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

Filing 1418

Declaration of Prashanth Chennakesavan in Support of 1414 Joint Motion Regarding Sealing of Trial Exhibits filed by Samsung Electronics America, Inc.(a New York corporation), Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC(a Delaware limited liability company). (Related document(s) 1414 ) (Maroulis, Victoria) (Filed on 7/27/2012) Modified text on 7/30/2012 (dhm, COURT STAFF).

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP
Charles K. Verhoeven (Bar No. 170151)
2 [e-mail]
50 California Street, 22nd Floor
3 San Francisco, California 94111
Telephone: [phone]
4 Facsimile: [phone]
5 Kevin P.B. Johnson (Bar No. 177129)
[e-mail]
6 Victoria F. Maroulis (Bar No. 202603)
[e-mail]
th
7 555 Twin Dolphin Drive, 5 Floor
Redwood Shores, California 94065-2139
8 Telephone: [phone]
Facsimile: [phone]
9
Michael T. Zeller (Bar No. 196417)
10 [e-mail]
865 S. Figueroa St., 10th Floor
11 Los Angeles, California 90017
Telephone: [phone]
12 Facsimile: [phone]
13 Attorneys for SAMSUNG ELECTRONICS CO.,
LTD., SAMSUNG ELECTRONICS AMERICA,
14 INC. and SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

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19 APPLE INC., a California corporation,
Plaintiff,

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vs.

22 SAMSUNG ELECTRONICS CO., LTD., a
Korean business entity; SAMSUNG
23 ELECTRONICS AMERICA, INC., a New
York corporation; SAMSUNG
24 TELECOMMUNICATIONS AMERICA,
LLC, a Delaware limited liability company,
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Defendant.
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CASE NO. 11-cv-01846-LHK
DECLARATION OF PRASHANTH
CHENNAKESAVAN IN SUPPORT OF
THE PARTIES’ JOINT MOTION
REGARDING THE SEALING OF TRIAL
EXHIBITS

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02198.51855/4878046.1

Case No. 11-cv-01846-LHK
DECLARATION OF PRASHANTH CHENNAKESAVAN

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I, Prashanth Chennakesavan, declare:

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1.

I am an associate with the law firm of Quinn Emanuel Urquhart & Sullivan, LLP,

3 counsel for Samsung Electronics Co., Ltd., Samsung Electronics America, Inc., and Samsung
4 Telecommunications America, LLC (collectively “Samsung”). I have personal knowledge of the
5 facts set forth in this declaration and, if called upon as a witness, I could and would testify to such
6 facts under oath.
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2.

I make this declaration in support of the parties’ Joint Motion Regarding the

8 Sealing of Trial Exhibits.
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3.

On July 25, 2012, the same day that Samsung and Apple Inc. (“Apple”) exchanged

10 their respective trial exhibits, counsel for the parties held a telephonic conference to discuss a joint
11 approach on the presentation of evidence at trial that would minimize the need to seal trial
12 exhibits.
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4.

On July 26, 2012, counsel for the parties participated in an in-person meet-and-

14 confer session to discuss the sealing of trial exhibits.
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5.

During the meet-and-confer session, counsel for the parties exchanged draft

16 proposals about the presentation of evidence at trial that would minimize the need to introduce
17 into evidence exhibits that contain highly-sensitive information.
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6.

While the parties have yet to reach a final agreement that would eliminate the need

19 to introduce into evidence exhibits that contain highly sensitive information altogether, Samsung
20 will negotiate in good faith to minimize the need to seal trial exhibits. Based on my discussions
21 with counsel for Apple, I believe that Apple will also negotiate in good faith.
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I declare under penalty of perjury that the foregoing is true and correct. Executed in Los

24 Angeles, California on July 27, 2012.
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/s/ Prashanth Chennakesavan

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Prashanth Chennakesavan

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02198.51855/4878046.1

Case No. 11-cv-01846-LHK
DECLARATION OF PRASHANTH CHENNAKESAVAN

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GENERAL ORDER ATTESTATION

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I, Victoria Maroulis, am the ECF user whose ID and password are being used to file the
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foregoing document. I hereby attest pursuant to General Order 45.X.B. that concurrence in the
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electronic filing of this document has been obtained from Prashanth Chennakesavan.
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/s/ Victoria Maroulis
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02198.51855/4878046.1

Case No. 11-cv-01846-LHK
DECLARATION OF PRASHANTH CHENNAKESAVAN

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