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

Filing 11

Declaration of Jason Bartlett in Support of #10 MOTION to Expedite Discovery filed byApple Inc.. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8, #9 Exhibit 9, #10 Exhibit 10, #11 Exhibit 11, #12 Proposed Order Proposed Order)(Related document(s) #10 ) (Bartlett, Jason) (Filed on 4/19/2011)

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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]
JASON R. BARTLETT (CA SBN 214530)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: 415.268.7522
Attorneys for Plaintiff
APPLE INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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APPLE INC., a California corporation,

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Case No.

Plaintiff,

4:11-cv-01846-LB

[PROPOSED] ORDER GRANTING
PLAINTIFF’S MOTION TO
EXPEDITE DISCOVERY

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,

Date: May 3, 2011
Time: 9:00 a.m.
Place:
Judge:

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Defendants.
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Plaintiff Apple Inc. (“Apple”) has moved the Court for an order to expedite discovery

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regarding certain products soon to be released by Defendant Samsung Telecommunications

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America, LLC (“Samsung”).

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Having considered the arguments of the parties and the papers submitted, and finding

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good cause therefore, the Court hereby grants Apple’s Motion to Expedite Discovery, and orders

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Samsung to produce the following documents and things by May 17, 2011:

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1
[PROPOSED] ORDER GRANTING MOTION TO EXPEDITE DISCOVERY
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(1) a domestic production model1 of the Galaxy S2, along with its commercial packaging

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and initial release marketing materials;

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(2) a domestic production model of the Galaxy Tab 8.9, along with its commercial

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packaging and initial release marketing materials;

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(3) a domestic production model of the Galaxy Tab 10.1, along with its commercial

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packaging and initial release marketing materials;

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(4) a domestic production model of the Infuse 4G, along with its commercial packaging

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and initial release marketing materials;

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(5) a domestic production model of the 4G LTE (or “Droid Charge”), along with its

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commercial packaging and initial release marketing materials; and

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(6) documents relating to any copying of design elements of, or attempts to design around

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Apple’s intellectual property relating to, the iPhone 4, iPad, and iPad 2.

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In addition, by May 19, 2011, Samsung shall make available for deposition in the United

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States a 30(b)(6) corporate witness on the following topics:

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(a) The design of the shell and graphical user interface of the Galaxy S2, Galaxy Tab 8.9,

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Galaxy Tab 10.1, Infuse 4G, and 4G LTE;

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(b) Any copying of design elements from the iPhone 4, iPad, and iPad 2; and

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(c) Any attempts to design around the iPhone 4, iPad, and iPad 2.

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IT IS SO ORDERED.

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Dated: ___________________, 2011

By:
Honorable ________________

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“Domestic Production Model” means a final, commercial version of a product to be sold
in the United States.

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[PROPOSED] ORDER GRANTING MOTION TO EXPEDITE DISCOVERY
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