ian Chung
209
Wayne Chang (Elan Legal)
IH Yeh, WF Lu
Godwin Chiu, Ian Chung
Wayne Chang (Elan Legal)
WF Lu, IH Yeh, Dennis Liu, Godwin Chiu, Alfie Tsai,
Eve Chang (Elan Legal), JH Liu (Elan Legal)
210
211
IH Yeh
Godwin Chiu, WF Lu, Wayne Chang (Elan Legal)
212
Roven Lee
Godwin Chiu, IH Yeh, Wayne Chang (Elan Legal),
Charlie Huang
213
Godwin Chiu
IH Yeh, Wayne Chang (Elan Legal), Roven Lee,
Charlie Huang
214
Godwin Chiu
IH Yeh, Ian Chuang, WF Lu, Godwin Chiu
215
Godwin Chiu
IH Yeh, Bill Tsai (Elan Legal)
216
Godwin Chiu
Smith Han
217
Wayne Chang (Elan Legal)
IH Yeh
218
JH Liu (Elan Legal)
Eric Yang
Certain Electronic Devices with Multi-Touch Enabled Touchpads and Touchscreens
ITC Inv. No. 337-TA-714
DESCRIPTION
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice, regarding patent application.
Email communications with Elan legal department and containing
attachments prepared by Elan's outside counsel in anticipation of
litigation and/or for purposes of seeking/providing legal advice re
patent analysis.
Email communications with Elan legal department and containing
attachments prepared by Elan legal department and/or counsel in
anticipation of litigation and/or for purposes of seeking/providing
legal advice, regarding certain court/administrative order.
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice, regarding litigation against
Synaptics.
Email communications with Elan legal department and/or counsel
Eliot Lin, Ian Chung, Eric Jhuang,
in anticipation of litigation and/or for purposes of
Maco Tang, Charles Pai
seeking/providing legal advice re patent analysis.
Email communications with Elan legal department and/or counsel
Eliot Lin, Ian Chung, Eric Jhuang,
in anticipation of litigation and/or for purposes of
Maco Tang, Charles Pai
seeking/providing legal advice re patent analysis.
Email communications with Elan legal department and containing
Wayne Chang (Elan Legal); Bill attachment prepared by Elan legal department in anticipation of
Tsai (Elan Legal)
litigation and/or for purposes of seeking/providing legal advice;
containing patent analysis.
WF Lu, Ian Chung, Roven Lee,
Wayne Chang (Elan Legal)
Email communications with Elan legal department and containing
attachments prepared by Elan legal department and/or counsel in
anticipation of litigation and/or for purposes of seeking/providing
legal advice, regarding Elan patent analysis.
Email communications with Elan legal department and containing
attachment prepared by Elan legal department in anticipation of
litigation and/or for purposes of seeking/providing legal advice,
regarding UI patent.
Email communications with Elan legal department and containing
attachments prepared by Elan legal department and/or counsel in
Godwin Chiu, Dai-Min Liu, WF Lu
anticipation of litigation and/or for purposes of seeking/providing
legal advice, regarding patent litigation.
Wayne Chang (Elan Legal); Bill
Tsai (Elan Legal), Annie Jeong,
Michael Na
Email communications with Elan legal department and containing
Draco Wu, WF Lu, Wayne Chang attachment prepared by Elan's outside counsel in anticipation of
(Elan Legal), Bill Tsai (Elan Legal) litigation and/or for purposes of seeking/providing legal advice re
patent analysis and patent litigation.
21
DATE
PRIVILEGE
ASSERTED
PORTION
WITHHELD
5/28/2008
AC
Entire Document
5/28/2008
AC/WP
Entire Document
5/27/2008
AC/WP
Entire Document
5/23/2008
AC
Entire Document
4/27/2008
AC
Entire Document
4/27/2008
AC
Entire Document
4/17/2008
AC/WP
Entire Document
4/16/2008
AC/WP
Entire Document
4/15/2008
AC/WP
Entire Document
6/2/2008
AC/WP
Entire Document
6/9/2008
AC/WP
Entire Document
Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)
Elan's Privilege Log 2010-10-25
NO.
AUTHOR
RECIPIENT
219
JH Liu (Elan Legal)
Phoenix Lin, WF Lu, Eric Yang, Alfie Tsai, Wayne
Chang (Elan Legal), Bill Tsai (Elan Legal), IH Yeh,
Rich Tan
220
JH Liu (Elan Legal)
Draco Wu
221
JH Liu (Elan Legal)
WF Lu
222
Alfie Tsai
Wayne Chang (Elan Legal), Phoenix Lin
223
IH Yeh
Chin-Chih Wu
224
Wayne Chang (Elan Legal)
IH Yeh, WF Lu
225
Wayne Chang (Elan Legal)
IH Yeh, WF Lu
226
Phoenix Lin
Wayne Chang (Elan Legal)
227
Wayne Chang (Elan Legal)
IH Yeh, WF Lu
228
WF Lu
Wayne Chang (Elan Legal), JH Liu (Elan Legal)
229
Wayne Chang (Elan Legal)
Jason Liu
230 Alston & Bird (Outside Counsel)
COPY RECIPIENT
Email communications with Elan legal department and containing
attachment prepared by Elan legal department in anticipation of
litigation and/or for purposes of seeking/providing legal advice re
patent analysis.
