Apple Inc. v. Samsung Electronics Co. Ltd. et al
Filing
1429
OPPOSITION to ( 1420 MOTION TO ENFORCE COURT ORDERS REGARDING SONY DESIGNS ) filed by Samsung Electronics America, Inc.(a New York corporation), Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC(a Delaware limited liability company). (Attachments: # 1 Declaration of Curran M. Walker, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Exhibit 6, # 8 Exhibit 7, # 9 Exhibit 8, # 10 Exhibit 9, # 11 Exhibit 10, # 12 Exhibit 11, # 13 Exhibit 12, # 14 Exhibit 13)(Maroulis, Victoria) (Filed on 7/28/2012) 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)
charlesverhoeven@quinnemanuel.com
50 California Street, 22nd Floor
San Francisco, California 94111
Telephone: (415) 875-6600
Facsimile: (415) 875-6700
Kevin P.B. Johnson (Bar No. 177129
kevinjohnson@quinnemanuel.com
Victoria F. Maroulis (Bar No. 202603)
victoriamaroulis@quinnemanuel.com
555 Twin Dolphin Drive, 5th Floor
Redwood Shores, California 94065-2139
(650) 801-5000
Telephone:
Facsimile:
(650) 801-5100
Michael T. Zeller (Bar No. 196417)
michaelzeller@quinnemanuel.com
865 S. Figueroa St., 10th Floor
Los Angeles, California 90017
Telephone: (213) 443-3000
Facsimile: (213) 443-3100
Attorneys for SAMSUNG ELECTRONICS CO.,
LTD., SAMSUNG ELECTRONICS AMERICA,
INC. and SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION
APPLE INC., a California corporation,
CASE NO. 11-cv-01846-LHK (PSG)
DECLARATION OF CURRAN M.
WALKER IN SUPPORT OF SAMSUNG'S
OPPOSITION TO APPLE'S MOTION TO
ENFORCE COURT ORDERS
REGARDING SONY DESIGNS
Plaintiff,
vs.
SAMSUNG ELECTRONICS CO., LTD., a
Korean business entity; SAMSUNG
ELECTRONICS AMERICA, INC., a New
York corporation; SAMSUNG
TELECOMMUNICATIONS AMERICA,
LLC, a Delaware limited liability company,
Defendant.
02198.51855/4879464.1
Case No. 11-cv-01846-LHK (PSG)
WALKER DEC. ISO OPP. TO MOTION TO ENFORCE COURT ORDERS RE: SONY DESIGN
1
I, Curran M. Walker, declare as follows:
1.
I am a member of the bar of the State of California and an associate at Quinn
Emanuel Urquhart & Sullivan LLP, attorneys for Samsung Electronics Co., Ltd., Samsung
Electronics America, Inc., and Samsung Telecommunications America, LLC (collectively,
“Samsung”). I make this declaration of personal knowledge and could testify competently to the
facts stated herein.
2.
Attached hereto as Exhibit 1 is a true and correct copy of an email from counsel
for Apple, Kristen Yohannan to counsel for Samsung, Alex Lasher and Eric Huang, copying
others and dated April 18, 2012.
3.
Attached hereto as Exhibit 2 is a true and correct copy of Trial Exhibit 649.
4.
Attached hereto as Exhibit 3 is a true and correct copy of excerpts of the May 2,
2012 deposition of Shin Nishibori.
5.
Attached hereto as Exhibit 4 is a true and correct copy of excerpts of the
November 4, 2011 deposition of Christopher Stringer.
6.
Attached hereto as Exhibit 5 is a true and correct copy of excerpts of the October
27, 2011 deposition of Eugene Whang.
7.
Attached hereto as Exhibit 6 is a true and correct copy of excerpts of the October
31, 2011 deposition of Richard Howarth.
8.
Attached hereto as Exhibit 7 is a true and correct copy of a letter from counsel for
Apple, Jason Bartlett, to counsel for Samsung, Diane Hutnyan, dated February 1, 2012.
9.
Attached hereto as Exhibit 8 is a true and correct copy of Trial Exhibit 562.
10.
Attached hereto as Exhibit 9 is a true and correct copy of excerpts of the February
9, 2012 deposition of Douglas Satzger.
11.
Attached hereto as Exhibit 10 is a true and correct copy of screen shots from Shin
Nishibori's Twitter feed.
12.
Attached hereto as Exhibit 11 is a true and correct copy of a certified translation of
Shin Nishibori's Twitter feed.
02198.51855/4879464.1
13.
Attached hereto as Exhibit 12is a true and correct copy of Trial Exhibit 1.
Case No. 11-cv-01846-LHK (PSG)
WALKER DEC. ISO OPP. TO MOTION TO ENFORCE COURT ORDERS RE: SONY DESIGN
1
14.
Attached hereto as Exhibit 13 is a true and correct copy of a letter from counsel for
2 Samsung, Michael Zeller, to counsel for Apple, Mia Mazza, dated November 8, 2011.
3
15.
Executed July 27, 2012, at San Jose, California.
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/s/ Curran M. Walker
Curran M. Walker
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02198.51855/4879464.1
Case No. 11-cv-01846-LHK (PSG)
-2WALKER DEC. ISO OPP. TO MOTION TO ENFORCE COURT ORDERS RE: SONY DESIGN
1
GENERAL ORDER ATTESTATION
I, Victoria Maroulis, am the ECF user whose ID and password are being used to file the
foregoing document. I hereby attest pursuant to General Order 45.X.B. that concurrence in the
electronic filing of this document has been obtained from Curran Walker.
/s/ Victoria Maroulis
02198.51855/4879464.1
Case No. 11-cv-01846-LHK (PSG)
WALKER DEC. ISO OPP. TO MOTION TO ENFORCE COURT ORDERS RE: SONY DESIGN
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