Apple Inc. v. Samsung Electronics Co. Ltd. et al

Filing 1013

Administrative Motion to File Under Seal Documents Under Seal Re Apples Opposition To Samsungs Motion For Summary Judgment filed by Apple Inc.. (Attachments: #1 Proposed Order, #2 Declaration Of Karl Kramer In Support Of Apples Opposition To Samsungs Motion For Summary Judgment, #3 Exhibit Kramer Decl. Ex. 1, #4 Exhibit Kramer Decl. Ex. 2, #5 Exhibit Kramer Decl. Ex. 3, #6 Exhibit Kramer Decl. Ex. 4, #7 Exhibit Kramer Decl. Ex. 5, #8 Exhibit Kramer Decl. Ex. 6, #9 Exhibit Kramer Decl. Ex. 7, #10 Exhibit Kramer Decl. Ex. 8, #11 Exhibit Kramer Decl. Ex. 9, #12 Exhibit Kramer Decl. Ex. 10, #13 Exhibit Kramer Decl. Ex. 11, #14 Declaration Of Michel Maharbiz, Ph.D. In Support Of Apples Opposition To Samsungs Motion For Summary Judgment, #15 Exhibit Maharbiz Decl. Ex. A, #16 Exhibit Maharbiz Decl. Ex. B, #17 Exhibit Maharbiz Decl. Ex. E, #18 Exhibit Maharbiz Decl. Ex. F)(Jacobs, Michael) (Filed on 6/1/2012)

Exhibit 4
(Submitted Under Seal)

SUBJECT TO PROTECTIVE ORDER
CONTAINS HIGHLY CONFIDENTIAL – ATTORNEY’S EYES ONLY INFORMATION
1 QUINN EMANUEL URQUHART & SULLIVAN, LLP
Charles K. Verhoeven (Cal. Bar No. 170151)
2 [e-mail]
50 California Street, 22nd Floor
3 San Francisco, California 94111
Telephone: [phone]
4 Facsimile: [phone]
5 Kevin P.B. Johnson (Cal. Bar No. 177129)
[e-mail]
6 Victoria F. Maroulis (Cal. Bar No. 202603)
[e-mail]
7 555 Twin Dolphin Drive 5th Floor
Redwood Shores, California 94065
8 Telephone: [phone]
Facsimile: [phone]
9
Michael T. Zeller (Cal. Bar No. 196417)
10 [e-mail]
865 S. Figueroa St., 10th Floor
11 Los Angeles, California 90017
Telephone: [phone]
12 Facsimile: [phone]
13 Attorneys for SAMSUNG ELECTRONICS
CO., LTD., SAMSUNG ELECTRONICS
14 AMERICA, INC. and SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

18 APPLE INC., a California corporation,
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CASE NO. 11-cv-01846-LHK

Plaintiff,
vs.

21 SAMSUNG ELECTRONICS CO., LTD., a
Korean business entity; SAMSUNG
22 ELECTRONICS AMERICA, INC., a New
York corporation; SAMSUNG
23 TELECOMMUNICATIONS AMERICA,
LLC, a Delaware limited liability company,
24
Defendants.
25

SAMSUNG’S SECOND SUPPLEMENTAL
OBJECTIONS AND RESPONSES TO
APPLE'S SIXTEENTH SET OF
INTERROGATORIES (NO. 81)
HIGHLY CONFIDENTIAL –
ATTORNEYS’ EYES ONLY
UNDER THE PROTECTIVE ORDER

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Case No. 11-cv-01846-LHK
SAMSUNG’S SECOND SUPPLEMENTAL OBJECTIONS AND RESPONSES TO
APPLE’S 16TH SET OF INTERROGATORIES (NO. 81)

SUBJECT TO PROTECTIVE ORDER
CONTAINS HIGHLY CONFIDENTIAL – ATTORNEY’S EYES ONLY INFORMATION
1 already in the possession of Apple, publicly available, or as readily available to Apple as it is to
2 Samsung.
3

24.

Samsung objects to each interrogatory to the extent that it seeks information before

4 Samsung is required to disclose such information in accordance with any applicable law, such as
5 the Northern District of California Patent Local Rules.
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25.

Samsung objects to the interrogatories on the grounds and to the extent that they

7 seek legal conclusions or call for expert testimony.

