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

Filing 223

DECLARATION of Jason R. Bartlett in Support of Opposition to #205 MOTION to Compel Request for Production No. 1 and Interrogatory Nos. 1, 3, and 6 (Public Redacted Version) filed by Apple Inc.. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Exhibit J)(Related document(s) #205 ) (Bartlett, Jason) (Filed on 9/12/2011) Modified text on 9/13/2011 (dhm, COURT STAFF).

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Exhibit F Behind Samsung's Tablet Redesign: We Won't Be Outdone By Apple - Forbes ◦ ◦ ◦ ◦ ◦ ◦ ◦ Global 2000 Leading Companies Largest Private Companies Most Expensive Zip Codes 100 Most Powerful Women World's Billionaires World's Most Powerful People All Lists Help | Login | SignUp Search news, business le Submit Query Free Issue > Protecting Your Wealth Best Business Schools How To Escape From A Bear World's Billionaires Elizabeth Woyke, Forbes Staff From smartphones to tablets, Wi-Fi to 3G/4G: I cover telecom & mobile. + Follow http://www.forbes.com/sites/elizabethwoyke/2011/03/22/behind-samsungs-tablet-redesign-... 9/7/2011 Behind Samsung's Tablet Redesign: We Won't Be Outdone By Apple - Forbes Tech | 3/22/2011 @ 4:25PM |3,309 views Behind Samsung's Tablet Redesign: We Won't Be Outdone By Apple Most Popular • • • • News People Places Companies • Larry Ellison and Marc Benioff Just Can't Agree: What Is the Cloud? +17,989 views • Obama's Economic Trifecta: How The President Helped Kill Progressivism, Capitalism And Moderation +17,740 views • For Yahoo, It Looks The Beginning Of The End +16,407 views • Sean "Day[9]" Plott Talks Starcraft, eSports and Nerd Pride +11,796 views • Why Lil Wayne's 'Carter IV' Outsold Jay-Z and Kanye's 'Throne' +11,294 views • Will Sallie Krawcheck's Replacement Send Merrill Lynch Brokers Sprinting? +10,568 views • Korean Choi "Bomber" Ji Sung Discusses the Future of Pro Gaming in America +6,372 views • Yahoo: Will They Ever Actually Name Another CEO? +5,894 views • Nvidia's Phone Strength May Be Underestimated +5,485 views • Two Bottles That Changed The World +4,888 views http://www.forbes.com/sites/elizabethwoyke/2011/03/22/behind-samsungs-tablet-redesign-... 9/7/2011 Behind Samsung's Tablet Redesign: We Won't Be Outdone By Apple - Forbes + show more Elizabeth Woyke Forbes Staff + Follow + show more Technology is going mobile and I'm here to cover the shift. En route to the Forbes gadget beat, I worked at Business Week, Time Asia and Random House. I also lived in South Korea and Hong Kong, where I quickly acquired a taste for fast broadband and sleek phones. Now I'm a staff writer focusing on telecom and mobile devices but with an interest in policy, e-commerce, location-based services and manufacturing/supply chain issues, among other topics. I like to think of my beat as technology that touches (nearly) everyone. Let me know your thoughts at ewoyke@forbes.com or @ewoyke on Twitter Elizabeth Woyke’s Popular Posts • • • • When Reddit Attacks 49,855 views Why Sprint/Samsung's Epic 4G Phone Costs $50 More Than The IPhone Or EVO 36,393 views $240 To Place Story On Digg Front Page: One Marketing Firm's Pitch 27,096 views Verizon iPhone Event Live Blog 21,082 views More from Elizabeth Woyke • Follow Elizabeth on Twitter • Elizabeth’s RSS Feed • Elizabeth’s Profile Elizabeth’s News Stream Show all activity (20) 6 • Comment 3 hours ago Right, that's because he didn't specify how he was defining it [...] http://www.forbes.com/sites/elizabethwoyke/2011/03/22/behind-samsungs-tablet-redesign-... 9/7/2011 Behind Samsung's Tablet Redesign: We Won't Be Outdone By Apple - Forbes on Nvidia CEO: Quad-Core Tablets Coming By End Of Year • New Post 6 hours ago Debate Over Warrantless Cellphone Searches Heats Up • • • • • Subscribe to Forbes Get a Free Trial Issue • • • • • • Your Name Address City State 6 Zip E-mail Subscribe Submit Forbes Subscriptions • Subscribe To Newsletter • Subscribe To Magazine • Subscriber Customer Service http://www.forbes.com/sites/elizabethwoyke/2011/03/22/behind-samsungs-tablet-redesign-... 