Apple Inc. v. Samsung Electronics Co. Ltd. et al
Filing
1322
TRIAL BRIEF Samsung's Unsealed Trial Brief and Exhibits Thereto by Samsung Electronics America, Inc.(a New York corporation), Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC(a Delaware limited liability company). (Attachments: # 1 Declaration of Joby Martin, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Exhibit 6, # 8 Exhibit 7, # 9 Exhibit 8, # 10 Exhibit 9, # 11 Exhibit 10, # 12 Exhibit 11, # 13 Exhibit 12, # 14 Exhibit 13, # 15 Exhibit 14, # 16 Exhibit 15, # 17 Exhibit 16, # 18 Exhibit 17, # 19 Exhibit 18)(Maroulis, Victoria) (Filed on 7/25/2012) Modified on 8/7/2012 EXHIBIT 5, 6, 8 AND 11 HAVE NOT BEEN MANUALLY SUBMITTED TO THE CLERK'S OFFICE FOR FILING (dhm, COURT STAFF).
1 QUINN EMANUEL URQUHART & SULLIVAN, LLP
Charles K. Verhoeven (Bar No. 170151)
charlesverhoeven@quinnemanuel.com
50 California Street, 22nd Floor
San Francisco, California 94111
Telephone: (415) 875-6600
Facsimile: (415) 875-6700
Kevin P.B. Johnson (Bar No. 177129
kevinjohnson@quinnemanuel.com
Victoria F. Maroulis (Bar No. 202603)
victoriamaroulis@quinnemanuel.com
555 Twin Dolphin Drive, 5th Floor
Redwood Shores, California 94065-2139
(650) 801-5000
Telephone:
Facsimile:
(650) 801-5100
Michael T. Zeller (Bar No. 196417)
michaelzeller@quinnemanuel.com
865 S. Figueroa St., 10th Floor
Los Angeles, California 90017
Telephone: (213) 443-3000
Facsimile: (213) 443-3100
Attorneys for SAMSUNG ELECTRONICS CO.,
LTD., SAMSUNG ELECTRONICS AMERICA,
INC. and SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION
APPLE INC., a California corporation,
CASE NO. 11-cv-01846-LHK
DECLARATION OF JOBY MARTIN IN
SUPPORT OF SAMSUNG’S TRIAL
BRIEF
Plaintiff,
vs.
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,
Defendant.
02198.51855/4871770.1
Case No. 11-cv-01846-LHK
MARTIN DECLARATION IN SUPPORT OF SAMSUNG'S TRIAL BRIEF
1
I, Joby Martin, declare as follows:
1.
I am an associate in the law firm of Quinn Emanuel Urquhart & Sullivan, LLP,
counsel for Samsung Electronics Co., Ltd., Samsung Electronics America, Inc., and Samsung
Telecommunications America, LLC (collectively, “Samsung”). I submit this declaration in
support of Samsung’s Trial Brief. I have personal knowledge of the facts set forth in this
declaration and, if called upon as a witness, I could and would testify to such facts under oath.
2.
Attached hereto as Exhibit 1 is a true and correct copy of Defendant’s Exhibit No.
623, a document produced by Apple in this litigation bearing Bates label APLNDC NCC00000274.
3.
Attached hereto as Exhibit 2 is a true and correct copy of Defendant’s Exhibit No.
690, a document produced by Apple in In Re Certain Electronic Digital Media Devices and
Components Thereof, Inv. No. 337-TA-796 ("ITC 796 Investigation"), bearing Bates label APL ITC-X0000016675.
4.
Attached hereto as Exhibit 3 is a true and correct copy of Defendant’s Exhibit No.
562, a document produced by Apple in this litigation bearing Bates label APLNDC0003040119.
5.
Attached hereto as Exhibit 4 is a true and correct copy of Defendant’s Exhibit No.
578, a document produced by Apple in the ITC 796 Investigation, bearing Bates label APL-ITC 0000119763.
6.
Attached hereto as Exhibit 5 is a true and correct copy of Defendant’s Exhibit No.
