Apple Inc. v. Samsung Electronics Co. Ltd. et al
Filing
479
MOTION for Leave to File Excess Pages re Samsung's Administrative Motion to Exceed Page Limit in Samsung's Responsive Claim Construction Brief filed by Samsung Electronics America, Inc., Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC. (Attachments: #1 Briggs Declaration, #2 Exhibit 1 to Briggs Declaration, #3 Exhibit 2 to Briggs Declaration, #4 Proposed Order)(Briggs, Todd) (Filed on 12/12/2011)
EXHIBIT 1
Todd Briggs
From:
Sent:
To:
Cc:
Subject:
Ahn, Deok Keun Matthew [DAhn@mofo.com]
Wednesday, December 07, 2011 3:03 PM
Todd Briggs; Samsung v. Apple; Alan Whitehurst; Victoria Maroulis
Jacobs, Michael A.; Monach, Andrew E.; Hung, Richard S. J.; Selwyn, Mark; Stevens,
Bethany; Herriot, Liv; Kreeger, Matthew I.; Kolovos, Peter
RE: Apple v. Samsung -- Claim construction briefs and page limits
Todd,
We intend to adhere to the briefing limits set forth in the local rules.
Matt
From: Ahn, Deok Keun Matthew
Sent: Thursday, December 01, 2011 12:27 PM
To: 'Todd Briggs'; Samsung v. Apple; Alan Whitehurst; Victoria Maroulis
Cc: Jacobs, Michael A.; Monach, Andrew E.; Hung, Richard S. J.; Selwyn, Mark; Stevens, Bethany; Herriot, Liv; Kreeger,
Matthew I.; 'Kolovos, Peter'
Subject: RE: Apple v. Samsung -- Claim construction briefs and page limits
Todd,
As discussed, we are in agreement on the schedule for, and subject matter of, each party's briefs. We'll get back to you
as soon as possible on your page limits proposal.
Matt
From: Todd Briggs [mailto:toddbriggs@quinnemanuel.com]
Sent: Tuesday, November 29, 2011 9:22 PM
To: Todd Briggs; 'Kolovos, Peter'; Kreeger, Matthew I.
Cc: Ahn, Deok Keun Matthew; Alan Whitehurst; Victoria Maroulis; Jacobs, Michael A.; Monach, Andrew E.; Hung, Richard
S. J.; Selwyn, Mark; Stevens, Bethany; Herriot, Liv; Samsung v. Apple
Subject: RE: Apple v. Samsung -- Claim construction briefs and page limits
Peter and Matthew,
I have not heard back from you on my email below. Will you please provide a response tomorrow.
Thanks, Todd
From: Todd Briggs
Sent: Sunday, November 27, 2011 10:56 AM
To: Kolovos, Peter; Kreeger, Matthew I.
Cc: DAhn@mofo.com; Alan Whitehurst; Victoria Maroulis; MJacobs@mofo.com; Monach, Andrew E.; RHung@mofo.com;
Selwyn, Mark; Stevens, Bethany; Herriot, Liv; Samsung v. Apple
Subject: Apple v. Samsung -- Claim construction briefs and page limits
Peter and Matthew,
1
I wanted to follow up on our conversation a few weeks ago regarding claim construction briefs and page
limits. We understand that the claim construction briefs will address the 10 terms identified by the parties as
follows. Please confirm that this is your understanding as well.
12/8 Samsung’s opening brief – addresses the 2 disputed terms from Samsung’s patents
12/8 Apple’s opening brief – addresses the 8 disputed terms from Apple’s patents
12/22 Samsung’s response brief – addresses the 8 disputed terms from Apple’s patents
12/22 Apple’s response brief – addresses the 2 disputed terms from Samsung’s patents
12/29 Samsung’s reply brief – addresses the 2 disputed terms from Samsung’s patents
12/29 Apple’s reply brief – addresses the 8 disputed terms from Apple’s patents
With respect to page limits, we proposed that the parties be allowed to use their page limitations in flexible
way. This will allow both sides to more evenly distribute the total number of pages available under the local
rules to each disputed term. I believe that each party is entitled to a total of 65 pages under the local rules (25
opening/25 response/15 reply). Please let us know if this proposal is acceptable to you. If so, we should file a
stipulation alerting the Court to this agreement.
Best Regards,
Todd Briggs
Partner,
Quinn Emanuel Urquhart & Sullivan, LLP
555 Twin Dolphin Drive, 5th Floor
Redwood Shores, CA 94065
650-801-5020 Direct
650.801.5000 Main Office Number
650.801.5100 FAX
toddbriggs@quinnemanuel.com
www.quinnemanuel.com
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