Apple Inc. v. Samsung Electronics Co. Ltd. et al

Filing 1556

OPPOSITION to ( 1414 JOINT MOTION, 1493 Administrative Motion to File Under Seal , 1499 Administrative Motion to File Under Seal PRIOR MOTIONS AND EXHIBITS THERETO, 1489 Administrative Motion to File Under Seal (Revised), 1328 Administrative Motion to File Under Seal /Non-Party Nokia Corporation's Administrative Motion to File Under Seal, 1396 Administrative Motion to File Under Seal Third Party Confidential Information, 1390 Administrative Motion to File Under Seal Non-Party Microsoft Corporation's Motion to Seal Terms of Confidential License Agreement, 1376 EMERGENCY ADMINISTRATIVE MOTION for a Limited Sealing Order, 1340 Administrative Motion to Partially File Under Seal, 1400 Administrative Motion to File Under Seal (Emergency Motion by Non-Party Motorola Mobility LLC to Seal Exhibits, Close Courtroom and Seal Portions of Transcript), 1495 Administrative Motion to File Under Seal APPLE'S MOTION TO SEAL CONFIDENTIAL TRIAL EXHIBITS, 1506 First Administrative Motion to File Under Seal , 1488 MOTION to Seal Trial Exhibits , 1334 Emergency MOTION for an Order Closing the Courtroom and Sealing the Transcript During Discussion of InterDigital's Confidential Information, 1486 Administrative Motion to File Under Seal Portions of Proposed Trial Exhibit 630, 1490 Administrative Motion to File Under Seal Samsung's Renewed Motion to Seal Dkt. Nos. 927, 991, 1013, 1022, 1060, 1206, 1481 Administrative Motion to File Under Seal , 1498 Administrative Motion to File Under Seal Non-Party Siemens AG's Administrative Motion to Seal ) Third Party Reuters America LLC's Opposition to Motions to Seal Trial and Pretrial Evidence filed byReuters America LLC. (Attachments: # 1 Proposed Order [Proposed] Order Denying Motions to Seal Trial and Pretrial Evidence, # 2 Declaration Declaration of Julie P. Samuels, # 3 Declaration Declaration of Amy Stevens, # 4 Declaration Declaration of Patent Professors)(Olson, Karl) (Filed on 8/2/2012) Modified text on 8/6/2012 (dhm, COURT STAFF).

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KARL OLSON (SBN 104760)
[e-mail]
XINYING VALERIAN (SBN 254890)
[e-mail]
RAM, OLSON, CEREGHINO & KOPCZYNSKI LLP
555 Montgomery Street, Suite 820
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
Attorneys for Third-Party REUTERS AMERICA LLC

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE

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APPLE INC., a California corporation,
Plaintiff,
v.
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,
Defendants.

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CASE NO. 11-cv-01846-LHK
DECLARATION OF AMY STEVENS IN
SUPPORT OF REUTERS’ OPPOSITION
TO MOTIONS TO SEAL TRIAL AND
PRETRIAL EVIDENCE
Date:
Time:
Place:
Judge:

No hearing set
N/A
Courtroom 1, 5th Floor
Hon. Lucy H. Koh

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I, Amy Stevens, declare:

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1.

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I have personal knowledge of the facts set forth below, except as to those stated on

information and belief, and as to those I believe them to be true.
2.

I am employed by Reuters America, LLC as the executive editor, professional

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news. The following is a short summary of my experience: I was a reporter at the Wall Street

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Journal (“WSJ”) from 1990-96; I served in various editing roles for the WSJ from 1996-2000;

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was deputy page one editor of the WSJ from 2001-2003; editor of the Weekend Journal of the

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WSJ from 2004-2006; deputy editor of Conde Nast Portfolio magazine from 2006-2009; and

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have held my current job since June 2010.

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Reuters is the largest independent international news agency in the world. Each day its
news and insight reaches over one billion people, including 430,000 financial professionals

Case No. 11-cv-01846-LHK – DECLARATION OF AMY STEVENS IN SUPPORT OF REUTERS’
OPPOSITION TO MOTIONS TO SEAL TRIAL AND PRETRIAL EVIDENCE

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around the world who subscribe to Thomson Reuters desktop products, hundreds of thousands

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legal and tax and accounting professionals, 35 million visitors to Reuters web sites each month

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and 650 TV clients, 1700 text media clients and 1,000 pictures and graphics clients.

