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

Filing 473

RESPONSE (re #464 MOTION to Shorten Time Apple's Motion to Shorten Time for Briefing and Hearing on Apple's Motion to Compel Production of Documents and Things ) filed bySamsung Electronics America, Inc., Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC. (Attachments: #1 Declaration Declaration of Melissa N. Chan, #2 Exhibit Exhibit 1 to the Chan Declaration, #3 Exhibit Exhibit 2 to the Chan Declaration, #4 Exhibit Exhibit 3 to the Chan Declaration, #5 Proposed Order Proposed Order)(Maroulis, Victoria) (Filed on 12/9/2011)

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December 7, 2011

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Via E-Mail ([e-mail])
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.

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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

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