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 7

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February 1, 2012

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By Email ([e-mail])
Diane Hutnyan
Quinn Emanuel
865 Figueroa St., 10th Floor
Los Angeles, CA 90017
Re:

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

Dear Diane:
I write in response to your January 24, 2012 letter regarding Brain Box, Apple Cinema
Display, Sony, Treo/Razr, and Phillips receiver test reports.
Pursuant to the Court’s December 22 Order (Dkt. No. 536), Apple searched for and produced
documents and things relating to 1) investigations into other smartphone designs and
languages, if any, and 2) earlier Apple flat panel and Apple Cinema display models.
Before January 15, Apple ran searches for the keywords “Sony,” “Treo,” “Razr,” “Philips,”
“Phillips,” and “brain box” against documents and email collected from Industrial Design
inventors and produced any responsive hits.
Apple searched in its model database for “Treo,” “Razr,” and “brain box” and did not find
any responsive hits. Apple searched in its model database for “Sony” and found only a small
number of hits related to released iPhone projects, and thereafter, Apple produced for
inspection all Industrial Design models from released iPhone, iPad and iPod touch projects.
Apple also produced any models that hit “Philips” or “Phillips” in the database, as well as all
prior art Apple Cinema Display models and CAD, as noted in my January 13 letter. Your
letter acknowledges the Apple Cinema Display model and CAD production.
Apple’s search of Industrial Design inventor documents and emails included all of the search
terms proposed in your December 30 letter with the following exceptions:

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Diane Hutnyan
February 1, 2012
Page Two
cinema
Apple did not execute a search for the overbroad “cinema” term by itself,
which a test search immediately revealed would return a substantial volume of wholly
irrelevant material such as discussions of foreign cinema. Instead, Apple searched
the phrase “cinema display.”
“Jony” within 50 of *phone*
This proposed search phrase is overbroad on its face
and not reasonably directed at any design investigation.
Sincerely,
/s/ Jason R. Bartlett
Jason R. Bartlett
cc:

Samuel Maselli
S. Calvin Walden
Peter Kolovos

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