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

Filing 1121

*** EXHIBIT A FILED IN ERROR WITH CONFIDENTIAL INFORMATION. DOCUMENT LOCKED. *** MOTION for Leave to File Objection To Reply Evidence filed by Apple Inc.. (Attachments: #1 Exhibit A, #2 Declaration Of Jason R. Bartlett In Support Of Apples Administrative Motion For Leave To File Objection To Reply Evidence, #3 Proposed Order)(Jacobs, Michael) (Filed on 6/22/2012) Modified on 6/25/2012 (fff, COURT STAFF). Modified text on 6/27/2012 (dhm, COURT STAFF).

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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]
ALISON M. TUCHER (CA SBN 171363)
[e-mail]
RICHARD S.J. HUNG (CA SBN 197425)
[e-mail]
JASON R. BARTLETT (CA SBN 214530)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: [phone]

WILLIAM F. LEE
[e-mail]
WILMER CUTLER PICKERING
HALE AND DORR LLP
60 State Street
Boston, MA 02109
Telephone: [phone]
Facsimile: [phone]
MARK D. SELWYN (SBN 244180)
[e-mail]
WILMER CUTLER PICKERING
HALE AND DORR LLP
950 Page Mill Road
Palo Alto, California 94304
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff and
Counterclaim-Defendant APPLE INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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APPLE INC., a California corporation,

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Plaintiff,
v.

Case No. 11-cv-01846-LHK
APPLE’S ADMINISTRATIVE
MOTION FOR LEAVE TO FILE
OBJECTION TO REPLY EVIDENCE

SAMSUNG ELECTRONICS CO., LTD., a
Korean corporation; SAMSUNG ELECTRONICS
AMERICA, INC., a New York corporation; and
SAMSUNG TELECOMMUNICATIONS
AMERICA, LLC, a Delaware limited liability
company,

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Defendants.
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APPLE INC.’S ADMIN. MOT. FOR LEAVE TO FILE OBJECTION TO REPLY EVIDENCE
CASE NO. 11-CV-01846-LHK
sf-3162599

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In accordance with Northern District of California Civil Local Rule 7-11, Apple

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respectfully moves the Court for leave to file an Objection to Reply Evidence in Samsung’s Reply

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in Support of Motion for Summary Judgment (Dkt. No. 1063).

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Samsung cited new reply evidence (Exhibit 25 to the Declaration of Bill Trac in Support

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of Samsung’s Reply in Support of Motion for Summary Judgment (Dkt. No. 1068-25)), which the

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Court asked about during the 6/21/2012 hearing, in its summary judgment motion reply briefing.

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During that hearing, counsel for Apple made an oral motion for leave to submit the Supplemental

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Declaration of Ravin Balakrishnan, Ph.D. in Support of Apple’s Opposition to Samsung’s Motion

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for Summary Judgment and provided the Court and opposing counsel with copies.

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To ensure completeness of the record, Apple requests that the Court grant this motion so

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that Apple may have a fair opportunity to respond to Samsung’s contentions regarding this

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exhibit. Copies of the proposed objection and accompanying declaration are attached hereto as

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Exhibits A and B.

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Counsel for Samsung opposes the filing of this motion. (Declaration of Jason R. Bartlett

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in Support of Apple Inc.’s Administrative Motion for Leave to File Objection to Reply Evidence,

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filed herewith, ¶ 2.)

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Dated: June 22, 2012

MORRISON & FOERSTER LLP

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By: /s/ Michael A. Jacobs
Michael A. Jacobs
Attorneys for Plaintiff
APPLE INC.

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APPLE INC.’S ADMIN. MOT. FOR LEAVE TO FILE OBJECTION TO REPLY EVIDENCE
CASE NO. 11-CV-1846-LHK
sf-3162599