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

Filing 1384

Unredacted Exhibits to Arnold Declaration ISO Samsung's MSJ 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, (Dkt. Nos. 930, 945) (Attachments: # 1 Exhibit 46 to Arnold, # 2 Exhibit 47 to Arnold, # 3 Exhibit 48 to Arnold, # 4 Exhibit 49 to Arnold, # 5 Exhibit 50 to Arnold, # 6 Exhibit 51 to Arnold, # 7 Exhibit 52 to Arnold, # 8 Exhibit 54 to Arnold, # 9 Exhibit 55 to Arnold, # 10 Exhibit 56 to Arnold, # 11 Exhibit 57 to Arnold, # 12 Exhibit 58 to Arnold, # 13 Exhibit 60 to Arnold, # 14 Exhibit 63 to Arnold, # 15 Exhibit 64 to Arnold, # 16 Exhibit 66 to Arnold, # 17 Exhibit 68 to Arnold, # 18 Exhibit 69 to Arnold, # 19 Exhibit 71 to Arnold, # 20 Exhibit 73 to Arnold, # 21 Exhibit 74 to Arnold, # 22 Exhibit 75 to Arnold, # 23 Exhibit 76 to Arnold, # 24 Exhibit 77 to Arnold, # 25 Exhibit 78 to Arnold, # 26 Exhibit 79 to Arnold, # 27 Exhibit 80 to Arnold, # 28 Exhibit 81 to Arnold, # 29 Exhibit 82 to Arnold)(Maroulis, Victoria) (Filed on 7/26/2012) Modified text on 7/27/2012 (dhm, COURT STAFF).

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
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HAROLD J. MCELHINNY (CA SBN 66781)
[e-mail]
MICHAEL A. JACOBS (CA SBN 111664)
[e-mail]
RICHARD S.J. HUNG (CA SBN 197425)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: [phone]

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WILLIAM F. LEE (pro hac vice)
[e-mail]
WILMER CUTLER PICKERING
HALE AND DORR LLP
60 State Street
Boston, Massachusetts 02109
Telephone: [phone]
Facsimile: [phone]
MARK D. SELWYN (SBN 244180)
[e-mail]
WILMER CUTLER PICKERING
HALE AND DORR LLP
950 Page Mill Road
Palo Alto, California 94304
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff and
Counterclaim-Defendant Apple Inc.

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION

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APPLE INC., a California corporation,

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Plaintiffs,

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Civil Action No. 11-CV-01846-LHK

vs.

APPLE INC.’S SUPPLEMENTAL
OBJECTIONS AND RESPONSES TO
SAMSUNG’S FIRST SET OF
INTERROGATORIES

SAMSUNG ELECTRONICS CO., LTD., a
Korean business entity, SAMSUNG
ELECTRONICS AMERICA, INC., a New
York corporation, and SAMSUNG
TELECOMMUNICATIONS AMERICA,
LLC, a Delaware limited liability company,

CONFIDENTIAL UNDER THE
PROTECTIVE ORDER

Defendants.

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APPLE INC.’S SUPPLEMENTAL RESPONSES TO
SAMSUNG’S FIRST SET OF INTERROGATORIES
(NOS. 8, 13, & 14)
Case No. 11-cv-01846 (LHK)

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SAMSUNG ELECTRONICS CO., LTD., a
Korean business entity, SAMSUNG
ELECTRONICS AMERICA, INC., a New
York corporation, and SAMSUNG
TELECOMMUNICATIONS AMERICA,
LLC, a Delaware limited liability company, a
California corporation,
Counterclaim-Plaintiff,

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v.
APPLE INC., a California corporation,
Counterclaim-Defendants.

