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

Filing 1086

Declaration of MIA MAZZA in Support of #1085 MOTION to Strike #1040 Opposition filed by Apple Inc.. (Attachments: #1 Exhibit A, #2 Exhibit B)(Related document(s) #1085 ) (Bartlett, Jason) (Filed on 6/12/2012) Modified text on 6/13/2012 (dhm, COURT STAFF).

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HAROLD J. MCELHINNY (CA SBN 66781)
[e-mail]
MICHAEL A. JACOBS (CA SBN 111664)
[e-mail]
JENNIFER LEE TAYLOR (CA SBN 161368)
[e-mail]
ALISON M. TUCHER (CA SBN 171363)
[e-mail]
RICHARD S.J. HUNG (CA SBN 197425)
[e-mail]
JASON R. BARTLETT (CA SBN 214530)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: [phone]

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WILLIAM F. LEE
[e-mail]
WILMER CUTLER PICKERING
HALE AND DORR LLP
60 State Street
Boston, MA 02109
Telephone: [phone]
Facsimile: [phone]
MARK D. SELWYN (SBN 244180)
[e-mail]
WILMER CUTLER PICKERING
HALE AND DORR LLP
950 Page Mill Road
Palo Alto, California 94304
Telephone: [phone]
Facsimile: [phone]

Attorneys for Plaintiff and
Counterclaim-Defendant APPLE INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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APPLE INC., a California corporation,
Plaintiff,

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v.
SAMSUNG ELECTRONICS CO., LTD., a
Korean business entity; SAMSUNG
ELECTRONICS AMERICA, INC., a New York
corporation; SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC, a
Delaware limited liability company,

Case No.

11-cv-01846-LHK (PSG)

DECLARATION OF MIA MAZZA
IN SUPPORT OF APPLE’S
MOTION TO STRIKE
SAMSUNG’S OPPOSITION TO
NOTICE OF MOTION FOR
CLARIFICATION OF APRIL 12,
2012 ORDER

Defendants.

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MAZZA DECL. ISO APPLE’S MOT. TO STRIKE OPP. TO NOT. OF MOT. FOR CLARIFICATION OF APRIL 12, 2012 ORDER
CASE NO. 11-CV-01846-LHK (PSG)

sf-3157993

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I, MIA MAZZA, declare as follows:

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1.

I am a partner in the law firm of Morrison & Foerster LLP, counsel for Apple Inc.

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(“Apple”). I am licensed to practice law in the State of California and admitted to practice before

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this Court. I have personal knowledge of the matters stated herein or understand them to be true

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from outside counsel for Apple in other matters identified below. I make this declaration in

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support of Apple’s Motion to Strike Samsung’s Opposition to Apple’s Notice of Motion for

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Clarification of April 12 Order

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2.

Attached hereto as Exhibit A is a true and correct copy of a letter I sent to counsel

for Samsung dated June 8, 2012.
3.

Attached hereto as Exhibit B is a true and correct copy of an email I received from

counsel for Samsung dated June 8, 2012.
4.

Apple has produced unredacted versions of all court documents from the Motorola

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matters pending in the Northern District of Illinois and the ITC (Inv. No. 337-TA-750) with the

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exception of documents containing Confidential Business Information of nine nonparties who

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have not responded to Apple’s multiple requests for consent or have affirmatively refused to

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consent. Apple has produced redacted versions of these remaining Motorola documents

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involving nine nonparties’ CBI, with the exception of fifteen documents that were withheld in

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their entirety because they could not meaningfully be redacted. On June 11, 2012, counsel for

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Apple sent counsel for Samsung a list of those fifteen documents, identifying the third party

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involved in each.

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5.

Apple has produced unredacted versions of all court documents from the HTC case

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pending in the District of Delaware, with the exception of four documents containing Google

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CBI, to which production Google has objected. Apple has produced redacted versions of those

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four documents.

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6.

After having given Elan notice and an opportunity to seek a protective order,

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Apple has now produced unredacted versions of all court documents from the Elan case litigated

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in the Northern District of California.

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MAZZA DECL. ISO APPLE’S MOT. TO STRIKE OPP. TO NOT. OF MOT. FOR CLARIFICATION OF APRIL 12, 2012 ORDER
CASE NO. 11-CV-01846-LHK (PSG)

sf-3157993

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7.

Outside counsel for Apple in the Elan ITC investigation prepared a proposed

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redacted set of confidential documents from that matter and provided it to counsel for Elan. Elan

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has requested more time to review the confidential documents before they may be provided to

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counsel for Apple or Samsung in this matter. Outside counsel for Apple in the Elan matter

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therefore has declined to provide the confidential documents for production to Samsung at this

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time.

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I declare under penalty of perjury that the foregoing is true and correct. Executed this
12th day of June, 2012 at San Francisco, California.

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/s/ Mia Mazza

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Mia Mazza

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MAZZA DECL. ISO APPLE’S MOT. TO STRIKE OPP. TO NOT. OF MOT. FOR CLARIFICATION OF APRIL 12, 2012 ORDER
CASE NO. 11-CV-01846-LHK (PSG)

sf-3157993

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ATTESTATION OF E-FILED SIGNATURE
I,. Jason R. Bartlett, am the ECF User whose ID and password are being used to file this

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Declaration. In compliance with General Order 45, X.B., I hereby attest that Mia Mazza has

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concurred in this filing.

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Dated: June 12, 2012

/s/ Jason R. Bartlett
Jason R. Bartlett

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MAZZA DECL. ISO APPLE’S MOT. TO STRIKE OPP. TO NOT. OF MOT. FOR CLARIFICATION OF APRIL 12, 2012 ORDER
CASE NO. 11-CV-01846-LHK (PSG)

sf-3157993

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