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

Filing 1236

Administrative Motion to File Under Seal Samsung's Objections to Apple's Exhibit List, Proposed Joint Exhibit List and Deposition Designations filed by Samsung Electronics Co. Ltd.. (Attachments: #1 Trac Declaration, #2 Proposed Order, #3 Samsung's Objections, #4 Ex. A, #5 Ex. B, #6 Ex. C, #7 Ex. D)(Maroulis, Victoria) (Filed on 7/13/2012) Modified on 7/16/2012 Pursuant to General Order No. 62 attachment #1 Sealed (dhm, COURT STAFF).

EXHIBIT C

Exhibit C
Codes for Abbreviated Objections
DESCRIPTION
FEDERAL RULES OF EVIDENCE 401/402
(IRRELEVANT)
LACKS FOUNDATION
FEDERAL RULE OF EVIDENCE 802 (HEARSAY)
FEDERAL RULE OF EVIDENCE 403 (UNDULY
PREJUDICIAL, CONFUSING OR WASTE OF
TIME)
MISLEADING
BEST EVIDENCE
FEDERAL RULE OF EVIDENCE 106
(INCOMPLETE DOCUMENT)
FEDERAL RULE OF EVIDENCE 105
FEDERAL RULE OF EVIDENCE 501
(PRIVILEGE)
NARRATIVE
OVERLY BROAD
AUTHENTICITY
NO SPONSOR OR IMPROPER SPONSOR
FEDERAL RULE OF EVIDENCE 408
(COMPROMISE OFFERS AND NEGOTIATIONS)
OBJECTION TO TRANSLATION
LACK OF PERSONAL KNOWLEDGE OR
COMPETENCY
IMPROPER OPINION TESTIMONY BY LAY
WITNESS
IMPROPER TESTIMONY BY EXPERT WITNESS
IMPROPER INCLUSION OF MULTIPLE
DOCUMENTS AS ONE EXHIBIT/ VIOLATES
COURT’S LIMIT ON NUMBER OF EXHIBITS
UNTIMELY/NEVER PRODUCED
DEMONSTRATIVE/SHOULD NOT BE
ADMITTED INTO EVIDENCE
MOTION # 1: EXCLUDE EVIDENCE OR
ARGUMENT NOT TIED TO THE SPECIFIC IP
RIGHTS CLAIMED BY APPLE IN THIS ACTION
MOTION #2: EXCLUDE OUT-OF-COURT
THIRD-PARTY STATEMENTS ABOUT
PURPORTED SIMILARITIES OR PURPORTED
CONFUSION
MOTION #3: EXCLUDE ACCUSED DEVICES,
CONTENTIONS, THEORIES, AND WITNESSES
NOT TIMELY DISCLOSED IN INFRINGEMENT
CONTENTIONS OR INTERROGATORY
RESPONSES

02198.51855/4851616.1

OBJECTIONS
402
lacks foundation
802
403

misleading
1002
incomplete
105
501
narrative
overbroad
authenticity
lacks sponsoring witness
408
translation
602
701
702/703
I

U
D
MIL 1

MIL 2

MIL 3

Exhibit C
Codes for Abbreviated Objections
DESCRIPTION
MOTION #4: EXCLUDE REFERENCE TO
FINDINGS OR RULINGS IN OTHER
PROCEEDINGS NOT INVOLVING THE
PATENTS AT ISSUE IN THIS CASE
MOTION #5: EXCLUDE DISPUTES AND
RULINGS IN THIS ACTION, INCLUDING
DISCOVERY DISPUTES AND THE
PRELIMINARY INJUNCTION RULING
MOTION #6: EXCLUDE GENERALIZATIONS
REGARDING THE OPERATION OF ACCUSED
SAMSUNG PRODUCTS
MOTION # 7: EXCLUDE RESIZED OR ALTERED
PHOTOS OF SAMSUNG’S PRODUCTS IN SIDEBY-SIDE PRODUCT COMPARISONS
MOTION # 8: EXCLUDE ANY EVIDENCE OF
PRE-FILING NOTICE OTHER THAN
IDENTIFIED IN APPLE’S INTERROGATORY
RESPONSE AND PROVISIONALLY EXCLUDE
MR. MUSIKA’S OPINIONS ON PRE-FILING
DAMAGES UNLESS AND UNTIL APPLE
MAKES A PRIMA FACIE SHOWING OF
ENTITLEMENT TO SUCH DAMAGES
MOTION #9: EXCLUDE EVIDENCE OF
SAMSUNG’S OVERALL REVENUES, PROFITS,
WEALTH AND VALUE AND EVIDENCE OR
ARGUMENT THAT SAMSUNG HAS PAID
LOWER TAXES THAN IT SHOULD HAVE
UNOPPOSED MOTION# 10: EXCLUDE
EVIDENCE AND ARGUMENT THAT APPLE IS
PRESENTLY LICENSED TO THE DECLARED
ESSENTIAL PATENTS-IN-SUIT

02198.51855/4851616.1

OBJECTIONS
MIL 4

MIL 5

MIL 6

MIL 7

MIL 8

MIL 9

MIL 10