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PLAINTIFF AND COUNTERCLAIM-DEFENDANT APPLE INC.’S
SUPPLEMENTAL RESPONSES TO SAMSUNG’S
FIRST SET OF INTERROGATORIES (NOS. 8, 13, & 14)

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Under Rules 26 and 33 of the Federal Rules of Civil Procedure and Local Rule 33, Apple

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Inc. (“Apple”) hereby provides supplemental responses to the First Set of Interrogatories to

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Apple Inc. (Nos. 8, 13, & 14) served by Samsung Electronics Co., Ltd., Samsung Electronics

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America, Inc., and Samsung Telecommunications America LLC (collectively, “Samsung”) on

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August 3, 2011. These responses are based on information reasonably available to Apple at the

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present time. Apple reserves the right to amend and supplement these responses when and if

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additional information becomes available.

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GENERAL OBJECTIONS
The General Objections set forth in Apple Objections and Responses to Samsung’s First
Set of Interrogatories, served on September 12, 2011, are incorporated herein by reference.

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APPLE INC.’S SUPPLEMENTAL RESPONSES TO
SAMSUNG’S FIRST SET OF INTERROGATORIES
(NOS. 8, 13, & 14)
Case No. 11-cv-01846 (LHK)

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OBJECTIONS AND RESPONSES TO INTERROGATORIES
Subject to the foregoing qualifications and General Objections and the specific objections
made below, Apple objects and responds to Samsung Electronics Co. Ltd.’s First Set of
Interrogatories to Apple Inc. as follows:
Interrogatory No. 8

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Separately for each claim or counterclaim APPLE has asserted or will assert, identify and
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fully describe any and all damages that APPLE is claiming in This Lawsuit and the detailed basis
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for any such damages claim, including whether APPLE is seeking lost profits or a reasonable
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royalty and the periods of time over which APPLE claims it has suffered damages. If APPLE is
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seeking lost profits, identify the amount of the alleged lost profits, the computation of the alleged
lost profits including all revenues, income, costs, unit costs, and quantity associated with the
manufacture, sales and offers for sale by APPLE or any other entity of any product APPLE
contends is covered by the APPLE PATENTS-IN-SUIT, each purported lost sale or other item
which forms any part of APPLE’s alleged lost profits, and the time period over which APPLE
claims it is entitled to lost profits. If APPLE is seeking a reasonable royalty, identify the amount
of the reasonable royalty, including any royalty rate expressed in per unit or percentage of

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revenues terms and the basis for the per unit or percentage used, the computation of the alleged

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reasonable royalty, and the time period over which APPLE claims it is entitled to lost profits.

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Response to Interrogatory No. 8

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Apple objects to this Interrogatory as overbroad, unduly burdensome, and not reasonably

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calculated to lead to the discovery of admissible evidence. Apple objects to this Interrogatory as

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premature to the extent that it: (a) conflicts with the schedule entered by the Court, (b) conflicts

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with the obligations imposed by the Federal Rules of Civil Procedure, the Civil Local Rules

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and/or the Patent Local Rules of this Court, and/or any other applicable rule; (c) seeks

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information that is the subject of expert testimony; (d) seeks information and/or responses that

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are dependent on the Court’s construction of the asserted claims of the patents-in-suit; (e) seeks

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APPLE INC.’S SUPPLEMENTAL RESPONSES TO
SAMSUNG’S FIRST SET OF INTERROGATORIES
(NOS. 8, 13, & 14)
Case No. 11-cv-01846 (LHK)

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information and/or responses that are dependent on depositions and documents that have not
been taken or produced; or (f) requires access to data and information in Samsung’s sole
possession. Apple objects to this Interrogatory to the extent it seeks information that: (i) requires
the disclosure of information, documents, and things protected from disclosure by the attorneyclient privilege, work product doctrine, common interest doctrine, joint defense privilege, or any

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other applicable privilege, doctrine, or immunity; or (ii) can be obtained as easily by Samsung, is
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already in Samsung’s possession, or is publicly available.
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Subject to and without waiving the foregoing General and Specific Objections, Apple
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responds as follows:
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Apple claims a monetary award as a result of Samsung’s infringement of Apple’s patents.
Pursuant to 35 U.S.C. § 289, Apple claims Samsung’s total profits from all sales that infringe
Apple’s design patents, together with prejudgment interest. These shall include Samsung’s total
profits based on sales of each of the infringing products and any profits resulting from associated
or reasonably foreseeable sales of other items in connection with or resulting from the sales of
each of the infringing products. Pursuant to 35 U.S.C. § 284, Apple claims damages adequate to
compensate for Samsung’s infringement of Apple’s design and utility patents, which shall in no

