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).

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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 15 16 UNITED STATES DISTRICT COURT 17 NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION 18 19 APPLE INC., a California corporation, Plaintiff, 20 21 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, 25 Defendants. 26 27 28 02198.51855/4877593.1 Case No. 11-cv-01846-LHK (PSG) DECLARATION OF YOUNGJIN KWON 1 DECLARATION OF YOUNGJIN KWON 2 I, YoungJin Kwon, do hereby declare as follows: 3 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. 9 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. 11 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. 16 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. 21 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 -2- Case No. 11-cv-01846-LHK (PSG) DECLARATION OF YOUNGJIN KWON 1 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. 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 02198.51855/4877593.1 -3- Case No. 11-cv-01846-LHK (PSG) DECLARATION OF YOUNGJIN KWON

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