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

Filing 1396

Administrative Motion to File Under Seal Third Party Confidential Information filed by Research In Motion Corporation, Research In Motion Ltd.. (Attachments: # 1 Attachment A, # 2 Declaration of Michael J. Crowley, # 3 Exhibit A to Crowley Decl, # 4 Exhibit B to Crowley Decl, # 5 Declaration of Jonathan Lange, # 6 Exhibit A to Lange Decl, # 7 Proposed Order)(Lange, Jonathan) (Filed on 7/26/2012)

EXHIBIT B

From: Borgman, Steve
Sent: Wednesday, February 01, 2012 3:58 PM
To: 'Melissa Dalziel'
Subject: RE: Apple v. Samsung (NDCA Action)
Melissa -- Thank you for your January 31 email. RIM does not object to the production of the single license agreement
(attached) so long as it is designated Highly Confidential -- Attorneys' Eyes Only under the protective order dated January
30, 2012 (Dkt. 687), and Apple employees and in-house counsel will not have access to it. Please be sure that the copy
produced includes this designation on every page; the attached copy does not include this required designation yet.
Please let me know if you have any questions.
Best,
Steve

Steve Borgman
Vinson & Elkins L.L.P.
1001 Fannin
2500 First City Tower
Houston, Texas 77002-6760
713-758-2002 (office)
713-615-5758 (fax)
[e-mail]

From: Melissa Dalziel [mailto:[e-mail]]
Sent: Tuesday, January 31, 2012 7:03 PM
To: Borgman, Steve
Subject: RE: Apple v. Samsung (NDCA Action)

Thanks, Steve.  Attached is the new protective order in the NDCA action. The only RIM document that we have identified 
as responsive in the NDCA action to date is the attached patent license agreement, which has already been produced in 
the ITC action.  The Court has ordered that this document be produced by February 3rd.  (See pp. 9‐11 of the attached 
1/27/12 Order re: production of license agreements; p. 2 re: February 3rd production date.)  Please let me know if RIM 
has any concerns regarding this production. 

Best regards, Melissa 
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Melissa Dalziel
Of Counsel
Quinn Emanuel Urquhart & Sullivan, LLP
865 S. Figueroa Street, 10th Floor
Los Angeles, CA 90017
213-443-3110 Direct
213-443-3000 Main Office Number
213-443-3100 Fax
[e-mail]
www.quinnemanuel.com
NOTICE: The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. This message
may be an attorney-client communication and/or work product and as such is privileged and confidential. If the reader of this message is not the intended
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From: Borgman, Steve [mailto:[e-mail]]
Sent: Tuesday, January 31, 2012 2:47 PM
To: Melissa Dalziel
Subject: RE: Apple v. Samsung (NDCA Action)

Melissa -- This is to follow up on our call last week. As I indicated on the call, RIM wants to see the specific
documents involved so it knows what disclosures are involved in connection with the requested consent. In
addition, I understood from the call that you were looking into the status of the stipulation and whether and to
what extent it applied to non-expedited discovery, as well as whether any other protective orders have been
entered in the case.
Please note that, pending resolution of these issues, RIM does not consent to the production of any RIM
confidential information.
Best,
Steve
Steve Borgman
Vinson & Elkins L.L.P.
1001 Fannin
2500 First City Tower
Houston, Texas 77002-6760
713-758-2002 (office)
713-615-5758 (fax)
[e-mail]

From: Melissa Dalziel [mailto:[e-mail]]
Sent: Wednesday, January 25, 2012 5:53 PM
To: Borgman, Steve
Subject: Apple v. Samsung (NDCA Action)

Steve, I understand that you may represent RIM.  Attached is a courtesy copy of correspondence we are sending to RIM 
via fed‐ex today.  Please feel free to contact me with any questions. 

Best regards, Melissa 

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Melissa Dalziel
Of Counsel
Quinn Emanuel Urquhart & Sullivan, LLP
865 S. Figueroa Street, 10th Floor
Los Angeles, CA 90017
213-443-3110 Direct
213-443-3000 Main Office Number
213-443-3100 Fax
[e-mail]
www.quinnemanuel.com
NOTICE: The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. This message
may be an attorney-client communication and/or work product and as such is privileged and confidential. If the reader of this message is not the intended
recipient or agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any
review, dissemination, distribution, or copying of this message is strictly prohibited. If you have received this communication in error, please notify us immediately
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