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event be less than a reasonable royalty for Samsung’s infringement. Apple has lost profits on

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sales of its products as well as other revenues due to the presence of Samsung’s infringement and

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the competition by Samsung using Apple’s intellectual property. These lost profits shall include

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lost profits due to lost sales of iPhone and iPad products. Further, they include lost profits due to

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price erosion with respect to Apple products and profits lost because Apple did not receive

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foreseeable downstream sales of additional products and services. A reasonable royalty shall

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apply to any sales of infringing products that are not proved to have resulted in lost profits.

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Apple seeks prejudgment interest on any monetary award provided pursuant to section 284.

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Further, Apples seeks enhanced damages of three times the amount assessed based on Samsung’s

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misconduct and willful infringement of Apple’s patents.

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APPLE INC.’S SUPPLEMENTAL RESPONSES TO
SAMSUNG’S FIRST SET OF INTERROGATORIES
(NOS. 8, 13, & 14)
Case No. 11-cv-01846 (LHK)

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Pursuant to 15 U.S.C. § 1117, Apple claims a monetary award for Samsung’s
misappropriation of Apple’s trademarks and trade dress, and the dilution of the foregoing. Apple
further claims an award based on Samsung’s common law trademark infringement. Samsung has
wrongly obtained profits by virtue of its infringement and misappropriation and this amount shall
be calculated initially on Samsung’s revenues from sales of all products obtained through and as

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a foreseeable result of Samsung’s infringement, dilution, and misappropriation. Apple separately
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claims an award for the damages that it sustained due to Samsung’s infringement, dilution, and
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misappropriation. These include lost sales of Apple products as well as foreseeable downstream
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sales of products and services and the expense of remedial, corrective or other steps that Apple
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has had to take in light of Samsung’s infringement. Further, Apple seeks a monetary award for
purposes of future corrective advertising. Pursuant to section 1117, Apple seeks an award
trebling the damages assessed.
Apple has and will have expended costs and reasonable attorneys fees, which it will seek
to recover pursuant to 15 U.S.C. § 1117 and 35 U.S.C. § 285 because Samsung’s infringement
and misconduct presents an exceptional case.
Based on Samsung’s unfair business practices in violation of California Business and

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Professions Code § 17200 and Samsung’s unjust enrichment of itself due to misappropriation of

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Apple’s intellectual property, Apple claims an award restoring to Apply all profits earned as a

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result of Samsung’s unlawful actions. Apple further claims restitution based on other revenues or

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benefits wrongly obtained by Samsung due to its violations.

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Apple also claims damages as a result of Samsung’s anticompetitive conduct and

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unlawful business acts and practices, including its failure to offer Apple a license on fair,

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reasonable and non-discriminatory (FRAND) terms to Samsung’s claimed standards-essential

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patents. These damages include the expenditure of resources and costs to resolve its licensing

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dispute with Samsung and defending against Samsung’s patent infringement claims,

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notwithstanding Apple’s license to those patents by virtue of Samsung’s FRAND commitments.

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APPLE INC.’S SUPPLEMENTAL RESPONSES TO
SAMSUNG’S FIRST SET OF INTERROGATORIES
(NOS. 8, 13, & 14)
Case No. 11-cv-01846 (LHK)

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Apple also is threatened by loss of profits, loss of customers and potential customers, loss of
goodwill and product image, uncertainty in business planning and uncertainty among customers
and potential customers. Such damages may be determined by methods including, but not limited
to, litigation expenditures incurred in the defense of Samsung’s patent infringement claims, lost
profits, and lost sales. In addition, pursuant to Section 4 of the Clayton Act and/or Section 16750

