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 D

quinn emanuel

trial lawyers | los angeles

865 South Figueroa Street, 10th Floor, Los Angeles, California 90017-2543 | TEL: [phone] FAX: [phone]

December 30, 2011

Mia Mazza
Morrison & Foerster LLP
425 Market St.
San Francisco, CA 94105-2482
Re:

Apple v. Samsung Electronics, et al., No. 5:11-cv-01846-LHK (N.D. Cal.)

Dear Mia:
I write regarding the search terms applied to the electronic document and model databases for
items relating to the Brain Box flat panel display, Apple Cinema Display,
. As you are well aware, the Court
has ordered Apple to conduct a reasonable, good faith search for these items, and although we
appreciate Apple's explanation regarding its search process for these items, Apple’s search
process as described in your December 24, 2011 letter is deficient. Accordingly, per your
invitation, we would like to propose some additional search terms that should not be overly
burdensome to run, but that are very likely to result in additional relevant hits.
Brain Box flat panel display
In your December 24 letter, you stated that Apple has run the search term "Brain Box" through
the entire electronic document collection of the Industrial Design inventors, and that Apple has
also run the term "Brain Box," the names of the alleged designers of the Brain Box, and the year
1989 through its database of models.
Please also run the following terms through the electronic document and email collection: "flat
quinn emanuel urquhart & sullivan, llp
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Pennsylvania Avenue NW, Suite 825, Washington, District of Columbia 20004-2400 | TEL [phone] FAX [phone]
Old Bailey, London EC4M 7EG, United Kingdom | TEL [phone] FAX [phone]
TOKYO | NBF Hibiya Building, 25F, 1-1-7, Uchisaiwai-cho, Chiyoda-ku, Tokyo 100-0011, Japan | TEL [phone] FAX [phone]
MANNHEIM | Erzbergerstraße 5, 68165 Mannheim, Germany | TEL [phone] FAX [phone]
MOSCOW | Voentorg Building, 3rd Floor, 10 Vozdvizhenka Street, Moscow 125009, Russia | TEL [phone] FAX [phone]
LONDON | 16

panel" within 20 of ("1989" or "Sigmar" or "Wilnauer" or "Gavin" or "Ivester" or "Tony" or
"Anthony" or "Guido").
Apple Cinema Display
Your December 24 letter does not specify what searches have been or are being conducted to
locate materials related to the Apple Cinema Display. Please confirm that you have searched the
term "Apple Cinema Display" in the electronic document and email collection as well as in the
model database. Further, if you have not already done so, please also run the search terms
“ACD” and “cinema” on the electronic document and email collection as well as the model
database.

Please confirm in writing by January 2, 2012 that we have the correct understanding of your
search terms and process, and that you will apply Samsung's proposed terms and produce by
January 15, 2012 all additional items and documents that these proposed terms hit.

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Kind regards,
/s/
Diane C. Hutnyan

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