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

Filing 1350

UNREDACTED NOTICE OF MOTIONS AND MOTIONS in Limine by Samsung Electronics America, Inc.(a New York corporation), Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC(a Delaware limited liability company) re 1256 Order on Administrative Motion to File Under Seal, (Attachments: # 1 Exhibit C to the D'Amato Declaration, # 2 Exhibit E to the D'Amato Declaration, # 3 Exhibit G to the D'Amato Declaration, # 4 Exhibit H to the D'Amato Declaration, # 5 Exhibit J to the D'Amato Declaration, # 6 Exhibit K to the D'Amato Declaration, # 7 Exhibit L to the D'Amato Declaration, # 8 Exhibit M to the D'Amato Declaration, # 9 Exhibit N to the D'Amato Declaration, # 10 Exhibit T to the D'Amato Declaration, # 11 Exhibit V to the D'Amato Declaration, # 12 Exhibit W to the D'Amato Declaration)(Maroulis, Victoria) (Filed on 7/26/2012) Modified text on 7/27/2012 (dhm, COURT STAFF).

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Ki Hyun Seo <[e-mail]>
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Subject: Team Leader’s Directives at the Executives’ Meeting 2/22 (Mon)

Recipients: See recipients
Sender: Planning Operations Part Leader
Title: Team Leader’s Directives at the Executives’ Meeting 2/22 (Mon)

Sent Date: 2.23.2010 (Tue)

Greetings.
I am notifying you of the team leader’s directives from the executives’ meeting yesterday (2/22 Mon) as
described below, so corresponding parts and people in charge, please keep them in mind when carrying them
out.
- Below –
1. Push for follow up strategy meetings for U.K., France and Germany within March, and regarding the
subsidiary corporation’s request about Non- touch device, let them know that the HQ’s basic strategy is to
respond to the market mainly with smartphones and touch phones and need to respond with the existing
roadmap instead of planning a new device. (Vice President Hankil Yoon, Vice President Jun Yeong Kim).
2. Each of the PP part leaders and group leaders needs to prepare a response strategy against RIM
Company for this year and next year. Need to thoroughly concern ourselves with RIM Company. Need
countermeasures to RIM Company’s Enterprise stronghold, like Apple Company’s A-store (this is an item
of interest for the COO) (Vice President Hankil Yoon, Vice President Wonsik Lee, Vice President Jong In
Kim/Vice President Yongbae Lee/ Senior Vice President DongHoon Chang, Vice President Changhwan
Hwang, Vice President Seogguen Kim)
3. Planning to hold Product Strategy Team’s strategy meeting every Tuesday (08:00~09:00) with Head
of Division. For this week, we need to summarize and prepare MWC follow-up F/U. (Vice President
Hankil Yoon, Vice President Wonsik Lee)
[Regarding MWC follow up]
3. For the 4” model, push to confirm the designs for the 4 major carriers such as T-Mobile, and as for the
P1 model, things have been finalzed with T-Mobile, while Verizon (3G, LTE proposal requested) and
Sprint are requesting proposals, and we need to consider going with the same 7” design.
Design and Features regarding the P1 and P3 were discussed with Google during MWC, and adoption of
the P3 is confirmed and the decision on whether or not to go with the P1 is scheduled to be made within
the next two weeks. Samsung needs to decide on the design and detailed specifications internally. (
Need to measure AMOLED vs. TFT power consumption)
In regards to the commercialization of the Curved Display Qwert and Touch model[s], we need to consider
global adoption by Google and commercialization in the North American market. We need to examine in
detail because North American carriers have a wide variety of demands.
Need a formal proposal for the Kiosk for Google DTC-bound Curved device and the Veyron model. Need

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4. Regarding design Quality upgrade for the US-bound models, we are working on supplementing the ’11
archetypes by reflecting suggestions from the carriers. Planning to prepare the design to be offered to AT&T in early
March (likely 3/8). (Vice President Changhwan Hwang)
5. Lismore has been fairly well received locally and we need to push to expand sales as much as we can in the first
half of the year. The local subsidiary corporation is requesting samples but it is still undergoing S/W stabilization
process. Monte is in launching stage and we need to respond aggressively to Nokia’s 5230 and 5530
Regarding the S1, carriers, including Orange, are responding positively, and we need to consider a metal version
because there is a lot of demand for it. Marketing Strategy Team needs to decide on the launching timetable
between Lismore and the S1 model.
(Vice President Jun Yeong Kim, Vice President Hankil Yoon/ Senior Vice President DongHoon Chang, Vice
President Changhwan Hwang, Vice President Seogguen Kim)
6. Respond to the issue of design similarity for the S series by changing the CMF, and we also need to prepare for
accessory standardization. Need discussion and preparation from PUI. Also need to consider whether or not to
pursue P2 and P4 of the P series (to be decided after looking into marketability).
Google is demanding distinguishable design vis-à-vis the iPad for the P3. Consider design distinguishability for the
items demanded by Google while maintaining the current design, and in regards to each carrier’s demands, Design
Group needs to actively voice their opinions to the Head of the Division.
Curved Display models have been received relatively well by the carriers, so we should prepare Curved series but
should prepare a Working Sample at an early stage and evaluate it.
(Vice President Hankil Yoon, Vice President Wonsik Lee/ Senior Vice President DongHoon Chang, Vice President
Changhwan Hwang, Vice President Seogguen Kim)
7. Design for China Telecom’s S1 (Dual Standby) will likely be decided this week. As for the Woodstock model
(WM6.5), do not introduce in China if not it is not introduced globally. SP part is expected to confirm whether or not it
will be adopted globally this week. (Vice President Hankil Yoon, Department Head Sung Eun Kim)
8. The Head of Division directed us to pursue making a common domestic S1 model for all carriers, but SKT is
asking for an exclusive version. Please ascertain and report the progress status for PMD and plans for the future
Need to change the process so that matters relating to the Mobile Communications Division are always discussed
ahead of time before proceeding, even if it is a matter handled by MSC and DMC Lab (Vice President Jong In Kim,
Senior Manager Chang Han Kim)
9. A separate report is needed for issues relating to other matters (Department Head Sang Yoon Lee)
10. NBI Part needs to be thorough in organizational management, and there needs to be summary of New Idea[s]
and pursuit of Open Innovation[s]. Rather than adopting the new concepts/technologies being worked on at
Development, we need to prepare a response for the coming 2012 Web World era by identifying the technological
trends of our competitors and Merging existing technologies as the start. (Vice President Seok Ha Ko)
11.Pushing to load Google Maps on the S1 in response to Nokia’s announcement regarding Free Map. (Nokia’s
Navteq Solution is better, but going with Google Maps because it would add to costs) Need to continue discussions
with Development (Vice President Yongbae Lee)
-That is allI filled in the names of corresponding executives and department heads in charge for each of the team leader’s
directives.
I organized items inter-related amongst different groups in the order of Product Planning, EA and Design group;
thank you for your understanding.

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