Apple Inc. v. Samsung Electronics Co. Ltd. et al
Filing
1360
Unredacted Declaration of Bill Trac in Support of Samsung's Reply in Support of Motion for Summary Judgment 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, re (Dkt. Nos. 1068, 1069) (Attachments: # 1 Exhibit 1 to the Trac Declaration, # 2 Exhibit 2 to the Trac Declaration, # 3 Exhibit 8 to the Trac Declaration, # 4 Exhibit 9 to the Trac Declaration, # 5 Exhibit 10 to the Trac Declaration, # 6 Exhibit 14 to the Trac Declaration, # 7 Exhibit 15 to the Trac Declaration, # 8 Exhibit 16 to the Trac Declaration, # 9 Exhibit 17 to the Trac Declaration, # 10 Exhibit 18 to the Trac Declaration, # 11 Exhibit 19 to the Trac Declaration, # 12 Exhibit 20 to the Trac Declaration, # 13 Exhibit 21 to the Trac Declaration, # 14 Exhibit 22 to the Trac Declaration, # 15 Exhibit 23 to the Trac Declaration, # 16 Exhibit 24 to the Trac Declaration, # 17 Exhibit 25 to the Trac Declaration, # 18 Exhibit 26 to the Trac Declaration, # 19 Exhibit 27 to the Trac Declaration, # 20 Exhibit 28 to the Trac Declaration)(Maroulis, Victoria) (Filed on 7/26/2012) Modified text on 7/27/2012 (dhm, COURT STAFF).
EXHIBIT 1
FILED UNDER SEAL
CONTAINS CONFIDENTIAL BUSINESS INFORMATION, SUBJECT TO PROTECTIVE ORDER
UNITED STATES INTERNATIONAL TRADE COMMISSION
WASHINGTON, DC
Before The Honorable Thomas B. Pender
Chief Administrative Law Judge
In the Matter of:
Investigation No. 337-TA-796
Certain Electronic Digital Media Devices and
Components Thereof
RESPONDENT SAMSUNG ELECTRONICS CO., LTD.'S EIGHTH SET OF
SUPPLEMENTAL RESPONSES TO COMPLAINANT’S FIRST SET OF
INTERROGATORIES (NOS. 33-38)
Preliminary Statement
Samsung Electronics Co., Ltd. (“SEC” or “Respondent”) has made a reasonable
investigation for information responsive to Apple Inc.'s (“Complainant”) Interrogatories based
upon its current employees’ knowledge, information, and belief and based on the limited time
since Complainant served those interrogatories. Respondent’s investigation of the facts and law
pertaining to this action is ongoing. Respondent expects that it will supplement or modify its
responses and nothing herein should be interpreted to the contrary or to otherwise prejudice
Respondent's ability to do so. Respondent reserves all available rights to use or introduce at any
hearing, or at trial, information and/or documents responsive to Complainant’s Interrogatories
that is discovered after the date of this response. Respondent reserves all objections or other
questions as to the competency, relevance, materiality, privilege, or admissibility in any
proceeding or trial of this or any other action for any purpose whatsoever of Respondent’s
responses herein and any document or thing identified or provided in response to Complainant’s
1
CONTAINS CONFIDENTIAL BUSINESS INFORMATION, SUBJECT TO PROTECTIVE ORDER
VII.
U.S. Patent D618,678 (“the D’678 patent”)
A. Prior Art
SEC incorporates by reference the prior art identified in its Notice of Prior Art.
B. Invalidity Under 35 U.S.C. § 102 or 103
SEC identifies the following additional prior art that anticipates and/or renders obvious
the D'678 patent either expressly or inherently as understood by a person having ordinary skill in
the art at the time of the alleged invention, either alone or in combination with other references
identified below. These references are prior art under at least 35 U.S.C. §§ 102(a), (b), (e), (g)
and/or 103.
