Apple Inc. v. Samsung Electronics Co. Ltd. et al
Filing
129
Declaration of Richard J. Lutton in Support of #86 MOTION for Preliminary Injunction filed byApple Inc.. (Related document(s) #86 ) (Bartlett, Jason) (Filed on 7/21/2011)
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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.
Case No.
11-cv-01846-LHK
DECLARATION OF RICHARD J.
LUTTON, JR. IN SUPPORT OF
APPLE’S MOTION FOR A
PRELIMINARY INJUNCTION
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,
Defendants.
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DECLARATION OF RICHARD J. LUTTON, JR. IN SUPPORT OF APPLE’S MOTION FOR A PRELIMINARY INJUNCTION
CASE NO. 11-CV-01846-LHK
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I, Richard J. Lutton, Jr., do hereby declare as follows:
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I am a Senior Director and the Chief Patent Counsel at Apple Inc. (“Apple”). I
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submit this declaration in support of Apple’s Motion for Preliminary Injunction. If called as a
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witness, I could and would testify competently as follows.
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Apple’s negotiations with Samsung over Samsung’s copying of Apple’s designs
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began in July 2010, when Samsung first launched its Galaxy line of smartphones bearing a
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striking resemblance to Apple’s own iPhone products.
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DECLARATION OF RICHARD J. LUTTON, JR. IN SUPPORT OF APPLE’S MOTION FOR A PRELIMINARY INJUNCTION
CASE NO. 11-CV-01846-LHK
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My hopes, however, were not realized. In February 2011, Samsung announced
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that it would be introducing a new tablet-style device called the Galaxy Tab 10.1. The Tab 10.1,
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in size, shape, and styling, is a close copy of Apple’s iPad. That same month, the press also
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released images of Samsung’s new Galaxy S 2 smartphone, which bore a remarkable similarity to
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Apple’s own iPhone.
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As of late March 2011, with the emergence of additional Samsung products
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copying the iPhone’s distinctive features arriving on the market such as the Galaxy S 4G, it
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became clear that Samsung had no intention of ceasing its infringement.
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DECLARATION OF RICHARD J. LUTTON, JR. IN SUPPORT OF APPLE’S MOTION FOR A PRELIMINARY INJUNCTION
Case No. 11-cv-01846-LHK
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