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

Filing 1557

Declaration of Xinying Valerian in Support of 1556 Opposition/Response to Motion,,,,,,,, filed byReuters America LLC. (Attachments: # 1 Exhibit A to Declaration of Xinying Valerian, # 2 Exhibit B to Declaration of Xinying Valerian, # 3 Exhibit C to Declaration of Xinying Valerian, # 4 Exhibit D to Declaration of Xinying Valerian, # 5 Exhibit E to Declaration of Xinying Valerian, # 6 Exhibit F to Declaration of Xinying Valerian, # 7 Exhibit G to Declaration of Xinying Valerian)(Related document(s) 1556 ) (Olson, Karl) (Filed on 8/2/2012)

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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 XINYING
VALERIAN 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, Xinying Valerian, declare:

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1.

I am an attorney with the law firm of Ram, Olson, Cereghino & Kopczynski, LLP,

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counsel for Reuters America, LLC. I am licensed to practice law in the State of California. I

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have personal knowledge of the matters stated herein.

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2.

Attached as Exhibit A hereto is a printout of a Reuters article dated July 26, 2012

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from the Internet, “Apple U.S. margins for iPad about half of iPhone,” which is accessible at the

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URL, http://www.reuters.com/article/2012/07/26/us-apple-margins-idUSBRE86P1NI20120726

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(last visited August 2, 2012).

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3.

Attached as Exhibit B hereto is a printout of a Forbes article dated July 29, 2012

from the Internet, “Why Are Apple's iPad Margins Half The iPhone Ones?,” available at

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

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http://www.forbes.com/sites/timworstall/2012/07/29/why-are-apples-ipad-margins-half-the-

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iphone-ones/ (last visited August 2, 2012).

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4.

Attached as Exhibit C hereto is a Apple’s 3rd Quarter 2012 data summary which I

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downloaded from the Press Releases section of Apple’s website containing the July 24, 2012

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earnings release, at http://www.apple.com/pr/library/2012/07/24Apple-Reports-Third-Quarter-

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Results.html (last visited August 2, 2012).

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5.

Attached as Exhibit D hereto is a printout from the Internet which provides a

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“Preliminary Bill of Materials (BOM) Cost Analysis” for the 3rd Generation iPad. The URL is

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http://www.isuppli.com/Teardowns/News/pages/New-iPad-32-GB-4G-Carries-364-35-Bill-of-

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Materials.aspx (last visited August 2, 2012).

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6.

Attached as Exhibit E hereto is a printout from a July 31, 2012 article from the

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online tech magazine The Verge, “Nearly 40 iPhone and iPad prototypes revealed in Samsung

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trial,” available at http://www.theverge.com/2012/7/31/3209913/apple-iphone-ipad-prototypes-

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new-samsung-trial-pictures (last visited August 2, 2012). According to this webpage as of my

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last visit, there were 335 comments. Here I include only pages 1 and 2 containing the main

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article and I omit the public comments, which span over 50 printed pages.

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7.

Attached as Exhibit F hereto is a printout of a Wall Street Journal article dated

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July 26, 2012, “Turns Out Apple Conducts Market Research After All,” available at

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http://blogs.wsj.com/digits/2012/07/26/turns-out-apple-conducts-market-research-after-all/ (last

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visited August 2, 2012).

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8.

Attached as Exhibit G hereto is a printout of a press release “Strong Demand for

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Smartphones in Second Quarter Continues to Drive the Worldwide Mobile Phone Market,

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According to IDC,” July 26, 2012, from the website of International Data Corporation (IDC).

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The URL is http://www.idc.com/getdoc.jsp?containerId=prUS23624612 (last visited August 2,

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2012).

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I declare under penalty of perjury that the foregoing is true and correct. Executed in San
Francisco, California on August 2, 2012.
/s/ Xinying Valerian
Xinying Valerian

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

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