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of the California Business and Professions Code, Apple is entitled to treble the amount of its
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actual damages suffered as a result of Samsung’s conduct and all reasonable attorneys’ fees and
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costs. Moreover, Apple is seeking all reasonable attorneys’ fees and costs as a result of
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Samsung’s violations of the California Unfair Competition Law, and in connection with its
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defense against Samsung’s infringement claims.
Apple reserves the right to supplement its damages theory as additional information
becomes available. In addition, Apple will provide information responsive to this Interrogatory
consistent with the Court’s Scheduling Order for the disclosure of damages experts.
Supplemental Response to Interrogatory No. 8
Subject to and without waiving the foregoing General and Specific Objections, Apple
responds as follows: Apple also claims damages as a result of Samsung’s breach of contract,

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anticompetitive conduct and unlawful business acts and practices, including its failure to offer

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fair, reasonable and non-discriminatory (FRAND) license terms to Samsung’s claimed

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standards-essential patents. These damages include the expenditure of resources and costs to

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resolve its licensing dispute with Samsung and defending against Samsung’s patent infringement

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claims, notwithstanding Apple’s license to those patents by virtue of Samsung’s FRAND

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commitments. Apple also is threatened by loss of profits, loss of customers and potential

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customers, loss of goodwill and product image, increased input technology costs and decreased

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quality and innovation, uncertainty in business planning and uncertainty among customers and

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potential customers. Such damages may be determined by methods including, but not limited to,

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litigation expenditures incurred in the defense of Samsung’s patent infringement claims, lost

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APPLE INC.’S SUPPLEMENTAL RESPONSES TO
SAMSUNG’S FIRST SET OF INTERROGATORIES
(NOS. 8, 13, & 14)
Case No. 11-cv-01846 (LHK)

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profits, and lost sales. In addition, pursuant to Section 4 of the Clayton Act and/or Section 17200
of the California Business and Professions Code, Apple is entitled to treble the amount of its
actual damages suffered as a result of Samsung’s conduct and all reasonable attorneys’ fees and
costs. Moreover, Apple is seeking all reasonable attorneys’ fees and costs as a result of
Samsung’s violations of the California Unfair Competition Law, and the Sherman Act, and in

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connection with its defense against Samsung’s infringement claims.
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Apple reserves the right to supplement its damages theory as additional information
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becomes available. In addition, Apple will provide information responsive to this Interrogatory
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consistent with the Court’s Scheduling Order for the disclosure of damages experts.
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Interrogatory No. 13
Separately for each of the SAMSUNG PATENTS-IN-SUIT, identify the date(s) APPLE
first became aware of each patent, the persons at APPLE who first became aware of each patent
and the detailed circumstances by which each such person became aware of each patent.
Response to Interrogatory No. 13
Apple objects to this Interrogatory as overbroad, unduly burdensome, and not reasonably
calculated to lead to the discovery of admissible evidence, especially to the extent it calls for the

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identification of the “detailed circumstances” by which Apple became aware of each patent.

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Apple also objects to this Interrogatory to the extent it requires the disclosure of information,

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documents and things protected from disclosure by the attorney-client privilege, work product

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doctrine, common interest doctrine, joint defense privilege, or any other applicable privilege,

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doctrine, or immunity.

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Subject to and without waiving the foregoing General and Specific Objections, Apple

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responds as follows: Apple became aware of U.S. Patent No. 7,675,941 and U.S. Patent No.

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7,447,516 on or before April 21, 2011, when Samsung first asserted the respective foreign

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counterparts of these patents against Apple in Japan and Korea. Apple became aware of the

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following Samsung Patents-in-Suit on or before April 27, 2011, when Samsung filed its initial

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APPLE INC.’S SUPPLEMENTAL RESPONSES TO
SAMSUNG’S FIRST SET OF INTERROGATORIES
(NOS. 8, 13, & 14)
Case No. 11-cv-01846 (LHK)

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Complaint in Case No. 1 1-CV-02079: U.S. Patent Nos. 7,362,867, 7,200,792, 7,386,001,
7,050,410, 6,928,604, and 7,069,055. Apple became aware of the remaining Samsung Patentsin-Suit on or before June 30, 2011, when Samsung filed its Answer and Counterclaims in this
action.
Apple’s investigation is ongoing and Apple reserves the right to supplement this response

