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

Filing 1060

*** Declaration of Trevor Darrell in Support of Samsung's Reply and Exhibit D and E to Darrell Declaration FILED IN ERROR WITH CONFIDENTIAL INFORMATION. DOCUMENT LOCKED. *** Administrative Motion to File Under Seal filed by Samsung Electronics America, Inc.(a New York corporation), Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC(a Delaware limited liability company). (Attachments: #1 Proposed Order Granting Motion to File Documents Under Seal, #2 Samsung's Reply in Support of Motion to Strike Expert Testimony Based on Undislcosed Facts and Theories, #3 Declaration of Christopher E. Price in Support of Samsung's Reply, #4 Exhibit 1 to Price Declaration, #5 Exhibit 2 to Price Declaration, #6 Exhibit 3 to Price Declaration, #7 Exhibit 4 to Price Declaration, #8 Exhibit 5 to Price Declaration, #9 Exhibit 6 to Price Declaration, #10 Exhibit 7 to Price Declaration, #11 Exhibit 8 to Price Declaration, #12 Exhibit 9 to Price Declaration, #13 Exhibit 10 to Price Declaration, #14 Exhibit 11 to Price Declaration, #15 Exhibit 12 to Price Declaration, #16 Exhibit 13 to Price Declaration, #17 Exhibit 14 to Price Declaration, #18 Exhibit 15 to Price Declaration, #19 Exhibit 16 to Price Declaration, #20 Exhibit 17 to Price Declaration, #21 Exhibit 18 to Price Declaration, #22 Exhibit 19 to Price Declaration, #23 Exhibit 20 to Price Declaration, #24 Exhibit 21 to Price Declaration, #25 Exhibit 22 to Price Declaration, #26 Exhibit 23 to Price Declaration, #27 Exhibit 24 to Price Declaration, #28 Exhibit 25 to Price Declaration, #29 Exhibit 26 to Price Declaration, #30 Exhibit 27 to Price Declaration, #31 Exhibit 28 to Price Declaration, #32 Exhibit 29 to Price Declaration, #33 Exhibit 30 to Price Declaration, #34 Exhibit 31 to Price Declaration, #35 Declaration of Michael J. Wagner in Support of Samsung's Reply, #36 Exhibit A to Wagner Declaration, #37 Exhibit B to Wagner Declaration, #38 Exhibit C to Wagner Declaration, #39 Declaration of Trevor Darrell in Support of Samsung's Reply, #40 Exhibit A to Darrell Declaration, #41 Exhibit B to Darrell Declaration, #42 Exhibit C to Darrell Declaration, #43 Exhibit D to Darrell Declaration, #44 Exhibit E to Darrell Declaration)(Maroulis, Victoria) (Filed on 6/7/2012) Modified on 6/8/2012 (fff, COURT STAFF).

EXHIBIT 31

Ketan Patel
From:
Sent:
To:
Cc:
Subject:

Ketan Patel
Monday, June 04, 2012 7:26 PM
'Mazza, Mia'
'AppleMoFo'; Samsung v. Apple; '[e-mail]'
RE: Apple v. Samsung: Samsung's Request for Inspection of Samsung Products

Hi Mia,
During his deposition, Dr. Balakrishnan testified that he examined devices with blue glow functionality at Apple’s
counsel’s office. (Balakrishnan 4/20/12 Dep. Tr. at 60:15Ͳ61:8, 62:12Ͳ20, 62:24Ͳ63:6, 70:7Ͳ10, 71:13Ͳ15, and 76:5Ͳ8).
Please make sure to provide these devices at tomorrow’s inspection.
Sincerely,
Ketan
From: Mazza, Mia [mailto:[e-mail]]
Sent: Monday, June 04, 2012 11:50 AM
To: Ketan Patel
Cc: AppleMoFo; Samsung v. Apple; [e-mail]
Subject: RE: Apple v. Samsung: Samsung's Request for Inspection of Samsung Products
The products will be available starting at 10 a.m. Tuesday. Please have Aileen ask for Ed Sittler. Will there be anyone
else?

From: Ketan Patel [mailto:[e-mail]]
Sent: Sunday, June 03, 2012 4:01 PM
To: Mazza, Mia
Cc: AppleMoFo; Samsung v. Apple; '[e-mail]'
Subject: RE: Apple v. Samsung: Samsung's Request for Inspection of Samsung Products

Hi Mia,
We would like to further inspect the ’381 products this Tuesday (June 5th) at 9 am? Can you please confirm that the
products will be available at that time for Aileen Kim to inspect?
Thanks,
Ketan
From: Mazza, Mia [mailto:[e-mail]]
Sent: Thursday, May 31, 2012 4:23 AM
To: Ketan Patel
Cc: AppleMoFo; Samsung v. Apple; [e-mail]
Subject: RE: Apple v. Samsung: Samsung's Request for Inspection of Samsung Products
We can make the products available at 10 a.m. this Friday, yes ask for Ed Sittler.