1. Claim Chart
Prior Art Design
Disclosure Rendering the Claim Unpatentable
Elements
Without waiving any
1. Bluebird Pidion BM-200 — (released November 2005;
right to address
SAMNDCA00326344 - SAMNDCA00326346)
additional design
characteristics of this
prior art that anticipate
and/or render obvious
the design claimed in
D'678, and without
waiving any right to
show that the design
claimed in D'678 is
indefinite, this prior art
shares at least the
following design
characteristics with
those that may be
claimed in D'678:
x Rounded Corners
x Lack of Significant
Ornamentation
x Rectangular Shape
x Flat Continuous
Surface
156
CONTAINS CONFIDENTIAL BUSINESS INFORMATION, SUBJECT TO PROTECTIVE ORDER
Prior Art Design
Disclosure Rendering the Claim Unpatentable
Elements
x Reflective or
Transparent Surface
x Horizontal Speaker
Slot
x Speaker Slot
Located Near Top
of Device
x Display Screen
Covering
Substantial Portion
of Front Face
x Display Screen in
Center of Device
x Narrow Borders on
Sides of Screen
x Broader Borders
Above and Below
Screen
Without waiving any
right to address
additional design
characteristics of this
prior art that anticipate
and/or render obvious
the design claimed in
D'678, and without
waiving any right to
show that the design
claimed in D'678 is
indefinite, this prior art
shares at least the
following design
characteristics with
those that may be
claimed in D'678:
x Rounded Corners
x Lack of Significant
Ornamentation
x Rectangular Shape
x Flat Continuous
2. Korean Patent 0398307 — (Issued Nov. 15, 2005;
SAMNDCA00282113 - SAMNDCA00282120)
157
CONTAINS CONFIDENTIAL BUSINESS INFORMATION, SUBJECT TO PROTECTIVE ORDER
Prior Art Design
Elements
Surface
x Horizontal Speaker
Slot
x Speaker Slot
Located Near Top
of Device
x Display Screen
Covering
Substantial Portion
of Front Face
x Display Screen in
Center of Device
x Narrow Borders on
Sides of Screen
x Broader Borders
Above and Below
Screen
Disclosure Rendering the Claim Unpatentable
158
CONTAINS CONFIDENTIAL BUSINESS INFORMATION, SUBJECT TO PROTECTIVE ORDER
Prior Art Design
Elements
Without waiving any
right to address
additional design
Disclosure Rendering the Claim Unpatentable
3. United States Patent D504,889 — (filed March 17, 2004;
SAMNDCA00200769—SAMNDCA00200773)
159
CONTAINS CONFIDENTIAL BUSINESS INFORMATION, SUBJECT TO PROTECTIVE ORDER
Prior Art Design
Disclosure Rendering the Claim Unpatentable
Elements
characteristics of this
prior art that anticipate
and/or render obvious
the design claimed in
D'678, and without
waiving any right to
show that the design
claimed in D'678 is
indefinite, this prior art
shares at least the
following design
characteristics with
those that may be
claimed in D'678:
x Rounded Corners
x Lack of Significant
Ornamentation
x Rectangular Shape
x Flat Continuous
Surface
x Reflective or
Transparent Surface
x Display Screen
Covering
Substantial Portion
of Front Face
x Display Screen in
Center of Device
Without waiving any
right to address
additional design
characteristics of this
prior art that anticipate
and/or render obvious
the design claimed in
D'678, and without
waiving any right to
show that the design
claimed in D'678 is
indefinite, this prior art
shares at least the
following design
characteristics with
4. LG Prada — (Images available to public by December 2006;
SAMNDCA00326458 - SAMNDCA00326461)
160
CONTAINS CONFIDENTIAL BUSINESS INFORMATION, SUBJECT TO PROTECTIVE ORDER
Prior Art Design
Disclosure Rendering the Claim Unpatentable
Elements
those that may be
claimed in D'678:
x Rounded Corners
x Lack of Significant