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3.

I am well-acquainted with media coverage of this lawsuit. Business and

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technology reporters from many media organizations are closely following this lawsuit due to the

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widespread interest in the disputes between Apple and various companies, including Samsung,

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that utilize Google’s Android operating system. Mainstream business outlets like the Wall Street

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Journal, Bloomberg and Reuters tend to focus coverage on the case’s strategic impact on the

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companies, including financial risks for shareholders; publications like The Recorder analyze

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legal tactics, and sites like The Verge dig into the technology.
4.

Our organization is providing detailed reporting and analysis on the case because

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our subscribers here in North America and in Asia are interested in the information. Some

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subscribers follow developments in the wireless devices industry, for example. Other subscribers

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are retail and institutional investors who may own stock in Apple, Samsung, or both.

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5.

Our reporting on the case also facilitates a broad discourse on the interesting and

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important issues presented by the case. Our stories, either on Reuters’ own platforms or

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transmitted on the wire, are picked up or otherwise incorporated into the reporting, analysis and

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commentary of many others.

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6.

Although certain colorful aspects of this case (such as Steve Jobs’ supposed

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declaration of “thermonuclear” war on Android) have increased the limelight on the case, Reuters

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believes that the journalistic value of the case derives from having a complete picture of the

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evidence and arguments.

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Our organization, like others in journalism, sees this public and open jury trial as a

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rare opportunity to inform the public about the workings of our justice system, and particularly

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patent law, which has been much in the spotlight because of its use and possible abuse in many

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cases but which may not be well understood by the general public.

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8.

I am informed and believe that the public is particularly interested in this case

because it is a major dispute between corporate giants that are leaders in the most popular

Case No. 11-cv-01846-LHK – DECLARATION OF AMY STEVENS IN SUPPORT OF REUTERS’
OPPOSITION TO MOTIONS TO SEAL TRIAL AND PRETRIAL EVIDENCE

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consumer technologies. Millions of people have smartphones and tablets like the ones at issue in

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this case.

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I am informed and believe that maximum public access to the records in this case

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is important to consumers and investors. The wide coverage and interest in this case supports

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this belief.

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Maximum public access to the records in this case increases public understanding

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of the workings of the court and promotes discussion about patent policy and intellectual property

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trends in general.

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Based on my professional experience, and talking to those Reuters employees who

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have covered Silicon Valley, I do not believe that the level of secrecy and secrecy measures that

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Apple claims to have actually reflects the true level of secrecy at Apple. By way of example, the

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profit margins on Apple’s iPhone and iPad were disclosed last week, and previously other

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websites have published estimates of the cost of its components.

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I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct.
Executed in New York, New York, on August 3, 2012.

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/s/ Amy Stevens
Amy Stevens

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N:\Docs\1273-02\OppMotsSeal4-Stevens Decl-FINAL.doc
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Case No. 11-cv-01846-LHK – DECLARATION OF AMY STEVENS IN SUPPORT OF REUTERS’
OPPOSITION TO MOTIONS TO SEAL TRIAL AND PRETRIAL EVIDENCE

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SIGNATURE ATTESTATION
I hereby attest that I have on file all holograph signatures for any signatures indicated by a

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“conformed” signature (/s/) within this e-filed document.

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Dated: August 2, 2012

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/s/ Karl Olson
Karl Olson (SBN 104760)
RAM, OLSON, CEREGHINO & KOPCZYNSKI
555 Montgomery Street, Suite 820
San Francisco, CA 94111
Tel: [phone]; Fax: [phone]
Email: [e-mail]

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Attorneys for Reuters America LLC

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By:

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Case No. 11-cv-01846-LHK – DECLARATION OF AMY STEVENS IN SUPPORT OF REUTERS’
OPPOSITION TO MOTIONS TO SEAL TRIAL AND PRETRIAL EVIDENCE

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