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

Filing 1098

Declaration of Cyndi Wheeler in Support of #1061 Administrative Motion to File Under Seal Samsung's Reply In Support of Motion To Exclude Opinions of Certain of Apple's Experts, #1067 Administrative Motion to File Under Seal , #1060 Administrative Motion to File Under Seal , #1069 Administrative Motion to File Under Seal Exhibits to Trac Declaration in Support of Reply to Samsung's Motion for Summary Judgment, #1074 Administrative Motion to File Under Seal , #1063 Administrative Motion to File Under Seal Samsung's Reply in Support of Samsung's Motion for Summary Judgment filed byApple Inc.. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Proposed Order)(Related document(s) #1061 , #1067 , #1060 , #1069 , #1074 , #1063 ) (Jacobs, Michael) (Filed on 6/14/2012)

EXHIBIT C

quinn emanuel

trial lawyers | silicon valley

555 Twin Dolphin Drive, 5th Floor, Redwood Shores, California 94065-2139 | TEL: [phone] FAX: [phone]

December 10, 2011

Mia Mazza
Morrison & Foerster
425 Market Street
San Francisco, CA 94105-2482

Re:

S. Calvin Walden
WilmerHale
399 Park Ave
New York, NY 10022

Apple, Inc. v. Samsung Elecs. Co., Case No. 11-CV-1846 LHK

Dear Mia and Calvin:
In the Court's December 9, 2011 Order re Temporary Relief From In Person Meet and Confer
Requirement (Dkt. 472), the Court excused Apple from the "in-person" requirement, but Apple
still needs to conduct a lead counsel meet and confer. Mr. Verhoeven is available on December
11, 2011 at 2:00 pm, Pacific Time, to meet telephonically on the issues raised by Apple's motion,
as well as on the issues we've previously identified as ripe for lead-counsel meet-and-confer,
including:
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Documents from Apple’s action against Motorola in the ITC
Mac OS 10.0 and SuperClock source code
Return of Samsung’s memory cards and
n of Apple's copies of photographs
Documents, including model shop records and tangibles related to the 035
Mockup
Obtaining Apple's compliance with Judge Grewal's order of November 16, 2011
requiring complete searches for materials relating to the 035 Mockup
Supplemental response to Interrogatory 1

quinn emanuel urquhart & sullivan, llp
LOS ANGELES |

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02198.51855/4474632.3
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NEW YORK |

Mia Mazza
S. Calvin Walden
December 10, 2011
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Documents and prototypes related to the “Brain Box”
Documents and prototypes related to the Apple Cinema Display
Prior deposition testimony of Apple’s employees, testifying in their capacity as
Apple employees
Release of materials designated "Attorneys' Eyes Only" to Dr. Itay Sherman

Please let us know Mr. McElhinny's availability as soon as possible.
Kind regards,
/s/
Diane C. Hutnyan

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