Ornamentation
x Rectangular Shape
x Flat Continuous
Surface
x Reflective or
Transparent Surface
x Horizontal Speaker
Slot
x Speaker Slot
Located Near Top
of Device
x Display Screen
Covering
Substantial Portion
of Front Face
x Display Screen in
Center of Device
x Narrow Borders on
Sides of Screen
x Broader Borders
Above and Below
Screen
Without waiving any
right to address
additional design
characteristics of this
prior art that anticipate
and/or render obvious
the design claimed in
D'678, and without
waiving any right to
show that the design
claimed in D'678 is
indefinite, this prior art
5. Sharp Japanese Registration – JP 1241638 — (Issued June
6, 2005; SAMNDCA00255247—SAMNDCA00255260)
161
CONTAINS CONFIDENTIAL BUSINESS INFORMATION, SUBJECT TO PROTECTIVE ORDER
Prior Art Design
Elements
shares at least the
following design
characteristics with
those that may be
claimed in D'678:
x Rounded Corners
x Lack of Significant
Ornamentation
x Rectangular Shape
x Horizontal Speaker
Slot
x Speaker Slot
Located Near Top
of Device
x Display Screen
Covering
Substantial Portion
of Front Face
x Display Screen in
Center of Device
x Narrow Borders on
Sides of Screen
x Broader Borders
Above and Below
Screen
Without waiving any
right to address
additional design
characteristics of this
prior art that anticipate
and/or render obvious
the design claimed in
D'678, and without
waiving any right to
show that the design
claimed in D'678 is
indefinite, this prior art
shares at least the
following design
characteristics with
those that may be
claimed in D'678:
Disclosure Rendering the Claim Unpatentable
6. LG Chocolate (LG KG800) — (Released March 2006;
SAMNDCA00326329 - SAMNDCA00326331;
SAMNDCA00326462)
162
CONTAINS CONFIDENTIAL BUSINESS INFORMATION, SUBJECT TO PROTECTIVE ORDER
Prior Art Design
Disclosure Rendering the Claim Unpatentable
Elements
x Rounded Corners
x Lack of Significant
Ornamentation
x Rectangular Shape
x Flat Continuous
Surface
x Reflective or
Transparent Surface
x Horizontal Speaker
Slot
x Speaker Slot
Located Near Top
of Device
x Display Screen
Covering
Substantial Portion
of Front Face
x Display Screen in
Center of Device
x Narrow Borders on
Sides of Screen
x Broader Borders
Above and Below
Screen
Without waiving any
right to address
additional design
characteristics of this
prior art that anticipate
and/or render obvious
the design claimed in
D'678, and without
7. United States Patent, D536,691 — (Filed Mar. 13, 2006;
Issued Feb. 13, 2007; SAMNDCA00200883—
SAMNDCA00200888)
163
CONTAINS CONFIDENTIAL BUSINESS INFORMATION, SUBJECT TO PROTECTIVE ORDER
Prior Art Design
Disclosure Rendering the Claim Unpatentable
Elements
waiving any right to
show that the design
claimed in D'678 is
indefinite, this prior art
shares at least the
following design
characteristics with
those that may be
claimed in D'678:
x Rounded Corners
x Lack of Significant
Ornamentation
x Rectangular Shape
x Flat Continuous
Surface
x Reflective or
Transparent Surface
x Horizontal Speaker
Slot
x Speaker Slot
Located Near Top
of Device
x Display Screen
Covering
Substantial Portion
of Front Face
x Display Screen in
Center of Device
x Narrow Borders on
Sides of Screen
x Broader Borders
Above and Below
Screen
Without waiving any
right to address
additional design
characteristics of this
prior art that anticipate
and/or render obvious
the design claimed in
D'678, and without
waiving any right to
show that the design
8. Japanese Patent JP 1241383 — (Issued June 2005;
SAMNDCA00255283—SAMNDCA00255295)
164
CONTAINS CONFIDENTIAL BUSINESS INFORMATION, SUBJECT TO PROTECTIVE ORDER
