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

Filing 1573

MOTION for Leave to File Reply to 1556 Reuters America LLC's Opposition to Motions to Seal Trial and Pretrial Evidence filed by Qualcomm Incorporated. (Attachments: # 1 Declaration of David A. Kays, # 2 Exhibit A to Declaration of David A. Kays, # 3 Proposed Order, # 4 Certificate/Proof of Service)(Kays, David) (Filed on 8/3/2012) Modified on 8/6/2012 linking entry to document #1556 (dhm, COURT STAFF).

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DAVID KAYS, ESQ. (SBN 120798)
FREEDA LUGO, ESQ. (SBN 244913 )
MORGAN, FRANICH, FREDKIN & MARSH
99 Almaden Boulevard, Suite 1000
San Jose, California 95113-1613
Telephone: [phone]
Facsimile: [phone]
ROGER G. BROOKS, Pro Hac Vice
CRAVATH, SWAIN & MOORE LLP
Worldwide Plaza
825 Eighth Avenue
New York, NY 10019-7475
Telephone: [phone]
Facsimile: [phone]
Attorneys for Non-Party,
QUALCOMM INCORPORATED

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UNITED STATES DISTRICT COURT,

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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APPLE INC., a California corporation,,

Case No. 11-CV-01846-LHK

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Plaintiffs,

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DECLARATION OF DAVID A.
KAYS IN SUPPORT OF NONvs.
PARTY QUALCOMM
INCORPORATED’S MOTION FOR
SAMSUNG ELECTRONICS CO., LTD., a
Korean corporation; SAMSUNG
LEAVE TO FILE REPLY TO
ELECTRONICS AMERICA, INC., a New
REUTERS AMERICA LLC’S
York corporation; and SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC, OPPOSITION TO MOTIONS TO
SEAL TRIAL AND PRETRIAL
a Delaware limited liability company,
EVIDENCE
Defendants.

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I, David A. Kays, hereby declare:
1. I am an attorney with the law firm of Morgan Franich Fredkin & Marsh, counsel for

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Non-Party Qualcomm Incorporated (“Qualcomm”). I make this declaration in

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connection with Qualcomm’s Motion for Leave to File a Reply to Reuters America

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1
Apple, Inc. v. Samsung Electronics, Case No: 11-CV-01846-LHK
DECLARATION OF DAVID A. KAYS IN SUPPORT OF QUALCOMM'S MOTION
FOR LEAVE TO FILE REPLY TO REUTERS OPPO TO MOT. TO SEAL TRIAL AND PRE-TRIAL EVIDENCE

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LLC’s Opposition to Motions to Seal Trial and Pretrial Evidence. I have personal

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knowledge of the matters set forth herein and if called as a witness could

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competently testify thereto.

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2. Attached as Exhibit A is Non-Party Qualcomm Incorporated’s Reply to Third Party

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Reuters America LLC’s Opposition to Motions to Seal Trial and Pretrial Evidence.

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I declare under penalty of perjury under the laws of the State of California that the

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foregoing is true and correct.

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California.

Executed this 3rd day of August 2012, at San Jose,

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/S/
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DAVID KAYS

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2
Apple, Inc. v. Samsung Electronics, Case No: 11-CV-01846-LHK
DECLARATION OF DAVID A. KAYS IN SUPPORT OF QUALCOMM'S MOTION
FOR LEAVE TO FILE REPLY TO REUTERS OPPO TO MOT. TO SEAL TRIAL AND PRE-TRIAL EVIDENCE