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 7
425 MARKET STREET
SAN FRANCISCO
CALIFORNIA 94105-2482
U.S.A.
MO RRI SO N & F O E RST E R L LP
TELEPHONE: 415.268.7000
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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
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.
WWW.MOFO.COM
December 7, 2011
Writer’s Direct Contact
415.268.6024
MMazza@mofo.com
Via E-Mail (dianehutnyan@quinnemanuel.com)
Diane Cafferata Hutnyan
Quinn Emanuel
865 South Figueroa St., 10th Floor
Los Angeles, CA 90017
Re:
Apple v. Samsung, Case No. 11-cv-1846-LHK (PSG) (N.D. Cal.)
Dear Diane:
This letter is to confirm, as discussed during the parties’ meet-and-confer discussion this
evening and in previous correspondence, the written commitment that Samsung will need to
make to avoid motion practice at this time:
Samsung will substantially complete, by December 15, 2011, its production of
“Apple” and survey documents, as summarized in sections 3 and 4 of my
December 5, 2011, letter to Rachel Herrick Kassabian;
Samsung will substantially complete, by December 15, 2011, its production of certain
categories of source code and related technical documents, as summarized in my
December 6, 2011, letter to Melissa Chan;
Samsung will substantially complete, by December 23, 2011, its production of
sketchbooks and physical models for Galaxy phone and tablet products, as
summarized in my December 6, 2011, letter to Marissa Ducca; and
Samsung will substantially complete, by December 31, 2011, its production of CAD
created in connection with the design of Galaxy phone and tablet products, as
summarized in my December 6, 2011, letter to Marissa Ducca.
sf-3080794
Diane Cafferata Hutnyan
December 7, 2011
Page Two
Samsung’s commitment to the above scope and timing of substantially complete production
must be provided to Apple in writing no later than noon Pacific time on Thursday,
December 8, 2011. Absent such written confirmation, Apple intends to file, on December 8,
its motion to compel this production, requesting a December 16, 2011, hearing on shortened
time.
Sincerely,
/s/ Mia Mazza
Mia Mazza
cc:
Samuel Maselli
S. Calvin Walden
Peter Kolovos
sf-3080794
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