Prior Art Design
Disclosure Rendering the Claim Unpatentable
Elements
claimed in D'678 is
indefinite, this prior art
shares at least the
following design
characteristics with
those that may be
claimed in D'678:
x Rounded Corners
x Lack of Significant
Ornamentation
x Rectangular Shape
x Flat Continuous
Surface
x Display Screen
Covering
Substantial Portion
of Front Face
x Display Screen in
Center of Device
x Narrow Borders on
Sides of Screen
x Broader Borders
Above and Below
Screen
Without waiving any
right to address
additional design
characteristics of this
prior art that anticipate
and/or render obvious
the design claimed in
D'678, and without
waiving any right to
show that the design
claimed in D'678 is
indefinite, this prior art
shares at least the
following design
characteristics with
those that may be
9. Japanese Design Patent JP 1009317 — (Issued Feb. 20,
1998; SAMNDCA00255278—SAMNDCA00255282)
165
CONTAINS CONFIDENTIAL BUSINESS INFORMATION, SUBJECT TO PROTECTIVE ORDER
Prior Art Design
Elements
claimed in D'678:
x Rounded Corners
x Lack of Significant
Ornamentation
x Rectangular Shape
x Flat Continuous
Surface
x Horizontal Speaker
Slot
x Speaker Slot
Located Near Top
of Device
x Display Screen
Covering
Substantial Portion
of Front Face
x Display Screen in
Center of Device
x Narrow Borders on
Sides of Screen
x Broader Borders
Above and Below
Screen
Without waiving any
right to address
additional design
characteristics of this
prior art that anticipate
and/or render obvious
the design claimed in
D'678, and without
waiving any right to
show that the design
claimed in D'678 is
indefinite, this prior art
shares at least the
following design
characteristics with
those that may be
claimed in D'678:
x Rounded Corners
x Lack of Significant
Ornamentation
Disclosure Rendering the Claim Unpatentable
10. Samsung Korean Patent 30-0452984; Application KR 302006-0050769 — (Applied for December 2006; patent issued
Aug. 2007; SAMNDCA00255357—SAMNDCA00255365)
166
CONTAINS CONFIDENTIAL BUSINESS INFORMATION, SUBJECT TO PROTECTIVE ORDER
Prior Art Design
Elements
x Rectangular Shape
x Flat Continuous
Surface
x Horizontal Speaker
Slot
x Speaker Slot
Located Near Top
of Device
x Display Screen
Covering
Substantial Portion
of Front Face
x Display Screen in
Center of Device
x Narrow Borders on
Sides of Screen
x Broader Borders
Above and Below
Screen
Without waiving any
right to address
additional design
characteristics of this
prior art that anticipate
and/or render obvious
the design claimed in
D'678, and without
waiving any right to
show that the design
claimed in D'678 is
indefinite, this prior art
shares at least the
following design
characteristics with
those that may be
claimed in D'678:
x Rounded Corners
Disclosure Rendering the Claim Unpatentable
11. Japanese Design Patent JP-S-887388 — (Issued Dec. 21,
1993; SAMNDCA00255215—SAMNDCA00255221)
167
CONTAINS CONFIDENTIAL BUSINESS INFORMATION, SUBJECT TO PROTECTIVE ORDER
Prior Art Design
Elements
x Lack of Significant
Ornamentation
x Rectangular Shape
x Display Screen
Covering
Substantial Portion
of Front Face
x Display Screen in
Center of Device
Without waiving any
right to address
additional design
characteristics of this
prior art that anticipate
and/or render obvious
the design claimed in
D'678, and without
waiving any right to
show that the design
claimed in D'678 is
indefinite, this prior art
shares at least the
following design
characteristics with
those that may be
claimed in D'678:
x Rounded Corners
x Lack of Significant
Ornamentation
x Rectangular Shape
x Display Screen
