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

Filing 42

Declaration of Victoria F. Maroulis in Support of #41 MOTION to Relate Case filed bySamsung Electronics America, Inc., Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E (part 1), #6 Exhibit E (part 2), #7 Exhibit F, #8 Exhibit G, #9 Exhibit H, #10 Exhibit I, #11 Exhibit J, #12 Exhibit K, #13 Exhibit L, #14 Exhibit M)(Related document(s) #41 ) (Maroulis, Victoria) (Filed on 5/11/2011)

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP
Charles K. Verhoeven (Cal. Bar No. 170151)
2 [e-mail]
50 California Street, 22nd Floor
3 San Francisco, California 94111
Telephone: [phone]
4 Facsimile: [phone]
5 Kevin P.B. Johnson (Cal. Bar No. 177129)
[e-mail]
6 Victoria F. Maroulis (Cal. Bar No. 202603)
[e-mail]
th
7 555 Twin Dolphin Drive 5 Floor
Redwood Shores, California 94065
8 Telephone: [phone]
Facsimile: [phone]
9
Michael T. Zeller (Cal. Bar No. 196417)
10 [e-mail]
865 S. Figueroa St., 10th Floor
11 Los Angeles, California 90017
Telephone: [phone]
12 Facsimile: [phone]
13 Attorneys for Samsung Electronics Co., Ltd.,
Samsung Electronics America, Inc. and Samsung
14 Telecommunications America, LLC
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

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APPLE INC., a California corporation,
Plaintiff,

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vs.

SAMSUNG ELECTRONICS CO., LTD., a
21 Korean business entity; SAMSUNG
ELECTRONICS AMERICA, INC., a New
22 York corporation; SAMSUNG
TELECOMMUNICATIONS AMERICA,
23 LLC, a Delaware limited liability company,
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CASE NO. 11-cv-01846-LHK
DECLARATION OF VICTORIA F.
MAROULIS IN SUPPORT OF
SAMSUNG’S CIVIL L.R. 3-12(b)
MOTION TO CONSIDER WHETHER
CASES SHOULD BE RELATED

Defendants.

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02198.51855/4134494.1

Case No. 11-cv-01846-LHK
DECLARATION OF VICTORIA F. MAROULIS IN SUPPORT OF SAMSUNG’S CIVIL L.R. 3-12(b)
MOTION TO CONSIDER WHETHER CASES SHOULD BE RELATED

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I, Victoria F. Maroulis, declare:

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1.

I am a partner in the law firm of Quinn Emanuel Urquhart & Sullivan, LLP,

3 counsel for Samsung Electronics Co., Ltd., Samsung Electronics America, Inc., and Samsung
4 Telecommunications America, LLC (collectively "Samsung"). I have personal knowledge of the
5 facts set forth in this declaration and, if called upon as a witness, I could and would testify to such
6 facts under oath.
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2.

On May 6, 2011, I e-mailed counsel for Apple, Inc. (“Apple”) asking whether

8 Apple would join Samsung in filing a joint motion to consider related this case and Samsung
9 Electronics Co., Ltd. and Samsung Telecommunications America, LLC v. Apple, Inc. (Case No.
10 11-cv-02079-EDL) (N.D. Cal. April 27, 2011) (the "Samsung Action"). I attached to this email a
11 draft of such joint motion and a draft stipulation in support of the motion. I requested that counsel
12 for Apple let me know by Monday, May 9 whether Apple would join such a motion.
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3.

On May 10, 2011, counsel for Apple replied to my e-mail, indicating that Apple

14 would oppose a motion to consider related this case and the Samsung Action.
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4.

Attached hereto as Exhibit A is a true and correct copy of the complaint filed in the

16 Samsung Action.
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5.

Attached hereto as Exhibit B is a true and correct copy of Exhibit 1 to the

18 complaint filed in the Samsung Action.
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6.

Attached hereto as Exhibit C is a true and correct copy of Exhibit 2 to the

20 complaint filed in the Samsung Action.
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7.

Attached hereto as Exhibit D is a true and correct copy of Exhibit 3 to the

22 complaint filed in the Samsung Action.
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8.

Attached hereto as Exhibit E is a true and correct copy of Exhibit 4 to the

24 complaint filed in the Samsung Action.
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9.

Attached hereto as Exhibit F is a true and correct copy of Exhibit 5 to the complaint

26 filed in the Samsung Action.
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10.

Attached hereto as Exhibit G is a true and correct copy of Exhibit 6 to the

28 complaint filed in the Samsung Action.
02198.51855/4134494.1

Case No. 11-cv-01846-LHK
-1DECLARATION OF VICTORIA F. MAROULIS IN SUPPORT OF SAMSUNG’S CIVIL L.R. 3-12(b)
MOTION TO CONSIDER WHETHER CASES SHOULD BE RELATED

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11.

Attached hereto as Exhibit H is a true and correct copy of Exhibit 7 to the

2 complaint filed in the Samsung Action.
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12.

Attached hereto as Exhibit I is a true and correct copy of Exhibit 8 to the complaint

4 filed in the Samsung Action.
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13.

Attached hereto as Exhibit J is a true and correct copy of Exhibit 9 to the complaint

6 filed in the Samsung Action.
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14.

Attached hereto as Exhibit K is a true and correct copy of Exhibit 10 to the

8 complaint filed in the Samsung Action.
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15.

Attached hereto as Exhibit L is a true and correct copy of the e-mail I sent to

10 counsel for Apple on May 6, 2011.
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16.

Attached hereto as Exhibit M is a true and correct of the May 10, 2011 e-mail that I

12 received from counsel for Apple.
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I declare under penalty of perjury that the foregoing is true and correct. Executed in

14 Redwood Shores, California on May 11, 2011.
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By /s/ Victoria F. Maroulis
Victoria F. Maroulis

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02198.51855/4134494.1

Case No. 11-cv-01846-LHK
-2DECLARATION OF VICTORIA F. MAROULIS IN SUPPORT OF SAMSUNG’S CIVIL L.R. 3-12(b)
MOTION TO CONSIDER WHETHER CASES SHOULD BE RELATED