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as this litigation progresses.
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Supplemental Response to Interrogatory No. 13
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Subject to and without waiving the foregoing General and Specific Objections, Apple
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responds as follows: During a meeting between Apple and Samsung representatives on
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September 9, 2010, Samsung listed the following Samsung Patents-in-Suit in a PowerPoint
presentation: U.S. Patent Nos. 6,928,604; 7,050,410; 7,069,055; 7,079,871; 7,200,792;
7,362,867; 7,386,001; 7,447,516; 7,577,460; and 7,675,941. The September 9, 2010 meeting
was held in Cupertino, California, and Chip Lutton, Tom Mavrakakis, and Mike Pieja attended
for Apple. The Samsung attendees at this meeting included Kwang Jun Kim. Apple became
aware of the following Samsung Patents-in-Suit on or before June 30, 2011, when Samsung filed
its Answer and Counterclaims in this action: U.S. Patent Nos. 7,456,893 and 7,698,711.
Apple further responds that in accordance with Federal Rule of Civil Procedure 33(d),

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Apple has produced and/or will produce documents responsive to this Interrogatory, and that the

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burden of ascertaining the answer to this Interrogatory from the produced business records is

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substantially the same for Apple as for Samsung. Apple further designates, at this time,

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documents bearing the Bates numbers APLNDC00000369-387 and APLNDC00000898-916,

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from which information responsive to this Interrogatory may be ascertained.

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Apple’s investigation is ongoing and Apple reserves the right to supplement this response
as this litigation progresses.

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APPLE INC.’S SUPPLEMENTAL RESPONSES TO
SAMSUNG’S FIRST SET OF INTERROGATORIES
(NOS. 8, 13, & 14)
Case No. 11-cv-01846 (LHK)

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Interrogatory No. 14
Describe in detail the factual basis for every claim, affirmative defense and every
counterclaim APPLE has asserted or will assert in this lawsuit.
Response to Interrogatory No. 14
Apple objects to this Interrogatory on the grounds that it is overbroad, unduly

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burdensome, and not reasonably calculated to lead to this discovery of admissible evidence.
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Apple objects to this Interrogatory as it contains subparts that each should count as a separate
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Interrogatory. Apple further objects to this Interrogatory, to the extent it requests a complete
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articulation of the factual basis for all its claims in this case, on the grounds that it: (a) conflicts
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with the schedule entered by the Court, (b) conflicts with the obligations imposed by the Federal
Rules of Civil Procedure, the Civil Local Rules and/or the Patent Local Rules of this Court,
and/or any other applicable rule; (c) seeks information that is the subject of expert testimony; (d)
seeks information and/or responses that are dependent on the Court’s construction of the asserted
claims of the patents-in-suit; or (e) seeks information and/or responses that are dependent on
depositions and documents that have not been taken or produced. Moreover, the Court’s Local
Rules and the schedule entered by the Court do not contemplate the disclosure of claim
construction positions or expert opinions at this time.
Apple further objects to this Interrogatory to the extent it requires information outside

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Apple’s possession, custody and control, including, for example, information concerning

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components that Apple has purchased from third parties.

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Subject to and without waiving the foregoing General and Specific Objections, Apple

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responds as follows: Apple filed an amended complaint on June 16, 2011 which describes in

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detail, based upon information then known to Apple, the factual bases for every claim that Apple

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has asserted in this lawsuit. Apple also filed an Answer to Samsung’s Counterclaims and

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Counterclaims in Reply on July 21, 2011 which describes in detail, based upon information then

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APPLE INC.’S SUPPLEMENTAL RESPONSES TO
SAMSUNG’S FIRST SET OF INTERROGATORIES
(NOS. 8, 13, & 14)
Case No. 11-cv-01846 (LHK)

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known to Apple, the factual bases for every affirmative defense and counterclaim that Apple has
asserted in this lawsuit.
Specifically, the factual bases for Apple’s claims of Federal False Designation of Origin
and Unfair Competition, and for California Unfair Business Practices are described in paragraphs
21-25, 27, 48-56, 80-88, 90-92, 95-97, 99, and 106 of Apple’s Amended Complaint.

