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).

TXLQQ HPDQXHO

WULDO ODZ\HUV _ ORV DQJHOHV

865 South Figueroa Street, 10th Floor, Los Angeles, California 90017-2543 | TEL: [phone] FAX: [phone]

December 30, 2011

Mia Mazza
Morrison & Foerster LLP
425 Market St.
San Francisco, CA 94105-2482
Re:

Apple v. Samsung Electronics, et al., No. 5:11-cv-01846-LHK (N.D. Cal.)

Dear Mia:
I write regarding the search terms applied to the electronic document and model databases for
items relating to the Brain Box flat panel display, Apple Cinema Display, Sony and other
smartphone investigations, and Phillips Receiver test reports. As you are well aware, the Court
has ordered Apple to conduct a reasonable, good faith search for these items, and although we
appreciate Apple's explanation regarding its search process for these items, Apple’s search
process as described in your December 24, 2011 letter is deficient. Accordingly, per your
invitation, we would like to propose some additional search terms that should not be overly
burdensome to run, but that are very likely to result in additional relevant hits.
Brain Box flat panel display
In your December 24 letter, you stated that Apple has run the search term "Brain Box" through
the entire electronic document collection of the Industrial Design inventors, and that Apple has
also run the term "Brain Box," the names of the alleged designers of the Brain Box, and the year
1989 through its database of models.
Please also run the following terms through the electronic document and email collection: "flat
TXLQQ HPDQXHO XUTXKDUW VXOOLYDQ OOS
NEW YORK | 51

Madison Avenue, 22nd Floor, New York, New York 10010-1601 | TEL [phone] FAX [phone]
California Street, 22nd Floor, San Francisco, California 94111-4788 | TEL [phone] FAX [phone]
SILICON VALLEY | 555 Twin Dolphin Drive, 5th Floor, Redwood Shores, California 94065-2139 | TEL [phone] FAX [phone]
CHICAGO | 500 W. Madison Street, Suite 2450, Chicago, Illinois 60661-2510 | TEL [phone] FAX [phone]
SAN FRANCISCO | 50

WASHINGTON, DC | 1299

Pennsylvania Avenue NW, Suite 825, Washington, District of Columbia 20004-2400 | TEL [phone]

Old Bailey, London EC4M 7EG, United Kingdom | TEL [phone] FAX [phone]
TOKYO | NBF Hibiya Building, 25F, 1-1-7, Uchisaiwai-cho, Chiyoda-ku, Tokyo 100-0011, Japan | TEL [phone]

FAX (202)

LONDON | 16

MANNHEIM |

FAX +81

3 5510 1712

Erzbergerstraße 5, 68165 Mannheim, Germany | TEL [phone] FAX [phone]
MOSCOW | Voentorg Building, 3rd Floor, 10 Vozdvizhenka Street, Moscow 125009, Russia | TEL [phone] FAX [phone]

538-8100

panel" within 20 of ("1989" or "Sigmar" or "Wilnauer" or "Gavin" or "Ivester" or "Tony" or
"Anthony" or "Guido").
Apple Cinema Display
Your December 24 letter does not specify what searches have been or are being conducted to
locate materials related to the Apple Cinema Display. Please confirm that you have searched the
term "Apple Cinema Display" in the electronic document and email collection as well as in the
model database. Further, if you have not already done so, please also run the search terms
“ACD” and “cinema” on the electronic document and email collection as well as the model
database.
Sony design investigation
You state in your letter that you have applied the term "Sony" to Apple's entire collection of
emails and other electronic documents, as well as to the model database.
Please also run the following terms through the electronic document and email collection: "Jony"
within 50 of ("design investigation" or "design language" or "*phone*").
Our use of an asterisk (“*”) around the word “phone” indicates that this term should be open
ended (e.g., “*phone*” would include “smartphone,” “smartphones,” “phones,” etc.)
Treo/Razr investigations
You also indicate in your letter that you have run the terms "Treo" and "Razr" through Apple's
entire collection of emails and other electronic documents, as well as the model database.
Please also run the following terms through the electronic document and email collection, as well
as the model database: ("Motorola" or "Palm") within 20 of ("design investigation" or "design
language" or "*phone*").
Phillips receiver test reports
Finally, your letter states that you have run the terms "Philips" and "Phillips" through Apple's
entire collection of emails and other electronic documents.
Please also run the following terms through the electronic document and email collection:
("Philip" or "Phillip") within 10 of "receiver".
Please confirm in writing by January 2, 2012 that we have the correct understanding of your
search terms and process, and that you will apply Samsung's proposed terms and produce by
January 15, 2012 all additional items and documents that these proposed terms hit.

2

Kind regards,
/s/
Diane C. Hutnyan

3