Apple Inc. v. Samsung Electronics Co. Ltd. et al
Filing
112
DECLARATION of AUSTIN TARANGO IN SUPPORT OF #111 SAMSUNG'S OPPOSITION TO APPLE'S MOTION FOR EXPEDITED TRIAL ON ITS CLAIMS AND FOR EARLY CASE MANAGEMENT CONFERENCE filed bySamsung Electronics America, Inc., Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC. (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)(Maroulis, Victoria) (Filed on 7/15/2011) Modified on 7/20/2011 counsel failed to link entry to document #111 (dhm, COURT STAFF).
EXHIBIT 1
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Samsung Vibrant from T-Mobile USA to Bring Robust Entertainment Experience on a Brilliant
Screen
International news
T-Mobile’s Latest Android™-Powered Device Offers Exclusive Entertainment Experience,
Including James Cameron’s Avatar In a Slim Smartphone Package
BELLEVUE, Wash. and DALLAS — June 28, 2010 — T-Mobile USA, Inc. and Samsung
Telecommunications America (Samsung Mobile), the No. 1 mobile phone provider in the U.S.1,
today announced the Samsung Vibrant™, a Samsung Galaxy S™ device available from T-Mobile.
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Through pre-installed applications and pre-loaded content, the Samsung Vibrant’s comprehensive
multimedia capabilities combine all your entertainment and communication needs into one device
— it’s a television, bookshelf, radio, movie library, gaming system, and of course, a smartphone. .
The Vibrant comes fully loaded with exclusive entertainment features including “James Cameron’s
Avatar” on an included 2GB external memory card and an exclusive collector’s edition of a popular
game. The Vibrant also brings the Amazon Kindle for Android™ application with access to more
than 600,000 books, MobiTV with live and on-demand TV, and much more.
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The Vibrant’s 4-inch Super AMOLED touch screen display gives customers a vivid, sharp color
HD-like viewing experience, whether consumers choose to play a game, watch a movie or read an
e-book while on the go. Featuring a slim and sleek design, the Vibrant is one of the most portable
and accessible mobile entertainment devices available to U.S. consumers. The speedy Samsung
1GHz Cortex A8 Hummingbird Application Processor and six-axis motion sensing which uses an
accelerometer and geo-magnetic sensors are optimized for media and gaming, which gives
consumers a seamless, immersive experience while reading, watching and playing. The Vibrant is
also the latest smartphone in T-Mobile’s lineup that can benefit from enhanced speeds in locations
with T-Mobile’s super-fast HSPA+ network.2
“By combining best-selling, award-winning content and amazing hardware that brings that content
to life, T-Mobile continues to deliver on its commitment to bring innovative mobile entertainment
experiences to consumers’ fingertips,” said Paul Cole, vice president, devices and accessories, TMobile USA. “We are proud to introduce the Samsung Vibrant as the latest addition to our growing
lineup of Android-powered devices.”
“The Samsung Vibrant contains all of the premium core features that the Galaxy S portfolio offers
to consumers, including an industry leading display and powerful processor. The Galaxy S devices
make the smartphone brilliant,” said Omar Khan, chief strategy officer for Samsung Mobile. “When
you combine the Vibrant’s incredible hardware with preloaded content like ”Avatar,” along with
thousands of applications available on the Android Market, the entertainment and customization
possibilities are endless.”
‘“James Cameron’s Avatar” is in many ways the most innovative film ever produced, and in
working with Samsung and T-Mobile we are now able to offer this eye-catching experience to
viewers in a new and dynamic environment on the Samsung Vibrant,’ said Peter Levinsohn,
president of new media and digital distribution for 20th Century FOX Film Company.
The multimedia experience that makes the Samsung Vibrant a great option for entertainment
enthusiasts includes the following:
- 20th Century Fox’s “James Cameron’s Avatar,” full-screen movie pre-loaded on the Samsung
Vibrant, takes consumers back to Pandora, the fictional world created by James Cameron, in the
highest-grossing film in history.
- Amazon Kindle for Android application provides direct access to more than 600,000 books,
including a vast majority of The New York Times Best Sellers and New Releases. Before
consumers purchase a book, they can read the first chapter for free. They also can read reviews
and recommendations from Amazon.com and its customers. With Kindle for Android, customers
can sync their reading with their other Kindle devices so they never lose their place or are without
their reading.
- MobiTV mobile phone application offers consumers access to live and on-demand TV available in
English and Spanish — including more than 35 channels of news, sports and entertainment.
Favorite channels such as Bravo, Disney Channel, ESPN, NBC and more are available for
Samsung Vibrant consumers to watch at home or away. Plus, when Vibrant consumers subscribe
to MobiTV, their first 30 days of service are free.3
- Slacker Radio mobile application comes pre-loaded on the Samsung Vibrant, allowing anyone to
listen to free personalized radio. Slacker offers more than 120 genre stations and the ability to
create your own. With millions of songs from thousands of artists, Slacker is the best way to
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- Gogo® Inflight Internet service offers a bonus to consumers who purchase the Samsung Vibrant:
up to a month of free in-flight Wi-Fi access on their device, with Internet access on more than
3,000 daily flights and growing every day in the continental U.S.4
- Samsung Media Hub, expected to be available in the near future,is a full library of video and
literary content powered by some of the biggest names in entertainment.