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The factual bases for Apple’s claims of Federal Trade Dress Infringement and Federal
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Trade Dress Dilution are described in paragraphs 14-16, 18-21, 23-24, 30-68, 80-84, 87, 95-97,
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99-102 of Apple’s Amended Complaint.
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The factual bases for Apple’s claims of Federal Trademark Infringement and Common
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Law Trademark Infringement are described in paragraphs 13-16, 18-21, 23-24, 69-78, 104-105
of Apple’s Amended Complaint.
The factual bases for Apple’s claims of infringement of the ‘D790, ‘D334, ‘D305, ‘D677,
‘D889, ‘D087, ‘D270 patents are supported by paragraph 29 of Apple’s Amended Complaint.
The factual bases for Apple’s claims of infringement of the ‘002, ‘381, ‘607, ‘828, ‘915,
‘891, ‘163, and ‘129 patents are described in paragraphs 26-28, and 94 of Apple’s Amended
Complaint.
Additionally, in accordance with Federal Rule of Civil Procedure 33(d), Apple refers to

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the following documents because the burden of deriving or ascertaining the answer to this

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Interrogatory from the produced business records is substantially the same for Apple as for

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Samsung: Apple’s claim charts for the ‘002, ‘381, ‘607, ‘828, ‘915, ‘891, ‘163, and ‘129 patents

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that Apple served on Samsung on August 26, 2011 pursuant to the Northern District of

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California’s Patent Local Rules.

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To the extent this Interrogatory seeks the identification of the factual basis for Apple’s

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affirmative defenses and counterclaims that the Samsung Patents-in-Suit are invalid, Apple will

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make those disclosures in accordance with the schedule set by the Court. To the extent this

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Interrogatory seeks the identification of the factual basis for Apple’s affirmative defenses and

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APPLE INC.’S SUPPLEMENTAL RESPONSES TO
SAMSUNG’S FIRST SET OF INTERROGATORIES
(NOS. 8, 13, & 14)
Case No. 11-cv-01846 (LHK)

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counterclaims of non-infringement, Apple incorporates by reference its response to Interrogatory
No. 12. To the extent this Interrogatory seeks an identification of the factual basis for Apple’s
remaining affirmative defenses and counterclaims, including its claims that Samsung has
engaged in anticompetitive conduct and unlawful business acts and practices as a result of, inter
alia, its failure to offer Apple a license to Samsung’s claimed standards-essential patents on fair,

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reasonable and non-discriminatory (FRAND) terms notwithstanding Samsung’s FRAND
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commitments, those facts are described at paragraphs 1-4 and 14-90 of Apple’s Counterclaims in
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Reply, which are incorporated herein by reference.
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Apple’s investigation is ongoing and Apple reserves the right to supplement this response
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as this litigation progresses.
Supplemental Response to Interrogatory No. 14
Subject to and without waiving the foregoing General and Specific Objections, Apple
responds as follows: Apple filed its Amended Answer, Defenses and Counterclaims in Reply to
Samsung’s Counterclaims (“Amended Counterclaims”) on November 8, 2011. Apple’s
Amended Counterclaims describes in detail, based upon information then known to Apple, the
factual bases for every affirmative defense and counterclaim that Apple has asserted in this
lawsuit.
To the extent this Interrogatory seeks an identification of the factual basis for Apple’s

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remaining affirmative defenses and counterclaims, including its claims that Samsung has

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engaged in anticompetitive conduct and unlawful business acts and practices in violation of

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Section 2 of the Sherman Act and Cal. Bus. & Prof. Code § 17200 as a result of, inter alia, its

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failure to timely disclose the patents it claims are essential to 3GPP and ETSI and its failure to

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offer Apple a license to Samsung’s claimed standards-essential patents on fair, reasonable and