Email communications with Elan legal department and containing
attachment prepared by Elan's outside counsel in anticipation of
litigation and/or for purposes of seeking/providing legal advice re
patent analysis.
Email communications with Elan legal department and containing
IH Yeh, Alfie Tsai, Phoenix Lin,
attachment prepared by Elan legal department in anticipation of
Wayne Chang (Elan Legal), Rich
litigation and/or for purposes of seeking/providing legal advice re
Tan, Jenny Chang
patent analysis.
Email communications with Elan legal department and containing
attachment prepared at the direction of Elan legal department in
anticipation of litigation and/or for purposes of seeking/providing
legal advice re patent analysis.
Email communication containing attachment prepared by Elan
legal department for third parties having a common legal interest
Alfie Tsai, WF Lu, Phoenix Lin with Elan, containing communications with counsel regarding
patent analysis in anticipation of litigation and/or for purposes of
seeking/providing legal advice.
Email communications with Elan legal department and/or counsel
Phoenix Lin, Elsa Tsai (Elan
in anticipation of litigation and/or for purposes of
Legal)
seeking/providing legal advice re patent license.
Email communications with Elan legal department and/or counsel
Phoenix Lin, Elsa Tsai (Elan
in anticipation of litigation and/or for purposes of
Legal)
seeking/providing legal advice re patent license.
Email communications with Elan legal department and/or counsel
WF Lu
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent litigation
Email communications with Elan legal department and/or counsel
Phoenix Lin
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent litigation.
Email communications with Elan legal department and/or counsel
IH Yeh, Alfie Tsai, Phoenix Lin in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent analysis.
Email communications with Elan legal department and/or counsel
in anticipation of litigation and/or for purposes of
seeking/providing legal advice re patent litigation.
Billing statements and invoices prepared by Elan's outside
counsel
Wayne Chang (Elan Legal)
Certain Electronic Devices with Multi-Touch Enabled Touchpads and Touchscreens
ITC Inv. No. 337-TA-714
DESCRIPTION
22
DATE
PRIVILEGE
ASSERTED
PORTION
WITHHELD
5/13/2008
AC/WP
Entire Document
9/18/2008
AC/WP
Entire Document
7/28/2008
AC/WP
Entire Document
4/22/2008
AC/WP
Entire Document
2/4/2009
WP/Common
Interest
Portion Withheld
12/3/2008
AC
Entire Document
12/3/2008
AC
Entire Document
10/3/2008
AC
Entire Document
6/7/2008
AC
Entire Document
7/14/2008
AC
Entire Document
8/28/2008
AC
Entire Document
AC/WP/
irrelevant
Portion Withheld
Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)
Elan's Privilege Log 2010-10-25
NO.
AUTHOR
RECIPIENT
231 Alston & Bird (Outside Counsel)
232 Alston & Bird (Outside Counsel)
233 Alston & Bird (Outside Counsel)
234 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
235 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
236 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
237 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
238 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
239 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
240 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
241 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
242 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
243 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
244 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
245 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
246 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
247 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
248 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
249 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
250 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
251 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
Certain Electronic Devices with Multi-Touch Enabled Touchpads and Touchscreens
ITC Inv. No. 337-TA-714
23
Portion Withheld
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Wayne Chang (Elan Legal)
AC/WP/
irrelevant
Billing statements and invoices prepared by Elan's outside
counsel
Wayne Chang (Elan Legal)
PORTION
WITHHELD
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Wayne Chang (Elan Legal)
PRIVILEGE
ASSERTED
Billing statements and invoices prepared by Elan's outside
counsel
COPY RECIPIENT
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
DESCRIPTION
DATE
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)
Elan's Privilege Log 2010-10-25
NO.
AUTHOR
RECIPIENT
252 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
254 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
255 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
256 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
257 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
258 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
259 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
260 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
261 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
262 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
263 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
264 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
265 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
266 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
267 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
268 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
269 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
270 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
271 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
272 Alston & Bird (Outside Counsel)
Wayne Chang (Elan Legal)
Certain Electronic Devices with Multi-Touch Enabled Touchpads and Touchscreens
ITC Inv. No. 337-TA-714
DESCRIPTION
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Billing statements and invoices prepared by Elan's outside
counsel
Wayne Chang (Elan Legal)
253 Alston & Bird (Outside Counsel)
COPY RECIPIENT
24
DATE
PRIVILEGE
ASSERTED
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
AC/WP/
irrelevant
PORTION
WITHHELD
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Portion Withheld
Elan Microelectronics Corp. v. Apple Inc.
Case No. C-09-01531 RS (PVT)
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