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

Filing 1129

MOTION for Reconsideration re 1115 Order on Motion for Miscellaneous Relief,,,,,, #1105 Order on Administrative Motion to File Under Seal,,,,,,,,, filed by Samsung Electronics America, Inc.(a New York corporation), Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC(a Delaware limited liability company). (Attachments: #1 Exhibit to Samsung's Motion, #2 Declaration of Hankil Kang in Support of Samsung's Motion, #3 Exhibit 1 to the Kang Declaration, #4 Exhibit 2 to the Kang Declaration, #5 Exhibit 3 to the Kang Declaration, #6 Exhibit 4 to the Kang Declaration, #7 Exhibit 5 to the Kang Declaration, #8 Exhibit 6 to the Kang Declaration, #9 Exhibit 7 to the Kang Declaration, #10 Exhibit 8 to the Kang Declaration, #11 Exhibit 9 to the Kang Declaration, #12 Exhibit 10 to the Kang Declaration, #13 Exhibit 11 to the Kang Declaration, #14 Exhibit 12 to the Kang Declaration, #15 Exhibit 13 to the Kang Declaration, #16 Exhibit 14 to the Kang Declaration, #17 Exhibit 15 to the Kang Declaration, #18 Exhibit 16 to the Kang Declaration, #19 Exhibit 17 to the Kang Declaration, #20 Proposed Order Granting Samsung's Motion for Reconsideration)(Maroulis, Victoria) (Filed on 6/25/2012)

KANG DECLARATION
EXHIBIT 5

Exhibit 30
Filed Under Seal

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------- Original Message ------Sender: Dale Sohn <[e-mail]> Exec. Dir./CEO/STA (North America)/Samsung
Electronics
Date: 2011-06-24 00:19 (GMT+09:00)
Title: RE: (To CEO) Re: STA weekly sales status report
To: Yongil Lee <[e-mail]> Ji-Ung Park <[e-mail]> Byunggil Yoo
<[e-mail]> Yonggi Min <[e-mail]> Moonchul Lee
<[e-mail]> Sangryong Lee <[e-mail]> Sungho Byun
<[e-mail]> Yongki Min <[e-mail]>
Executive Director Lee,
Thank you for your opinion. After I review it, I will send you the proposal from corporate.
Head of Division Yoo,
Please quickly prepare a GS2 response meeting at corporate. Please include marketing strategy,
sales simulations, and complaint elements regarding competitiveness and simulation results

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regarding apple’s product release. Let’s review re-distributions of marketing costs and linking with the
tab.

CEO
From: Yongil Lee [mailto:[e-mail]]
Sent: Thursday, June 23, 2011 1:59 AM
To: Dale Sohn: Byunggil Yoo: Yong KI Min: Mooncheol Lee: Sangryong Lee: Seongho Byun
Subject: (To CEO) Re: STA weekly sales status report

Exec. Director Sohn,
I am sending you details that I wanted to share with you from the contents of the conversation I had
with team leader Don Joo Lee in Seoul.
- From releasing the 3 models (Dempsey/Nexus/Charge), it seems that we have succeeded in
keeping HTC at bay, but Apple seems to have taken no damage.
Therefore, we should start thinking about how to hurt Apple. I think the three GS2 brothers’
successful release can achieve this.
- Since it is going to be difficult to pressure Apple with the Android tablet, we should use the money
that we have, other than the money we have for this year’s tablet launch, for the successful launching
activities of the GS2.

I will divert some manpower from the tablet strategic team and deploy them to work on delivering a
blow to Apple by getting us the successful launching of the GS2.
Please think about the focus within corporate and let us have a phone conversation afterwards.

I will keep in touch.
Sincerely,
Yongil Lee
------- Original Message ------Sender: Donju Lee <[e-mail]> Exec. Vice President/Team Leader/Strategic Marketing
Team (Wireless) / Samsung Electronics
Date: 2011-06-23 11:23 (GMT+09:00)
Title: Re: STA weekly sales status report

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Executive Director Dale Sohn,

In reading the attached weekly report,

1. I could not help but feel’s Apple’s power.
2. And felt that if the I-phone 5 is launched this September as we expect, the U.S. market will
probably be swept away by Apple’s wave.

The last counter-attack that Samsung can launch this year is stated as..

“I think the way to do it is to successfully launch the Galaxy S2 3 brothers (Galaxy S2, Hercules,
Gaudi) bundled into key features; 4G, dual Core, S-Amoled.”

In regards to his,

1. What are Samsung’s winning strategies against the competitors’ (Apple, HTC, Motorola’s new
models) new product introduction strategies? (Including pricing positions)

2. What are the ATL/BTL plans, including the branding strategy?

3. Please give me feedback on the results regarding what the groundwork strategy related to the GS3

introduction is.

I hope that Exec. Dir. Yongil Lee, Exec. Dir. Yonghee Lee actively participates, and helps in creating
a comprehensive and in-depth strategy (one that directly affects the competitor’s sales)

Thank you.

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Sincerely,
Wireless Strategic Marketing Team Leader

------- Original Message -------Sender : Byunghee Choi <[e-mail]> M6(Sr. Mgr.)/Sr. Mgr. in charge/STA(North
America)/Samsung Electronics
Date : 2011-06-23 04:22 (GMT+09:00)
Title : STA weekly sales status report

To: America Export Group, Global Management Team, North America Product Planning Group
Cc: Strategic Marketing Team Leader, Product Strategy Team Leader, Production Technology
Center Leader
From: Byunghee Choi (STA)

2. Competitor sales status

- Apple’s Sales: 0.53 million units (last week 0.5 million units)

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. Verizon 186K (including 56K the Apple store) and ATT 344K (128K from the Apple store)
- HTC’s sales: 0.26 million units (last week 0.24 million units)

Please see the attachment for detailed sales contents.

That is all.

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