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

Filing 1331

Declaration of Karl Olson in Support of 1330 Opposition/Response to Motion, Declaration of Karl Olson in Support of Third Party Reuters America LLC's Opposition to Renewed Motions to Seal filed byReuters America LLC. (Attachments: # 1 Exhibit A to Declaration of Karl Olson, # 2 Exhibit B to Declaration of Karl Olson, # 3 Exhibit C to Declaration of Karl Olson, # 4 Exhibit D to Declaration of Karl Olson, # 5 Exhibit E to Declaration of Karl Olson, # 6 Exhibit F to Declaration of Karl Olson, # 7 Exhibit G to Declaration of Karl Olson)(Related document(s) 1330 ) (Olson, Karl) (Filed on 7/25/2012)

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KARL OLSON (SBN 104760)
[e-mail]
RAM, OLSON, CEREGHINO & KOPCZYNSKI LLP
555 Montgomery Street, Suite 820
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Third-Party REUTERS AMERICA LLC

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE
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APPLE INC., a California corporation,

CASE NO. 11-cv-01846-LHK

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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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DECLARATION OF KARL OLSON IN
SUPPORT OF THIRD PARTY REUTERS
AMERICA LLC’S OPPOSITION TO
RENEWED MOTIONS TO SEAL
Date:
Time:
Place:
Judge:

July 27, 2012
3:00 p.m.
Courtroom 1, 5th Floor
Hon. Lucy H. Koh

Defendants.
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1.

I, Karl Olson, am a member in good standing of the State Bar of California and a

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partner at Ram, Olson, Cereghino & Kopczynski, counsel for third party intervenor Reuters

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America LLC. I make this declaration of personal knowledge and if called as a witness I could

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and would testify competently to the facts stated herein.

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2.

Attached as Exhibit A are excerpts (pages 87-89) from the July 18, 2012 Pretrial

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Conference in this case in this Court which I attended at which the court stated that other than

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third party source code “I=m really not going to seal anything.”

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3.

Attached as Exhibit B hereto is a printout from the Internet which gives a

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“Preliminary Bill of Materials Estimate for the Major Subsystems in the iPhone 4s.” This lists

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various financial information including the retail price and the manufacturing cost.

Case No. 11-cv-01846-LHK – DECLARATION OF KARL OLSON IN SUPPORT OF
THIRD PARTY REUTERS AMERICA LLC’S OPPOSITION TO RENEWED MOTIONS TO SEAL

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4.

Attached as Exhibit C hereto is an article from the Fair Labor Association entitled

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“Independent Investigation of Apple Supplier Foxconn” which reports on working conditions at

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Foxconn, Apple=s supplier and China=s largest employer, and an investigation thereof. Attached

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as Exhibit D hereto is a Reuters article about Apple and Foxconn agreeing to tackle violations of

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conditions among the 1.2 million workers assembling iPhones and iPads

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5.

Attached as Exhibit E hereto is an article reporting that Korea=s National Tax

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Service is asking Samsung to pay about $350 million in additional taxes after authorities

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reportedly uncovered tax evasions and transactions with overseas subsidiaries at non-market

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prices. The article reports that Samsung Chairman Lee Kun-Hee was convicted of tax evasion

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several years ago and later pardoned by the Korean president.
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Attached as Exhibit F hereto is an article from the New York Times, dated

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December 30, 2009, entitled, “Korean Leader Pardons Samsung=s Ex-Chairman,” reporting that

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in a Supreme Court ruling in 2009 Mr. Lee received a suspended three-year prison sentence for

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evading tens of millions of dollars in taxes and embezzling corporate money.

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7.

Attached as Exhibit G hereto is an excerpt from a rough trial transcript of the

Oracle v. Google trial on April 25, 2012.

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I declare under penalty of perjury that the foregoing is true and correct.

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Executed in San Francisco, California on July 25, 2012.

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/s/ Karl Olson
Karl Olson

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N:\DOCS\1273-02\OppMotsSeal2-KO Decl.doc

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Case No. 11-cv-01846-LHK – DECLARATION OF KARL OLSON IN SUPPORT OF
THIRD PARTY REUTERS AMERICA LLC’S OPPOSITION TO RENEWED MOTIONS TO SEAL

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