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 4

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November 23, 2011

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By Email ([e-mail])
Rachel Herrick Kassabian
Quinn Emanuel
555 Twin Dolphin Dr., 5th Floor
Redwood Shores, CA 94065
Re:

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

Dear Rachel:
I write to confirm the parties’ agreement to take this week’s meet-and-confer call off
calendar in light of the Thanksgiving holiday. Please note that Apple expects to receive at
least the following documents and information from Samsung no later than the evening
before the next meet-and-confer call (on November 30), as discussed on our call of
November 16 and in recent correspondence:
Samsung’s redline of the reciprocity charts attached to Wes Overson’s letters of
November 10 and November 22 labeled “Exhibit A” and “Exhibit B;”
A response to Wes Overson’s letter of November 9 identifying source code and other
technical documents related to the accused features that Samsung has not produced
but that Apple is entitled to receive, and designation of a date certain by which
Samsung’s production of the listed items will be substantially complete;
Substantially complete production of documents referencing “Apple” from “each of
Samsung[‘s] designers of Samsung’s Galaxy S 4G and Infuse 4G, Droid Charge
phones, and Galaxy Tab 10.1 table computer identified in Samsung’s Rule 26(a)
disclosures or interrogatory responses” (language taken from the Court’s Order of
September 28, 2011);
Substantially complete production of survey documents pursuant to the Court’s
September 28th Order;
Full and complete supplemental responses to Interrogatories 2 through 6;

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Rachel Herrick Kassabian
November 23, 2011
Page Two
Full and complete supplemental responses to Preliminary Injunction Interrogatories
12 through 14;
Designation of a date certain by which Samsung’s production of standards-related
documents will be substantially complete;
A response to Sam Maselli’s November 15 letter regarding Samsung’s overbroad
assertions of privilege; and
A response to Apple’s proposal that each party agree to notify the other party in
advance where possible when they become aware that productions are going to be
untimely.

Sincerely,
/s/ Mia Mazza
Mia Mazza

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