Covering
Substantial Portion
of Front Face
Disclosure Rendering the Claim Unpatentable
12. Japanese Design Patent JP-S-1142127 — (Issued May 27,
2002; SAMNDCA00255229—SAMNDCA00255246)
168
CONTAINS CONFIDENTIAL BUSINESS INFORMATION, SUBJECT TO PROTECTIVE ORDER
Prior Art Design
Elements
x Display Screen in
Center of Device
Without waiving any
right to address
additional design
characteristics of this
prior art that anticipate
and/or render obvious
the design claimed in
D'678, and without
waiving any right to
show that the design
claimed in D'678 is
indefinite, this prior art
shares at least the
following design
characteristics with
those that may be
claimed in D'678:
x Rounded Corners
x Lack of Significant
Ornamentation
x Rectangular Shape
x Flat Continuous
Surface
x Reflective or
Transparent Surface
x Display Screen
Covering
Substantial Portion
of Front Face
x Display Screen in
Center of Device
Disclosure Rendering the Claim Unpatentable
13. United States Design Patent D497,364 — (Filed Nov. 27,
2002, Issued Oct. 19, 2004; SAMNDCA00326308 SAMNDCA00326314)
169
CONTAINS CONFIDENTIAL BUSINESS INFORMATION, SUBJECT TO PROTECTIVE ORDER
Prior Art Design
Elements
Without waiving any
right to address
additional design
characteristics of this
prior art that anticipate
and/or render obvious
the design claimed in
D'678, and without
waiving any right to
show that the design
claimed in D'678 is
indefinite, this prior art
shares at least the
following design
characteristics with
those that may be
claimed in D'678:
x Rounded Corners
x Lack of Significant
Ornamentation
x Rectangular Shape
Disclosure Rendering the Claim Unpatentable
14. United States Patent D548,747 — (filed August 24, 2005;
SAMNDCA00200936—SAMNDCA00200940)
170
CONTAINS CONFIDENTIAL BUSINESS INFORMATION, SUBJECT TO PROTECTIVE ORDER
Prior Art Design
Disclosure Rendering the Claim Unpatentable
Elements
x Flat Continuous
Surface
x Reflective or
Transparent Surface
171
CONTAINS CONFIDENTIAL BUSINESS INFORMATION, SUBJECT TO PROTECTIVE ORDER
Prior Art Design
Elements
Disclosure Rendering the Claim Unpatentable
172
CONTAINS CONFIDENTIAL BUSINESS INFORMATION, SUBJECT TO PROTECTIVE ORDER
Prior Art Design
Disclosure Rendering the Claim Unpatentable
Elements
Without waiving any
15. iRiver U10 — (Released October 2005;SAMNDCA00326325
right to address
- SAMNDCA00326328)
additional design
characteristics of this
prior art that anticipate
and/or render obvious
the design claimed in
D'678, and without
waiving any right to
show that the design
claimed in D'678 is
indefinite, this prior art
shares at least the
following design
characteristics with
those that may be
claimed in D'678:
x Rounded Corners
x Lack of Significant
Ornamentation
x Rectangular Shape
x Flat Continuous
Surface
x Reflective or
Transparent Surface
x Display Screen
Covering
Substantial Portion
of Front Face
x Display Screen in
Center of Device
x Narrow Borders on
Two Opposing
Sides of Screen
x Broader Borders on
the Remaining Two
Sides of the Screen
Without waiving any
right to address
additional design
16. Nokia N92 — (Released 2005; SAMNDCA00326338 SAMNDCA00326339)
173
CONTAINS CONFIDENTIAL BUSINESS INFORMATION, SUBJECT TO PROTECTIVE ORDER
Prior Art Design
Disclosure Rendering the Claim Unpatentable
Elements
characteristics of this
prior art that anticipate
and/or render obvious
the design claimed in
D'678, and without
waiving any right to
show that the design
claimed in D'678 is
indefinite, this prior art
shares at least the
following design
characteristics with
those that may be
claimed in D'678:
