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

Filing 467

Administrative Motion to File Under Seal filed by Apple Inc.. (Attachments: #1 Exhibit Motion to Compel, #2 Exhibit Mazza Declaration, #3 Exhibit Ex. 1 to Mazza Decl, #4 Exhibit Ex. 2 to Mazza Decl, #5 Exhibit Ex. 3 to Mazza Decl, #6 Exhibit Ex. 4 to Mazza Decl, #7 Exhibit Ex. 5 to Mazza Decl, #8 Exhibit Ex. 6 to Mazza Decl, #9 Exhibit Ex. 7 to Mazza Decl, #10 Exhibit Ex. 8 to Mazza Decl, #11 Exhibit Ex. 9 to Mazza Decl, #12 Exhibit Ex. 10 to Mazza Decl, #13 Exhibit Ex. 11 to Mazza Decl, #14 Exhibit Ex. 12 to Mazza Decl, #15 Exhibit Ex. 13 to Mazza Decl, #16 Exhibit Ex. 14 to Mazza Decl, #17 Exhibit Ex. 15 to Mazza Decl, #18 Exhibit Ex. 16 to Mazza Decl, #19 Exhibit Ex. 17 to Mazza Decl, #20 Exhibit Ex. 18 to Mazza Decl, #21 Proposed Order)(Jacobs, Michael) (Filed on 12/8/2011) Modified on 12/15/2011 (feriab, COURT STAFF). (Attachment 10 replaced on 12/21/2011) (sp, COURT STAFF). (Attachment 16 replaced on 12/21/2011) (sp, COURT STAFF). PURSUANT TO ORDER #523 DOCUMENTS 467-10 AND 467-16 REMOVED. Modified on 12/21/2011 (sp, COURT STAFF).

Exhibit 18

425 MARKET STREET
SAN FRANCISCO
CALIFORNIA 94105-2482
TELEPHONE: [phone]
FACSIMILE: 415.268.7522

MO RRI SO N & F O E RST E R L LP
N E W YO RK , SAN F RAN C I SCO ,
L O S A N G E L E S, P A L O A L T O ,
SAC RAME N T O , SAN D I E G O ,
D E N VE R, N O RT H E RN VI RG I N I A,
WASH I N G T O N , D .C.
T O K YO , L O N D O N , BR U SSE L S,
BE I JI N G , SH AN G H AI , H O N G K O N G

WWW.MOFO.COM

December 6, 2011

Writer’s Direct Contact
415.268.6024
[e-mail]

Via E-Mail ([e-mail])
Marissa Ducca
Quinn Emanuel
555 Twin Dolphin Dr., 5th Floor
Redwood Shores, California 94065
Re:

Apple v. Samsung, Case No. 11-cv-1846-LHK (PSG) (N.D. Cal.)

Dear Marissa:
In connection with upcoming design-related depositions of Samsung witnesses, Apple
requests that Samsung substantially complete its production of the following sketchbooks,
CAD, and physical models on an expedited basis, as follows:
By no later than December 23, 2011, sketchbooks (or similar hand drawings,
however created, stored, or archived) depicting designs for all Galaxy phone and
tablet products, regardless of where sold, whether for a final design or an alternative
design that was not used.
By no later than December 23, 2011, physical models (including mockups,
prototypes, and similar items, however named) for all Galaxy phone and tablet
products, regardless of where sold, whether for a final design or an alternative design
that was not used.
By no later than December 31, 2011, CAD created in connection with the design of
all Galaxy phone and tablet products, regardless of where sold, whether for a final
design or an alternative design that was not used.

sf-3079881

Rachel Herrick Kassabian
December 6, 2011
Page Two
Please let us know during this Wednesday’s meet-and-confer call whether Samsung agrees to
the scope and timing of this limited production.
Sincerely,
/s/ Mia Mazza
Mia Mazza
cc:

Samuel Maselli
S. Calvin Walden
Peter Kolovos

sf-3079881