9/7/2011 Behind Samsung's Tablet Redesign: We Won't Be Outdone By Apple - Forbes 9 68 33 0 0 When Steve Jobs misquoted a Samsung executive at the early March launch of the iPad 2, Samsung declined to comment on the slight. Instead, it rapidly redesigned its tablets to be even thinner than Apple’s widely-admired device. On Tuesday, when Samsung unveiled the new tablets at the CTIA Wireless trade show in Orlando, the message was clear: Samsung would defend itself through its products, not words. Even in the fast-paced gadget industry, it’s rare to rework a product that has already been unveiled. It’s even rarer to do it in the space of a few weeks. In the case of its Galaxy Tab 10.1, so named because it sports a 10.1-inch screen, Samsung did both. Through a few hardware changes, Samsung http://www.forbes.com/sites/elizabethwoyke/2011/03/22/behind-samsungs-tablet-redesign-... 9/7/2011 Behind Samsung's Tablet Redesign: We Won't Be Outdone By Apple - Forbes compressed the device, which was first introduced at the Mobile World Congress trade show in midFebruary, to a width of 8.6 millimeters. The iPad 2, in comparison, is 8.8 millimeters thick. In an interview at CTIA, Samsung executives confirmed that they reworked their newest tablets in response to the iPad 2. In typical Samsung fashion, however, they refrained from actually mentioning Apple in their responses. “Samsung is determined to outperform and become the world’s leader in any area,” said Young-Hee Lee, the company’s vice president of marketing, who also happens to be the executive that was misquoted at the iPad 2 launch. This “never-stop spirit” “accelerated the evolution” of the Galaxy Tab after the iPad 2 was announced, Lee added. Omar Khan, the Chief Product Officer of Samsung’s mobile division, said the company’s philosophy was ‘We’re not going to be outdone.” Outdone by anyone, yes; but, specifically by Apple. The second tablet Samsung announced Monday, an 8.9-inch Galaxy Tab, is equally slim and weighs 470 grams. It, too, likely benefited from a quick redesign. After all, Samsung’s original, 7-inch Galaxy Tab, which launched last fall, is 11.4 millimeters thick. Khan declined to confirm that point, noting, “The 8.9 Galaxy Tab was never announced before, so there was nothing to modify.” How did Samsung squeeze more than two millimeters of bulk and four grams of weight out of the Galaxy Tab 10.1 in the space of several weeks? It turned to technology that was already in its labs — though not yet commercialized. “We went back to the drawing board,” acknowledged Khan. But since Samsung “spends billions on research and development annually”, the “innovations necessary” to enable the company to redesign 10.1 were ready, said Khan. Samsung prefers to remain vague about the exact nature of those innovations. But it’s clear that it will continue tweaking the tablets up until they actually go on sale, in early June for the 10.1 and “early summer” for the 8.9 version. “We’re always looking for better options…and to outperform the industry standard,” said Lee. If Samsung identifies any other “improvement points” before the summer launch, the company will adjust its tablets again, she added. Who will get these sleeker tablets? All U.S. consumers and most global consumers. Samsung has a deal with UK-based carrier Vodafone to launch the Galaxy Tab 10.1 before other operators get access. Lee said Samsung is honoring that agreement and currently hashing out which version of the tablet Vodafone will sell. U.S. consumers will get the thinner Tab in early June, according to Khan. Though Samsung did not showcase any phones at its CTIA press conference, it does have a new handset, on Sprint — a 4G version of the Nexus S Android phone that originally launched on TMobile USA last year. The company’s new flagship smartphone, the Galaxy S II, which was announced at Mobile World Congress in February, will also be coming to the U.S., said Khan. Related Posts: • Intersolar 2011 • Ford's New Business: Solar 9 68 33 http://www.forbes.com/sites/elizabethwoyke/2011/03/22/behind-samsungs-tablet-redesign-... 9/7/2011

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