x Rounded Corners
x Lack of Significant
Ornamentation
x Rectangular Shape
x Flat Continuous
Surface
x Reflective or
Transparent Surface
x Horizontal Speaker
Slot
x Speaker Slot
Located Near Top
of Device
x Display Screen
Covering
Substantial Portion
of Front Face
x Display Screen in
Center of Device
x Narrow Borders on
Sides of Screen
x Broader Borders
Above and Below
Screen
Without waiving any
17. Olympus m:robe MR-100 — (Released 2005;
174
CONTAINS CONFIDENTIAL BUSINESS INFORMATION, SUBJECT TO PROTECTIVE ORDER
Prior Art Design
Disclosure Rendering the Claim Unpatentable
Elements
right to address
SAMNDCA00326463 - SAMNDCA00326466)
additional design
characteristics of this
prior art that anticipate
and/or render obvious
the design claimed in
D'678, and without
waiving any right to
show that the design
claimed in D'678 is
indefinite, this prior art
shares at least the
following design
characteristics with
those that may be
claimed in D'678:
x Rounded Corners
x Lack of Significant
Ornamentation
x Rectangular Shape
x Flat Continuous
Surface
x Reflective or
Transparent Surface
x Display Screen
175
CONTAINS CONFIDENTIAL BUSINESS INFORMATION, SUBJECT TO PROTECTIVE ORDER
Prior Art Design
Disclosure Rendering the Claim Unpatentable
Elements
Without waiving any
18. Japanese Design Patent 1204221 — (Issued May 10, 2004; right to address
SAMNDCA00256066—SAMNDCA00256079)
additional design
characteristics of this
prior art that anticipate
and/or render obvious
the design claimed in
D'678, and without
waiving any right to
show that the design
claimed in D'678 is
indefinite, this prior art
shares at least the
following design
characteristics with
those that may be
claimed in D'678:
x Rounded Corners
x Lack of
Ornamentation
x Rectangular Shape
x Flat Continuous
Surface
x Horizontal Ear
Speaker Slot
x Ear Speaker Slot
Located Near Top
of Device
x Display Screen
Covering
Substantial Portion
of Front Face
x Display Screen in
Center of Device
x Narrow Borders on
Sides of Screen
x Broader Borders
Above and Below
Screen
Without waiving any
19. Nokia Design Contest Phone by Ricardo Villas-Boas —
176
CONTAINS CONFIDENTIAL BUSINESS INFORMATION, SUBJECT TO PROTECTIVE ORDER
Prior Art Design
Disclosure Rendering the Claim Unpatentable
Elements
right to address
(Publicly displayed online in 2004; SAMNDCA00326336 additional design
SAMNDCA00326337; SAMNDCA00326380 characteristics of this
SAMNDCA00326385)
prior art that anticipate
and/or render obvious
the design claimed in
D'678, and without
waiving any right to
show that the design
claimed in D'678 is
indefinite, this prior art
shares at least the
following design
characteristics with
those that may be
claimed in D'678:
x Rounded Corners
x Lack of
Ornamentation
x Flat Continuous
Surface
x Ear Speaker
Opening Near Top
of Device
x Display Screen
Covering
Substantial Portion
of Front Face
x Display Screen in
Center of Device
x Narrow Borders on
Sides of Screen
x Broader Borders
Above and Below
Screen
Without waiving any
right to address
20. Korean Design Patent KR 30-0418547 — (Issued July 2006;
SAMNDCA00255321—SAMNDCA00255329)
177
CONTAINS CONFIDENTIAL BUSINESS INFORMATION, SUBJECT TO PROTECTIVE ORDER
RESPONSE TO INTERROGATORY NO. 47:
SEC incorporates each of its general objections by reference. SEC further objects to this
request as premature to the extent it calls for SEC to identify “the person whom you expect will
offer testimony.” SEC further objects to this request to the extent it calls for information
protected from discovery by the attorney-client privilege and/or the work product doctrine.