1

From: Ketan Patel [mailto:[e-mail]]
Sent: Wednesday, May 30, 2012 3:44 PM
To: Mazza, Mia
Cc: AppleMoFo; Samsung v. Apple; [e-mail]
Subject: RE: Apple v. Samsung: Samsung's Request for Inspection of Samsung Products

Hi Mia,
We would like to further inspect the ‘381 products this Friday (June 1st) at 9 am. Can you please confirm that the
products will be available at that time? If so, should we ask for Ed Sittler?
Thanks.
Ketan
From: Mazza, Mia [mailto:[e-mail]]
Sent: Monday, May 28, 2012 8:28 PM
To: Ketan Patel
Cc: AppleMoFo; Samsung v. Apple; [e-mail]
Subject: Re: Apple v. Samsung: Samsung's Request for Inspection of Samsung Products

Ed Sittler.
Mia Mazza
Morrison & Foerster LLP
425 Market Street
San Francisco, CA 94110
(415) 268Ͳ6024 (office)
(415) 216Ͳ5835 (mobile)
(415) 268Ͳ7522 (facsimile)
[e-mail]

From: Ketan Patel [mailto:[e-mail]]
Sent: Monday, May 28, 2012 05:27 PM
To: Mazza, Mia
Cc: AppleMoFo; Samsung v. Apple <[e-mail]>;
'[e-mail]' <[e-mail]>
Subject: RE: Apple v. Samsung: Samsung's Request for Inspection of Samsung Products

Tuesday at 1 pm will be fine. For whom should we ask?
Ketan
From: Mazza, Mia [mailto:[e-mail]]
Sent: Friday, May 25, 2012 11:09 PM
To: Ketan Patel
Cc: AppleMoFo; Samsung v. Apple; [e-mail]
Subject: Re: Apple v. Samsung: Samsung's Request for Inspection of Samsung Products

On Tuesday we can't do the inspection until 1pm or later.
Mia Mazza
2

Morrison & Foerster LLP
425 Market Street
San Francisco, CA 94110
(415) 268Ͳ6024 (office)
(415) 216Ͳ5835 (mobile)
(415) 268Ͳ7522 (facsimile)
[e-mail]

From: Ketan Patel [mailto:[e-mail]]
Sent: Friday, May 25, 2012 04:08 PM
To: Mazza, Mia
Cc: AppleMoFo; Samsung v. Apple <[e-mail]>; WH Apple Samsung NDCal Service
<[e-mail]>
Subject: RE: Apple v. Samsung: Samsung's Request for Inspection of Samsung Products

Thanks Mia.
We would like to inspect these devices on Tuesday (May 29th) at 9 AM. Whom should we ask for?
Ketan Patel | Quinn Emanuel Urquhart & Sullivan, LLP
Office: (212) 849Ͳ7467 | EͲmail: [e-mail]
From: Mazza, Mia [mailto:[e-mail]]
Sent: Thursday, May 24, 2012 9:42 PM
To: Ketan Patel
Cc: AppleMoFo; Samsung v. Apple; WH Apple Samsung NDCal Service
Subject: RE: Apple v. Samsung: Samsung's Request for Inspection of Samsung Products
MoFo's San Francisco offices, 425 Market Street.

From: Ketan Patel [mailto:[e-mail]]
Sent: Thursday, May 24, 2012 9:17 AM
To: Mazza, Mia
Cc: AppleMoFo; Samsung v. Apple; 'WH Apple Samsung NDCal Service'
Subject: RE: Apple v. Samsung: Samsung's Request for Inspection of Samsung Products

Dear Mia,
Please let us know where Apple is offering to make the devices available for inspection.
Sincerely,
Ketan Patel
Quinn Emanuel Urquhart & Sullivan, LLP
51 Madison Avenue, 22nd Floor
New York, NY 10010
212-849-7467 Direct
212.849.7100 FAX
[e-mail]

From: Mazza, Mia [mailto:[e-mail]]
Sent: Wednesday, May 23, 2012 8:54 PM
To: Ketan Patel
3

Cc: AppleMoFo; Samsung v. Apple; WH Apple Samsung NDCal Service
Subject: RE: Apple v. Samsung: Samsung's Request for Inspection of Samsung Products
Hi Ketan,
Attached please find further correspondence regarding Samsung's request for inspection of certain Samsung products.
Regards,

Mia Mazza
Morrison & Foerster LLP
San Francisco
[phone] office
[phone] mobile
[phone] fax

From: Pernick, Marc J.
Sent: Thursday, May 10, 2012 3:17 PM
To: 'Ketan Patel'; Mazza, Mia
Cc: AppleMoFo; Samsung v. Apple; 'WH Apple Samsung NDCal Service'
Subject: RE: Apple v. Samsung: Samsung's Request for Inspection of Samsung Products

Hi Ketan:
Please see the attached letter from Mia Mazza regarding Samsung's request for inspection of the
Samsung products discussed in Dr. Balakrishnan's opening expert report.
Regards,
Marc Pernick
From: Ketan Patel [mailto:[e-mail]]
Sent: Sunday, May 06, 2012 8:35 PM
To: Mazza, Mia
Cc: AppleMoFo; Samsung v. Apple; 'WH Apple Samsung NDCal Service'
Subject: RE: Apple v. Samsung: Samsung's Request for Inspection of Samsung Products

Hi Mia,
Please find attached correspondence regarding the products discussed in Dr. Balakrishnan’s opening expert report on
infringement for the ‘381 patent.
Regards,
Ketan Patel
Associate,

Quinn Emanuel Urquhart & Sullivan, LLP
51 Madison Avenue, 22nd Floor
New York, NY 10010
212-849-7467 Direct
212.849.7000 Main Office Number
212.849.7100 FAX
4

[e-mail]
www.quinnemanuel.com
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From: Mazza, Mia [mailto:[e-mail]]
Sent: Wednesday, May 02, 2012 9:49 PM
To: Ketan Patel
Cc: AppleMoFo; Samsung v. Apple; WH Apple Samsung NDCal Service
Subject: Apple v. Samsung: Samsung's Request for Inspection of Samsung Products

<<2012-05-02 Ltr Mazza to Patel re Balakrishnan Chart.pdf>>

Hi Ketan,
Attached please find correspondence responding to Samsung's request for inspection of the Samsung products
discussed in Dr. Balakrishnan's opening expert report.
Regards,
Mia Mazza
Morrison & Foerster LLP
San Francisco
[phone] office
[phone] mobile
[phone] fax

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