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

Filing 1184

Administrative Motion to File Under Seal Re Apples Motions In Limine filed by Apple Inc.. (Attachments: #1 Declaration Of Cyndi Wheeler In Support Of Apples Administrative Motions To File Documents Under Seal Re Apples Motions In Limine, #2 [Proposed] Order Granting Apple Inc.s Administrative Motion To File Documents Under Seal Re Apples Motions In Limine, #3 Apples Motions In Limine, #4 Declaration Of Jason Bartlett In Support Of Apples Motions In Limine, #5 Exhibit 1, #6 Exhibit 3, #7 Exhibit 4, #8 Exhibit 5, #9 Exhibit 6, #10 Exhibit 7, #11 Exhibit 8, #12 Exhibit 9, #13 Proposed Order)(Jacobs, Michael) (Filed on 7/5/2012)

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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,
Plaintiff,

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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,

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Defendants.
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BARTLETT DECL. ISO APPLE’S MOT. IN LIMINE
CASE NO. 11-CV-01846-LHK (PSG)

pa-1540164

Case No.

11-cv-01846-LHK (PSG)

DECLARATION OF JASON
BARTLETT IN SUPPORT OF
APPLE’S MOTIONS IN LIMINE

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I, JASON BARTLETT, declare as follows:
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I am a partner in the law firm of Morrison & Foerster LLP, counsel for Apple Inc.

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(“Apple”). I am licensed to practice law in the State of California and admitted to practice before

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this Court. Unless otherwise indicated, I have personal knowledge of the matters stated herein or

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understand them to be true from members of my litigation team. I make this declaration in

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support of Apple’s Motion in Limine.

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2.

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Supplemental Objections and Responses to Apple’s Fifth Set of Interrogatories (11-12).
3.

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Attached hereto as Exhibit 2 is a true and correct copy of an excerpt of the

transcript of the March 30, 2012 deposition of Junho Park.
4.

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Attached hereto as Exhibit 1 is a true and correct copy of an excerpt of Samsung’s

Attached hereto as Exhibit 3 is a true and correct copy of an excerpt of Apple’s

Second Set of Request for Production of Documents (Nos. 9-52).
5.

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Attached hereto as Exhibit 4 is a true and correct copy of an excerpt of Samsung’s

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Objections and Responses to Apple’s Second Set of Requests for Production of Documents (Nos.

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9-52).

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6.

Attached hereto as Exhibit 5 is a true and correct copy of Japanese Patent No.

D1204221, produced as SAMNDCA00256066-79.
7.

Attached hereto as Exhibit 6 is a true and correct copy of excerpts of Samsung’s

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Pre-Hearing Brief in In the Matter of Certain Electronic Digital Media Devices and Components

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Thereof, Inv. No. 337-TA-796, dated May 10, 2012.

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8.

Attached hereto as Exhibit 7 is a true and correct copy of excerpts of the rebuttal

expert report of Peter W. Bressler, dated April 16, 2012.
9.

Attached hereto as Exhibit 8 is a true and correct copy of an email from Curan

Walker to Alison Tucher, dated July 5, 2012 at 2:15 P.M.
10.

Attached hereto as Exhibit 9 is a true and correct copy of excerpts of the hearing

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in In the Matter of Certain Electronic Digital Media Devices and Components Thereof, Inv. No.

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337-TA-796, dated June 7, 2012.
BARTLETT DECL. ISO APPLE’S MOT. IN LIMINE
CASE NO. 11-CV-01846-LHK (PSG)

pa-1540164

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11.

Attached hereto as Exhibit 10 is a true and correct copy of excerpts of the

deposition of Brian Huppi, dated October 18, 2011.
I declare under penalty of perjury that the foregoing is true and correct. Executed this
5th day of July, 2012 at San Francisco, California.

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/s/ Jason Bartlett
Jason Bartlett

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BARTLETT DECL. ISO APPLE’S MOT. IN LIMINE
CASE NO. 11-CV-01846-LHK (PSG)

pa-1540164

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ATTESTATION OF E-FILED SIGNATURE
I, Michael A. Jacobs, am the ECF User whose ID and password are being used to file this

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Declaration. In compliance with General Order 45, X.B., I hereby attest that Jason Bartlett has

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concurred in this filing.

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Dated: July 5, 2012
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/s/Michael A. Jacobs
Michael A. Jacobs

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BARTLETT DECL. ISO APPLE’S MOT. IN LIMINE
CASE NO. 11-CV-01846-LHK (PSG)

pa-1540164

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