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

Filing 1014

Declaration in Support of #1000 Opposition/Response to Motion, Declaration of James Ward In Support of Samsung's Opposition to Apple's Motion to Strike filed bySamsung Electronics America, Inc.(a New York corporation), Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC(a Delaware limited liability company). (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit E, #4 Exhibit F, #5 Exhibit L, #6 Exhibit M, #7 Exhibit N, #8 Exhibit O, #9 Exhibit P, #10 Exhibit R, #11 Exhibit S, #12 Exhibit U, #13 Exhibit V, #14 Exhibit W, #15 Exhibit AA, #16 Exhibit BB, #17 Exhibit CC, #18 Exhibit EE)*** EXHIBIT EE FILED IN ERROR WITH CONFIDENTIAL INFORMATION. DOCUMENT LOCKED. DOCUMENT TO BE REFILED LATER. *** (Related document(s) #1000 ) (Maroulis, Victoria) (Filed on 6/1/2012) Modified on 8/13/2014 (fff, COURT STAFF).

EXHIBIT E

quinn emanuel

trial lawyers | new york

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October 20, 2011

VIA ELECTRONIC MAIL AND FEDERAL EXPRESS
Richard S. J. Hung
Morrison & Foerster LLP
425 Market Street
San Francisco, CA 94105-2482

Re:

Subpoena Response from Mitsubishi Electric Research Laboratories (“MERL”);
Apple Inc. v. Samsung Elecs. Co., et al., Case No. 11-CV-1846 LHK (N.D. Cal.)

Dear Mr. Hung:
We have received a hard drive purporting to contain documents responsive to the MERL
subpoena. An exact duplicate of that hard drive is enclosed with this letter.
MERL indicated that its production is made “under the protective order,” but did not so label the
hard drive itself or (from what we can tell) any of the documents therein.
We thus plan on meeting and conferring with MERL on the question of what, if any,
confidentiality designations they intended to make for any particular files. Until we can resolve
that issue, we plan on treating the information therein as “HIGHLY CONFIDNENTIAL –
ATTORNEYS’ EYES ONLY,” under the Interim Model Protective Order and request that you
abide by the same.

quinn emanuel urquhart & sullivan, llp
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Please do not hesitate to contact me with any questions. Thank you.
Very truly yours,

Aaron S. Kaufman
Enclosure (with FedEx copy only)
cc: [e-mail] (via email only) (w/o enclosure)

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