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

Filing 387

Declaration of Melissa Chan in Support of #258 Opposition/Response to Motion, filed bySamsung Electronics America, Inc., Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8, #9 Exhibit 10, #10 Exhibit 11, #11 Exhibit 12, #12 Exhibit 13, #13 Exhibit 14, #14 Exhibit 15, #15 Exhibit 16, #16 Exhibit 17, #17 Exhibit 18, #18 Exhibit 19, #19 Exhibit 20, #20 Exhibit 21, #21 Exhibit 22)(Related document(s) #258 ) (Maroulis, Victoria) (Filed on 11/9/2011)

EXHIBIT 2

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HAROLD J. MCELHINNY (CA SBN 66781)
[e-mail]
MICHAEL A. JACOBS (CA SBN 111664)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: [phone]

KENNETH H. BRIDGES (CA SBN 243541)
[e-mail]
MICHAEL T. PIEJA (CA SBN 250351)
[e-mail]
BRIDGES & MAVRAKAKIS LLP
3000 El Camino Real
One Palo Alto Square, 2nd Floor
Palo Alto, CA 94306
Telephone: [phone]
Facsimile: [phone]

MARK D. SELWYN (SBN 244180)
[e-mail]
WILMER CUTLER PICKERING
HALE AND DORR LLP
950 Page Mill Road
Palo Alto, California 94304
Telephone: [phone]
Facsimile: [phone]
WILLIAM F. LEE (pro hac vice anticipated)
[e-mail]
WILMER CUTLER PICKERING
HALE AND DORR LLP
60 State Street
Boston, MA 02109
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
APPLE INC.

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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,
Plaintiff,

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v.
SAMSUNG ELECTRONICS CO., LTD., a
Korean corporation; SAMSUNG
ELECTRONICS AMERICA, INC., a New
York corporation; and SAMSUNG
TELECOMMUNICATIONS AMERICA,
LLC, a Delaware limited liability company,

Case No. 11-cv-01846-LHK
APPLE INC.’S INTERROGATORIES TO
DEFENDANTS RELATING TO APPLE’S
MOTION FOR A PRELIMINARY
INJUNCTION – SET ONE

Defendants.

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APPLE INC.’S INTERROGATORIES TO DEFENDANTS RELATING TO APPLE’S MOTION FOR PI – SET ONE
CASE NO. 11-CV-01846-LHK
sf-3017834

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APPLE INC. (“Apple”) hereby requests, pursuant to Rules 26 and 33 of the Federal Rules

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of Civil Procedure, that SAMSUNG ELECTRONICS CO., LTD.; SAMSUNG ELECTRONICS

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AMERICA, INC.; and SAMSUNG TELECOMMUNICATIONS AMERICA, LLC,

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(“Defendants”) respond to Apple’s Interrogatories Relating to Apple’s Motion for a Preliminary

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Injunction. Apple requests that Defendants answer each interrogatory below and serve their

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answers on Apple’s counsel at the offices of Morrison & Foerster, LLP, 425 Market St., San

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Francisco, CA 94105-2482 within fourteen (14) days, or such other time as the parties agree or

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the Court orders.

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DEFINITIONS
The words and phrases used in these Requests shall have the meanings ascribed to them

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under the Federal Rules of Civil Procedure and the Local Rules of the United States District

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Court for the Northern District of California. In addition, the following terms shall have the

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meanings set forth below whenever used in any Request.

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1.

“You” and/or “your” mean Defendants and all predecessors, successors,

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predecessors-in-interest, successors-in-interest, subsidiaries, divisions, parents, and/or affiliates,

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past or present, any companies that have a controlling interest in Defendants, and any current or

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former employee, officer, director, principal, agent, consultant, sales representative, or attorney

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thereof.

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2.

“Products at Issue” means the Samsung Galaxy S 4G, Infuse 4G, Droid Charge,

and Galaxy Tab 10.1, as released anywhere in the world.
3.

“Document(s)” has the broadest possible meaning permitted by Federal Rules of

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Civil Procedure Rules 26, 33 and 34 and the relevant case law. “Document(s)” also includes all

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drafts or non-final versions, alterations, modifications, and amendments to any of the foregoing.

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4.

“Identify” means (1) when referring to a person, the person’s full name, present or

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last known address and telephone number, and the last known title and place of employment; (2)

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when referring to nonpatent documents, the production number or type of document, its general

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nature and subject matter, date of creation, and all author(s), addresses(s), and recipient(s); and

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(3) when referring to patent documents, the country, patent and/or application number, dates of
APPLE INC.’S INTERROGATORIES TO DEFENDANTS RELATING TO APPLE’S MOTION FOR PI – SET ONE
CASE NO. 11-CV-01846-LHK
sf-3017834

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filing, publications, and grant, and the names of patentees or applicants.

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INTERROGATORIES
INTERROGATORY NO. 1:
For each of the Products at Issue, describe any analysis, review, consideration, or copying

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of, or comparison against, any Apple product or product feature in designing or developing, or

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implementing a feature on, the Product at Issue, and identify all documents and things relating to

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your response, and any persons with knowledge regarding your response.

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Dated: July 12, 2011

MORRISON & FOERSTER LLP

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By:

/s/ Richard S.J. Hung
RICHARD S.J. HUNG
Attorneys for Defendant
APPLE INC.

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APPLE INC.’S INTERROGATORIES TO DEFENDANTS RELATING TO APPLE’S MOTION FOR PI – SET ONE
CASE NO. 11-CV-01846-LHK
sf-3017834

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CERTIFICATE OF SERVICE

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I, Deok Keun Matthew Ahn, hereby certify that on July 12, 2011, true and correct

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copies of the foregoing document were served on the following counsel of record at the

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addresses and in the manner indicated:

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VIA ELECTRONIC MAIL

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Charles K. Verhoeven
[e-mail]
Quinn Emanuel Urquhart Oliver & Hedges, LLP
50 California Street, 22nd Floor
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]

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Kevin P.B. Johnson
[e-mail]
Victoria F. Maroulis
[e-mail]
Quinn Emanuel Urquhart Oliver & Hedges, LLP
555 Twin Dolphin Drive 5th Floor
Redwood Shores, California 94065
Telephone: [phone]
Facsimile: [phone]
Edward J. DeFranco
[e-mail]
Quinn Emanuel Urquhart Oliver & Hedges, LLP
335 Madison Avenue, 22nd Floor
New York, NY 10017
Telephone: [phone]
Facsimile: [phone]
Michael Thomas Zeller
[e-mail]
Quinn Emanuel Urquhart Oliver & Hedges, LLP
865 S. Figueroa Street, 10th Floor
Los Angeles, CA 90017
Telephone: [phone]
Facsimile: [phone]

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I declare under the penalty of perjury that the foregoing is true and correct.
/s/ Deok Keun Matthew Ahn
Deok Keun Matthew Ahn

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CERTIFICATE OF SERVICE
CASE NO. 4:11-CV-1846-LHK
sf-3019402