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

Filing 1087

REPLY (re #965 Administrative Motion to File Under Seal Samsung's Motion to Enforce April 12, 2012 Order ) Samsung's Reply Brief In Support Of Motion To Enforce April 12 Order filed bySamsung Electronics America, Inc.(a New York corporation), Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC(a Delaware limited liability company). (Attachments: #1 Declaration of Diane C. Hutnyan In Support of Motion to Enforce April 12 Order, #2 Exhibit A to Reply Declaration of Diane C. Hutnyan In Support of Motion to Enforce April 12 Order, #3 Exhibit B to Reply Declaration of Diane C. Hutnyan In Support of Motion to Enforce April 12 Order, #4 Exhibit C to Reply Declaration of Diane C. Hutnyan In Support of Motion to Enforce April 12 Order, #5 Exhibit D to Reply Declaration of Diane C. Hutnyan In Support of Motion to Enforce April 12 Order, #6 Exhibit E to Reply Declaration of Diane C. Hutnyan In Support of Motion to Enforce April 12 Order)(Maroulis, Victoria) (Filed on 6/12/2012)

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June 11, 2012

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415.268.6024
[e-mail]

By Email ([e-mail])
Diane C. Hutnyan
Quinn Emanuel
865 S. Figueroa Street, 10th Floor
Los Angeles, CA 90017
Re:

Apple v. Samsung, Case No. 11-cv-1846-LHK (PSG) (N.D. Cal.)

Dear Diane:
This letter is to provide you with an update regarding the court documents from other cases
that Apple has been unable to produce in unredacted form pursuant to the April 12, 2012
Order.
Apple v. HTC (D. Del.)
Apple has produced unredacted versions of all court documents with the exception of four
documents containing Google CBI. We are informed by counsel for Apple in the HTC
Delaware matter that Google has not provided consent for the production of unredacted
versions of these four documents. Redacted versions of the documents have been produced
at APLNDC-Y0000252836, APLNDC-Y0000252859, APLNDC-Y0000252954, and
APLNDC-Y0000252971.
Elan v. Apple (N.D. Cal.)
Apple has now produced unredacted versions of all court documents.
Elan v. Apple (ITC 714)
Apple has produced unredacted versions of all court documents from the Elan ITC matter
with the exception of the confidential documents that contain Elan CBI. We are informed by
counsel for Apple in the Elan ITC matter that Elan has refused to provide consent for the
production of unredacted versions of these documents. We are further informed that counsel
for Apple has given Elan until June 12 to object to or correct proposed redactions to those
documents. We expect that Apple will have produced redacted versions of the documents by
June 14.

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Diane C. Hutnyan
June 11, 2012
Page Two
Apple v. Motorola (N.D. Ill. and ITC 750)
Apple has produced unredacted versions of all court documents with the exception of
documents containing CBI of nine nonparties who have either not provided consent or
refused to consent. Nokia Siemens Networks has withheld consent. Thomas
Cronan/Taligent, Synaptics, Microsoft, New York University, Qualcomm, Texas Instruments
did not respond to two separate letters providing notice and requesting consent. We have
been informed that counsel for Apple in the Motorola matters did not have contact
information to request permission from Broadcom or BCN to release their CBI as those
materials were submitted by Motorola.
The Motorola documents that have not been produced in unredacted form fall into two
categories. Approximately 100 have been produced in redacted form, at APLNDCY0000384065 through APLNDC-Y0000394590. We are informed by counsel for Apple in
the Motorola matters that the third party whose CBI is involved in each document is plain
from the face of the document.
The remaining fifteen documents could not be produced in redacted form because they are
completely CBI:
Docket
Number
ITC-750
750-013

NDIL
216

224

229-2

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Document Title

Third Party Involved

Exhibit 15 to Complainant Apple Inc.'s
Opposition to Respondents'
Motion to Terminate Investigation with
Respect to U.S. Patent No. 5,379,430 (Cronan
Deposition Transcript)

Cronan/Taligent CBI

Declaration of George Kondylis filed by
Plaintiff Apple, Inc. re: 213 Motion for
Summary Judgment
Declaration of Jochen Vaihinger filed by
Plaintiff Apple, Inc. re: 213 Motion for
Summary Judgment
Exhibit 2 to Declaration of David M. Elihu
filed by Defendants Motorola Mobility, Inc.,
Motorola, Inc. re: 215 Motion to
Dismiss/Lack of Jurisdiction (Excerpts of
Thomas Cronin deposition transcript)

Broadcom CBI

Intel CBI

Cronan/Taligent CBI

Diane C. Hutnyan
June 11, 2012
Page Three
Docket
Number
450-1

450-3

458-2

462-8 to
462-14

462-15

Document Title

Third Party Involved

Exhibit 2 TO APPENDIX TO MOTOROLA'S
MEMORANDUM IN OPPOSITION TO
APPLES MOTION FOR SUMMARY
JUDGMENT OF U.S. PATENT NO.
5,311,516 (Declaration of George Kondylis)
Exhibit 4 TO APPENDIX TO MOTOROLA'S
MEMORANDUM IN OPPOSITION TO
APPLES MOTION FOR SUMMARY
JUDGMENT OF U.S. PATENT NO.
5,311,516 (Excerpts from Kondylis
deposition transcript)
Exhibit 2 from SEALED EXHIBITS TO
APPENDIX TO MOTOROLA MOBILITY,
INC. AND MOTOROLA SOLUTIONS, INC.'S
MOTION TO DISMISS PURSUANT TO FED.
R. CIV. P. 12(b)(1) (Excerpts from Cronan
deposition transcript)
Parts 1-7 of Exhibit 17 from SEALED
EXHIBITS TO APPENDIX TO
MOTOROLA'S MEMORANDUM IN
OPPOSITION TO APPLES MOTION FOR
SUMMARY JUDGMENT OF U.S. PATENT
NO. 6,175,559
Exhibit 18 from SEALED EXHIBITS TO
APPENDIX TO MOTOROLA'S
MEMORANDUM IN OPPOSITION TO
APPLES MOTION FOR SUMMARY
JUDGMENT OF U.S. PATENT NO.
6,175,559

Broadcom CBI

Sincerely,
/s/ Mia Mazza
Mia Mazza
cc:

S. Calvin Walden
Peter Kolovos

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Broadcom CBI

Cronan/Taligent CBI

Texas Instruments CBI

Boston Computing
Network CBI