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

Filing 501

Administrative Motion to File Under Seal filed by Samsung Electronics America, Inc., Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC. (Attachments: # 1 Proposed Order to file under seal, # 2 Declaration of Melissa Chan In Support of Admin Motion, # 3 Declaration In Support of Samsung's Opposition, # 4 Exhibit 1 to Chan Declaration, # 5 Exhibit 2 to Chan Declaration, # 6 Exhibit 3 to Chan Declaration, # 7 Exhibit 4 to Chan Declaration, # 8 Exhibit 5 to Chan Declaration, # 9 Exhibit 6 to Chan Declaration, # 10 Exhibit 7 to Chan Declaration, # 11 Exhibit 8 to Chan Declaration, # 12 Exhibit 9 to Chan Declaration, # 13 Declaration 10 to Chan Declaration, # 14 Exhibit 11 to Chan Declaration, # 15 Exhibit 3 to Jenkins Declaration, # 16 Samsung's Opposition to Apple's Motion to Compel, # 17 Proposed Order Denying Apple's Motion to Compel, # 18 Certificate/Proof of Service)(Maroulis, Victoria) (Filed on 12/15/2011)

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EXHIBIT 3 425 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 FACSIMILE: 415.268.7522 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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