522, a document produced by Samsung in this litigation bearing Bates label
SAMNDCA00321382.
7.
Attached hereto as Exhibit 6 is a true and correct copy of Defendant’s Exhibit No.
625, a document produced by Samsung in this litigation bearing Bates label
SAMNDCA00321707.
8.
Attached hereto as Exhibit 7 is a true and correct copy of Defendant’s Exhibit No.
519, a document produced by Samsung in this litigation bearing Bates label
SAMNDCA00255357.
02198.51855/4871770.1
Case No. 11-cv-01846-LHK
-1MARTIN DECLARATION IN SUPPORT OF SAMSUNG'S TRIAL BRIEF
1
9.
Attached hereto as Exhibit 8 is a true and correct copy of Defendant’s Exhibit No.
2 566, a document produced by Samsung in this litigation bearing Bates label
3 SAMNDCA00321539.
4
10.
Attached hereto as Exhibit 9.is a true and correct copy of Defendant’s Exhibit No.
5 684, which is a chart prepared by Samsung’s counsel depicting a timeline of mobile phone
6 products released by Samsung before and after the release of the iPhone.
7
11.
Attached hereto as Exhibit 10 is a true and correct copy of Defendant’s Exhibit No.
8 708, a document produced by Apple in this litigation bearing Bates label APLNDC0002230566.
9
12.
Attached hereto as Exhibit 11 is a true and correct copy of Defendant’s Exhibit No.
10 714, a document produced by Apple in this litigation bearing Bates label APLNDC0002367163.
11
13.
Attached hereto as Exhibit 12 is a true and correct copy of Defendant’s Exhibit No.
12 715, a document produced by Apple in the ITC 794 Investigation bearing Bates label
13 APL7940009836305.
14
14.
Attached hereto as Exhibit 13 is a true and correct copy of Defendant’s Exhibit No.
15 717, a document produced by Apple in this litigation bearing Bates label APLNDC0002868532.
16
15.
Attached hereto as Exhibit 14 is a true and correct copy of Defendant’s Exhibit No.
17 709, a document produced by Apple in the ITC 794 Investigation bearing Bates label
18 APL7940014663269.
19
16.
Attached hereto as Exhibit 15 is a true and correct copy of Defendant’s Exhibit No.
20 710, a document produced by Apple in this litigation bearing Bates label APLNDC0001509486.
21
17.
Attached hereto as Exhibit 16 is a true and correct copy of Defendant’s Exhibit No.
22 712, a document produced by Apple in this litigation bearing Bates label APLNDC0002230186.
23
18.
Attached hereto as Ex. 17 is a true and correct copy of excerpts from the February
24 23, 2012 deposition transcript of Greg Joswiak, an Apple witness.
25
19.
Attached hereto as Exhibit 18 is a true and correct copy of Defendant’s Exhibit No.
26 649, a document produced by Apple in this litigation bearing Bates label APLNDC0001207640.
27
28
02198.51855/4871770.1
Case No. 11-cv-01846-LHK
-2MARTIN DECLARATION IN SUPPORT OF SAMSUNG'S TRIAL BRIEF
1
I declare under penalty of perjury under the laws of the United States that the foregoing is
2 true and correct. Executed on the 23rd day of July, 2012, in San Francisco, California.
3
4
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____/s/ Joby Martin
Joby Martin
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02198.51855/4871770.1
Case No. 11-cv-01846-LHK
-3MARTIN DECLARATION IN SUPPORT OF SAMSUNG'S TRIAL BRIEF
1
2
General Order 45 Attestation
I, Victoria F. Maroulis, am the ECF user whose ID and password are being used to file this
3 Declaration. In compliance with General Order 45(X)(B), I hereby attest that Joby Martin has
4 concurred in this filing.
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/s/ Victoria Maroulis
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02198.51855/4871770.1
Case No. 11-cv-01846-LHK
-4MARTIN DECLARATION IN SUPPORT OF SAMSUNG'S TRIAL BRIEF
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