Samsung’s responses should not be

8 construed to provide legal conclusions.
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Subject to and without waiving the foregoing General Statement and General Objections,

10 Samsung responds as follows:
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INTERROGATORIES

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14 INTERROGATORY NO. 1:
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Explain in detail the operation of any monitoring circuitry, integrated circuit, chip,

16 controller, or module used to operate the touch screens (including the display and touch sensor
17 panels) and used to respond to touch events for each Product at Issue, with reference to and
18 identification of specific source code and microcode files and functions.
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20 SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 1:
21

In addition to the General Objections stated above, Samsung objects to this interrogatory

22 as vague and ambiguous. Samsung further objects to this interrogatory to the extent that it seeks
23 to elicit information subject to and protected by the attorney-client privilege, the attorney work24 product doctrine, the joint defense privilege, the common interest doctrine, and/or any other
25 applicable privilege or immunity. Samsung further objects to this interrogatory on the grounds
26 and to the extent that it seeks legal conclusions or calls for expert testimony. Samsung will
27 provide such contentions in accordance with the Court’s Minute Order and Case Management
28 order, dated August 25, 2011.
Case No. 11-cv-01846-LHK
-5SAMSUNG’S SECOND SUPPLEMENTAL OBJECTIONS AND RESPONSES TO
APPLE’S 16TH SET OF INTERROGATORIES (NO. 81)

SUBJECT TO PROTECTIVE ORDER
CONTAINS HIGHLY CONFIDENTIAL – ATTORNEY’S EYES ONLY INFORMATION
1

Subject to the foregoing general and specific objections, and following a reasonable

2 investigation, Samsung responds as follows:
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Case No. 11-cv-01846-LHK
-6SAMSUNG’S SECOND SUPPLEMENTAL OBJECTIONS AND RESPONSES TO
APPLE’S 16TH SET OF INTERROGATORIES (NO. 81)

SUBJECT TO PROTECTIVE ORDER
CONTAINS HIGHLY CONFIDENTIAL – ATTORNEY’S EYES ONLY INFORMATION
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15 SECOND SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 1:
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In addition to the General Objections stated above, Samsung objects to this interrogatory

17 as vague and ambiguous. Samsung further objects to this interrogatory to the extent that it seeks
18 to elicit information subject to and protected by the attorney-client privilege, the attorney work19 product doctrine, the joint defense privilege, the common interest doctrine, and/or any other
20 applicable privilege or immunity. Samsung further objects to this interrogatory on the grounds
21 and to the extent that it seeks legal conclusions or calls for expert testimony. Samsung will
22 provide such contentions in accordance with the Court’s Minute Order and Case Management
23 order, dated August 25, 2011.
24

Subject to the foregoing general and specific objections, and following a reasonable

25 investigation, Samsung responds as follows:
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Case No. 11-cv-01846-LHK
-7SAMSUNG’S SECOND SUPPLEMENTAL OBJECTIONS AND RESPONSES TO
APPLE’S 16TH SET OF INTERROGATORIES (NO. 81)

SUBJECT TO PROTECTIVE ORDER
CONTAINS HIGHLY CONFIDENTIAL – ATTORNEY’S EYES ONLY INFORMATION
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Samsung further responds that some of the information requested in this interrogatory is
outside Samsung’s possession, custody or control. Pursuant to Rule 33(d), Samsung further
Case No. 11-cv-01846-LHK
-8SAMSUNG’S SECOND SUPPLEMENTAL OBJECTIONS AND RESPONSES TO
APPLE’S 16TH SET OF INTERROGATORIES (NO. 81)

SUBJECT TO PROTECTIVE ORDER
CONTAINS HIGHLY CONFIDENTIAL – ATTORNEY’S EYES ONLY INFORMATION
1 responds by citing the following documents from which such information may be determined:
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13 DATED: March 22, 2012
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QUINN EMANUEL URQUHART &
SULLIVAN, LLP

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By Victoria F. Maroulis
Charles K. Verhoeven
Kevin P.B. Johnson
Victoria F. Maroulis
Michael T. Zeller
Attorneys for SAMSUNG ELECTRONICS CO.,
LTD., SAMSUNG ELECTRONICS AMERICA,
INC., and SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC

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Case No. 11-cv-01846-LHK
-9SAMSUNG’S SECOND SUPPLEMENTAL OBJECTIONS AND RESPONSES TO
APPLE’S 16TH SET OF INTERROGATORIES (NO. 81)