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).

EXHIBIT 13

quinn emanuel

trial lawyers | los angeles

865 South Figueroa Street, 10th Floor, Los Angeles, California 90017-2543 | TEL: [phone] FAX: [phone]

November 8, 2011
VIA ELECTRONIC MAIL
Mia Mazza
Morrison & Foerster
425 Market Street
San Francisco, California 94105-2482
Re:

Apple v. Samsung Elecs. Co. et al., Case No. 11-cv-1846 LHK (N.D. Cal.)

Dear Mia:
It has come to Samsung's attention that Apple generated designs based on Sony's design
language and created actual, three-dimensional models of these designs. See October 27, 2011
Deposition of Eugene Whang at 88:10-92:19; documents bearing production numbers APLNDCNCC00000200-217; APLNDC0000038109-38166; APLNDC0000038016-38040; October 31,
2011 Deposition of Richard Howarth at 17:23-26:25. Please produce the documents related to
the Sony design exercise/investigation, including but not limited to the notebooks, diagrams,
progress reports, studies, internal memoranda, contracts for services, and communications that
reflect Sony designs or that include the name or logo of Sony (or “Jony”), depictions of Sony
products, or references to Sony’s design language. Please also produce the physical models that
Apple created of the designs generated from this exercise/investigation. These materials are
responsive to at least Samsung's Request for Production Nos. 16 and 98.
Also, it appears Apple created designs based on other smart phones, including but not limited to
the Treo and the Razr. See, e.g., documents bearing productions numbers APLNDC0000036646,
36657, 36892, 37167, 37177. Please produce the documents related to these
exercises/investigations, including but not limited to the notebooks, diagrams, progress reports,
quinn emanuel urquhart & sullivan, llp
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studies, internal memoranda, contracts for services, and communications that include the names
or logos of these and all other prior art smart phones. Please also produce the physical models or
prototypes created in connection with these exercises/investigations.
Very truly yours,
/s/
Michael T. Zeller

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