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).

quinn emanuel

trial lawyers | silicon valley

555 Twin Dolphin Drive, 5th Floor, Redwood Shores, California 94065-2139 | TEL: [phone] FAX: [phone]

December 10, 2011

Mia Mazza
Morrison & Foerster
425 Market Street
San Francisco, CA 94105-2482

Re:

S. Calvin Walden
WilmerHale
399 Park Ave
New York, NY 10022

Apple, Inc. v. Samsung Elecs. Co., Case No. 11-CV-1846 LHK

Dear Mia and Calvin:
In the Court's December 9, 2011 Order re Temporary Relief From In Person Meet and Confer
Requirement (Dkt. 472), the Court excused Apple from the "in-person" requirement, but Apple
still needs to conduct a lead counsel meet and confer. Mr. Verhoeven is available on December
11, 2011 at 2:00 pm, Pacific Time, to meet telephonically on the issues raised by Apple's motion,
as well as on the issues we've previously identified as ripe for lead-counsel meet-and-confer,
including:
x
x
x
x
x
x
x

Documents from Apple’s action against Motorola in the ITC
Mac OS 10.0 and SuperClock source code
Return of Samsung’s memory cards and deletion of Apple's copies of photographs
Documents, including model shop records and tangibles related to the 035
Mockup
Obtaining Apple's compliance with Judge Grewal's order of November 16, 2011
requiring complete searches for materials relating to the 035 Mockup
Supplemental response to Interrogatory 1
Complete design inventor sketchbooks (redacting only future products)

quinn emanuel urquhart & sullivan, llp
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02198.51855/4474632.3
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NEW YORK |

Mia Mazza
S. Calvin Walden
December 10, 2011
x
x
x
x
x
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Materials related to Apple’s investigation of Sony design language and designs
based on other smartphones (Treo/Razr)
Materials related to "Phillips receiver" test reports in connection with
development of iPhone
Documents and prototypes related to the “Brain Box”
Documents and prototypes related to the Apple Cinema Display
Prior deposition testimony of Apple’s employees, testifying in their capacity as
Apple employees
Release of materials designated "Attorneys' Eyes Only" to Dr. Itay Sherman

Please let us know Mr. McElhinny's availability as soon as possible.
Kind regards,
/s/
Diane C. Hutnyan

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