The Samsung Vibrant’s assets go beyond its impressive entertainment features. Running Android
2.1, the Samsung Vibrant offers a seven-paned home screen and access to Android Market™ to
personalize the device with 65,000 applications, including applications for social networking,
gaming, travel and more. Samsung’s Social Hub service helps consumers to easily keep in touch
with family and friends through integrated contacts, calendars, social networking sites and group
messaging, including the ability to “reply all” for up to 10 contacts. The Vibrant also supports six
languages: English, Spanish, French, Dutch, Italian and Korean.
The Vibrant delivers advanced phone features such as GPS functionality with access to turn-byturn navigation and Swype® text input for fast, accurate communication. It also features a 5megapixel camera with digital zoom and autofocus, and a video camera for recording crystal-clear,
high-definition (720p) videos and photos for playback on an HD television. With support for up to
32 GB of external memory, the Vibrant provides ample space for consumers’ entertainment
favorites. Consumers can customize their Vibrant with two battery cover options in dark blue and
lavender that will come packaged exclusively with the T-Mobile device.
Availability
The Samsung Vibrant and its exclusive pre-loaded entertainment content is expected to be
available to T-Mobile customers beginning July 21. Customers can visit http://galaxy-s.tmobile.com for more information.
In addition, it is expected that beginning on July 1, customers may pre-order the Samsung Vibrant
at any one of more than 4,000 RadioShack® stores. To pre-order, customers must purchase a $50
gift card, which will be applied toward the retail price of the device. Customers can schedule an
appointment to pick up and activate their devices at RadioShack stores with anticipated availability
starting July 21. Customers who pre-order at RadioShack will receive a $50 gift card by mail after
purchasing their phone with qualifying voice and data plan on a two-year contract. The ability to
pre-order is also expected to be available online at http://www.radioshack.com/vibrant beginning
July 1.
###
1 Based upon reported shipment data for Q1 2010, 2009, and 2008, Strategy Analytics’ U.S.
Market Share Handset Shipments Reports.
2 HSPA+ available in specific markets.
3 After the first 30 days, monthly subscription charges will apply.
4 Free month requires purchase of device by 12/31/10; expires earlier of 30 days from registration
or 1/30/11.
Note to Editors in the United States
For photos of the Samsung Vibrant from T-Mobile and other T-Mobile services and products,
please log onto http://www.TheNewsMarket.com/T-Mobile to preview and request photos.
Registration is free to the media.
About Samsung Telecommunications America
Samsung Telecommunications America, LLC, a Dallas-based subsidiary of Samsung Electronics
Co., Ltd., researches, develops and markets wireless handsets and telecommunications products
throughout North America. For more information, please visit www.samsung.com.
About Samsung Electronics Co., Ltd.
Samsung Electronics Co., Ltd. is a global leader in semiconductor, telecommunication, digital
media and digital convergence technologies with 2009 consolidated sales of (US)$116.8 billion.
Employing approximately 188,000 people in 185 offices across 65 countries, the company consists
of eight independently operated business units: Visual Display, Mobile Communications,
Telecommunication Systems, Digital Appliances, IT Solutions, Digital Imaging, Semiconductor and
LCD. Recognized as one of the fastest growing global brands, Samsung Electronics is a leading
producer of digital TVs, memory chips, mobile phones and TFT-LCDs. For more information,
please visit www.samsung.com.
About T-Mobile USA, Inc.
Based in Bellevue, Wash., T-Mobile USA, Inc. is the U.S. wireless operation of Deutsche Telekom
AG. By the end of the first quarter of 2010, approximately 150 million mobile customers were
served by the mobile communication segments of the Deutsche Telekom group — 33.7 million by
T-Mobile USA — all via a common technology platform based on GSM and UMTS, the world’s
most widely used digital wireless standards. T-Mobile USA’s innovative wireless products and
services help empower people to connect to those who matter most. Multiple independent
research studies continue to rank T-Mobile among the highest in numerous regions throughout the
U.S. in wireless customer care and call quality. For more information, please visit http://www.TMobile.com. T-Mobile is a federally registered trademark of Deutsche Telekom AG.
Forward-Looking Statements
This press release contains forward-looking statements that reflect the current views of Deutsche
Telekom management with respect to future events. The words “anticipate,” “believe,” “estimate,”
“expect,” “intend,” “may,” “plan,” “project” and “should” and similar expressions are intended to
identify forward-looking statements. Forward-looking statements are based on current plans,
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statements are subject to risks and uncertainties, most of which are difficult to predict and are
generally beyond Deutsche Telekom’s control, including, without limitation, those factors set forth
in “Forward-Looking Statements” and “Risk Factors” contained in Deutsche Telekom’s annual
report. If these or other risks and uncertainties materialize, or if the assumptions underlying any of
these statements prove incorrect, Deutsche Telekom’s actual results may be materially different
from those expressed or implied by such statements. Deutsche Telekom does not intend or
assume any obligation to update these forward-looking statements.
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