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non-discriminatory (FRAND) terms notwithstanding Samsung’s FRAND commitments, those

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facts are described at paragraphs 1-6 and 16-106 of Apple’s Amended Counterclaims, which are

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incorporated herein by reference. To the extent this Interrogatory seeks an identification of the

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APPLE INC.’S SUPPLEMENTAL RESPONSES TO
SAMSUNG’S FIRST SET OF INTERROGATORIES
(NOS. 8, 13, & 14)
Case No. 11-cv-01846 (LHK)

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factual basis for Apple’s claims that Samsung has breached its contractual commitments to (and
is estopped from reneging on those promises to) ETSI, ETSI’s members, and designers and
sellers of products that implement the UMTS standard by claiming infringement and seeking to
enjoin Apple from practicing the UMTS standard, those facts are described at paragraphs 1-6 and
16-89 of Apple’s Amended Counterclaims, which are incorporated herein by reference.

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To the extent this Interrogatory seeks the identification of the factual basis for Apple’s
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affirmative defenses and counterclaims that the Samsung Patents-in-Suit are invalid, Apple
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incorporates by reference the invalidity contentions that it served on Samsung on October 7,
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2011 pursuant to the Northern District of California’s Patent Local Rules.
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Apple’s investigation is ongoing and Apple reserves the right to supplement this response
as this litigation progresses.

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Case No. 11-cv-01846 (LHK)

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Dated: March 7, 2012

/s/ Mark D. Selwyn
Mark D. Selwyn (SBN 244180)
([e-mail])
WILMER CUTLER PICKERING
HALE AND DORR LLP
950 Page Mill Road
Palo Alto, California 94304
Telephone: [phone]
Facsimile: [phone]

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William F. Lee (admitted pro hac vice)
([e-mail])
WILMER CUTLER PICKERING
HALE AND DORR LLP
60 State Street
Boston, Massachusetts 02109
Telephone: [phone]
Facsimile: [phone]

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Harold J. McElhinny (SBN 66781)
([e-mail])
Michael A. Jacobs (SBN 111664)
([e-mail])
Richard S.J. Hung (CA SBN 197425)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105
Telephone: ( 415) 268-7000
Facsimile: [phone]

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Attorneys for Plaintiff and
Counterclaim-Defendant Apple Inc.

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13

APPLE INC.’S SUPPLEMENTAL RESPONSES TO
SAMSUNG’S FIRST SET OF INTERROGATORIES
(NOS. 8, 13, & 14)
Case No. 11-cv-01846 (LHK)

OPPOS
FOR

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
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CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the above and foregoing

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document has been served on March 7, 2012 by electronic mail upon the following:
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Charles Kramer Verhoeven (Cal. Bar No. 170151)
([e-mail])
Quinn Emanuel Urquhart & Sullivan LLP
50 California Street, 22nd Floor
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
Kevin P.B. Johnson (Cal. Bar No. 177129)
([e-mail])
Victoria F. Maroulis (Cal. Bar No. 202603)
([e-mail])
Quinn Emanuel Urquhart & Sullivan LLP
555 Twin Dolphin Drive 5th Floor
Redwood Shores, California 94065
Telephone: [phone]
Facsimile: [phone]
Edward J. DeFranco (Cal. Bar No. 165596)
([e-mail])
Quinn Emanuel Urquhart & Sullivan LLP
51 Madison Avenue, 22nd Floor
New York, New York 10010
Telephone: [phone]
Facsimile: [phone]

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Michael T. Zeller (Cal. Bar No. 196417)
([e-mail])
Quinn Emanuel Urquhart & Sullivan LLP
865 S. Figueroa St., 10th Floor
Los Angeles, California 90017
Telephone: [phone]
Facsimile: [phone]

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/s/ Mark. D Selwyn
Mark D. Selwyn

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14

APPLE INC.’S SUPPLEMENTAL RESPONSES TO
SAMSUNG’S FIRST SET OF INTERROGATORIES
(NOS. 8, 13, & 14)
Case No. 11-cv-01846 (LHK)

OPPOS
FOR