Apple Inc. v. Samsung Electronics Co. Ltd. et al
Filing
1419
Declaration of YoungJin Kwon 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 charlesverhoeven@quinnemanuel.com
50 California Street, 22nd Floor
3 San Francisco, California 94111
Telephone: (415) 875-6600
4 Facsimile: (415) 875-6700
5 Kevin P.B. Johnson (Bar No. 177129)
kevinjohnson@quinnemanuel.com
6 Victoria F. Maroulis (Bar No. 202603)
victoriamaroulis@quinnemanuel.com
th
7 555 Twin Dolphin Drive, 5 Floor
Redwood Shores, California 94065-2139
8 Telephone: (650) 801-5000
Facsimile: (650) 801-5100
9
Michael T. Zeller (Bar No. 196417)
10 michaelzeller@quinnemanuel.com
865 S. Figueroa St., 10th Floor
11 Los Angeles, California 90017
Telephone: (213) 443-3000
12 Facsimile: (213) 443-3100
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.
CASE NO. 11-cv-01846-LHK (PSG)
DECLARATION OF YOUNGJIN KWON
IN SUPPORT OF THE PARTIES’ JOINT
MOTION REGARDING SEALING OF
TRIAL EXHIBITS
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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Defendants.
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02198.51855/4877593.1
Case No. 11-cv-01846-LHK (PSG)
DECLARATION OF YOUNGJIN KWON
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DECLARATION OF YOUNGJIN KWON
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I, YoungJin Kwon, do hereby declare as follows:
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1.
I am a Principal Engineer in the Patent & Technology Analysis Group of Samsung
4 Electronics Co., Ltd.’s Mobile Communications Intellectual Property Center. I submit this
5 Declaration in support of Samsung Electronics Co., Ltd’s, Samsung Electronics America, Inc.’s,
6 and Samsung Telecommunications America, LLC’s (“Samsung’s”) and Apple Inc.’s (“Apple’s”)
7 Joint Motion Regarding the Sealing of Trial Exhibits I have personal knowledge of the facts set
8 forth in this Declaration and, if called as a witness, could and would competently testify to them.
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2.
The requested relief in the Motion to Seal is necessary to protect the confidentiality
10 of extremely sensitive source code contained in the parties’ proposed trial exhibits.
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3.
Certain trial exhibits I have reviewed contain highly confidential technical
12 information regarding Samsung's products, including source code that reflects the ideas and efforts
13 of Samsung employees for product design, innovation and development. Source Code is protected
14 within Samsung so that only limited numbers of employees have access and copies cannot be
15 made without proper authorization.
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4.
During this litigation Samsung's source code has been made available for
17 inspection on free standing computers at the offices of Samsung's counsel, with allowances for
18 only a limited number of pages to be printed pursuant to the Protective Order. Additionally,
19 Samsung's source code has only been available to be viewed by Apple's outside counsel and
20 disclosed experts who are not involved competitive decision-making.
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5.
Samsung's source code is confidential and proprietary to Samsung, and the adverse
22 competitive effects on Samsung could be devastating if Samsung's competitors were able to obtain
23 this information because this document was not filed under seal. Competitors would not have to
24 invest the time and resources into developing their own source code for their products, which
25 Samsung had to invest, and use such information in order to compete with Samsung.
26 //
27 //
28 //
02198.51855/4877593.1
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Case No. 11-cv-01846-LHK (PSG)
DECLARATION OF YOUNGJIN KWON
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I declare under penalty of perjury that the forgoing is true and correct to the best of my
2 knowledge. Executed this 27th day of July, 2012, in Suwon, South Korea.
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02198.51855/4877593.1
-3-
Case No. 11-cv-01846-LHK (PSG)
DECLARATION OF YOUNGJIN KWON
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