Respondent objects to this request as being premature to the extent it calls for information prior
to the schedule set by the Court for the disclosure of such information, including to the extent
that it seeks information that is more properly the subject of expert testimony prior the time set
for expert discovery by the Court.
Without waiving the foregoing general and specific objections and subject to those
objections, SEC responds as follows:
After all parties to this Investigation have met and conferred for purposes of deciding on
a mutually-agreed joint schedule for the mutual exchange of information sought by
interrogatories served by any Party, including this interrogatory, that seek information as
described in 19 C.F.R. § 210.29(b)(3), SEC will supplement its response to this interrogatory in
accordance with such joint schedule.
SEC is continuing to investigate the subject matter of this interrogatory and reserves the
right to supplement its response to the extent it locates additional non-privileged, relevant
documents or information responsive to this interrogatory and to the extent Complainant
produces to SEC materials or information relevant to this request.
Dated: February 15, 2012
Respectfully submitted,
/s/ Eric Huang
Charles K. Verhoeven
230
CONTAINS CONFIDENTIAL BUSINESS INFORMATION, SUBJECT TO PROTECTIVE ORDER
Quinn Emanuel Urquhart & Sullivan, LLP
50 California Street, 22nd Floor
San Francisco, CA 94111
Telephone: 415-875-6600
Kevin P.B. Johnson
Victoria Maroulis
Quinn Emanuel Urquhart & Sullivan, LLP
555 Twin Dolphin Drive, 5th Floor
Redwood Shores, California 94065
Telephone: 650-801-5066
Eric Huang
Quinn Emanuel Urquhart & Sullivan, LLP
51 Madison Ave., 22nd Floor
New York, NY 10010
Telephone: 212-849-7000
William Price
Quinn Emanuel Urquhart & Sullivan, LLP
865 S. Figueroa St., 10th Floor
Los Angeles, California 90017
Telephone: 213-443-3000
Paul F. Brinkman
S. Alex Lasher
Quinn Emanuel Urquhart & Sullivan, LLP
1299 Pennsylvania Ave. NW, Suite 825
Washington, DC 20004
Telephone: 202-756-1950
Charles F. Schill
Steptoe & Johnson LLP
1330 Connecticut Avenue, NW
Washington, DC 20036
Telephone: 202-429-8162
Counsel for Respondent Samsung
Electronics Co., Ltd.
231
CONTAINS CONFIDENTIAL BUSINESS INFORMATION, SUBJECT TO PROTECTIVE ORDER
CERTIFICATE OF SERVICE
The undersigned certifies that, on February 15, 2012, he caused the
RESPONDENT SAMSUNG ELECTRONICS CO., LTD.'S EIGHTH SET OF SUPPLEMENTAL
RESPONSES TO COMPLAINANT’S FIRST SET OF INTERROGATORIES (NOS. 33-38)
to be served on behalf of Respondents Samsung Electronics Co., LTD, Samsung Electronics
America, and Samsung Telecommunications America, LLC. as follows:
;
Reginald Lucas, Esq.
Office of Unfair Import Investigations
U.S. International Trade Commission
500 E Street, SW
Washington, DC 20436
Via First Class Mail
Via Hand Delivery
Via Overnight Courier
Via Facsimile
Via E-mail (PDF)
Reginald.Lucas@usitc.gov
;
Alexander J. Hadjis
MORRISON & FOERSTER LLP
2000 Pennsylvania Ave., NW, Suite 6000
Washington, DC 20006
Tel: (202) 887-1500
Fax: (202) 887-0763
Via First Class Mail
Via Hand Delivery
Via Overnight Courier
Via Facsimile
Via E-mail (PDF)
AppleITC@mofo.com
Counsel for Complainant Apple, Inc.
______/s/ Ron Hagiz_________________________
232
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