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

Filing 594

REPLY (re #405 MOTION to Dismiss Apple's Amended Counterclaims ) filed bySamsung Electronics America, Inc.(a New York corporation), Samsung Electronics Co. Ltd.(a Korean corporation), Samsung Telecommunications America, LLC(a Delaware limited liability company). (Attachments: #1 Declaration of Remy Libchaber, #2 Declaration of Alex Baxter, #3 Exhibit 1 of Baxter Declaration, #4 Exhibit 2 of Baxter Declaration, #5 Exhibit 3 of Baxter Declaration, #6 Exhibit 4 of Baxter Declaration)(Maroulis, Victoria) (Filed on 1/9/2012)

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP
Charles K. Verhoeven (Bar No. 170151)
[e-mail]
2
50 California Street, 22nd Floor
3 San Francisco, California 94111
Telephone: [phone]
4 Facsimile: [phone]
5

Kevin P.B. Johnson (Bar No. 177129)
[e-mail]
Victoria F. Maroulis (Bar No. 202603)
6
[e-mail]
555 Twin Dolphin Drive, 5th Floor
7
Redwood Shores, California 94065-2139
[phone]
8 Telephone:
Facsimile:
[phone]
9
10

Michael T. Zeller (Bar No. 196417)
[e-mail]
865 S. Figueroa St., 10th Floor
11
Los Angeles, California 90017
12 Telephone: [phone]
Facsimile: [phone]
13
14 Attorneys for SAMSUNG ELECTRONICS CO.,
LTD., SAMSUNG ELECTRONICS AMERICA,
15 INC. and SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC
16
17

UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

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20 APPLE INC., a California corporation,

CASE NO. 11-cv-01846-LHK

21

DECLARATION OF ALEX BAXTER IN
SUPPORT OF DEFENDANT SAMSUNG’S
REPLY MEMORANDUM

22

Plaintiff,
vs.

23 SAMSUNG ELECTRONICS CO., LTD., a
Korean business entity; SAMSUNG
24 ELECTRONICS AMERICA, INC., a New
York corporation; SAMSUNG
25 TELECOMMUNICATIONS AMERICA,
LLC, a Delaware limited liability company,
26
Defendant.
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Date:
Time:
Place:
Judge:

April 5, 2012
1:30 p.m.
Courtroom 4, 5th Floor
Hon. Lucy H. Koh

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02198.51855/4540340.1

Case No. 11-cv-01846-LHK
DECLARATION OF ALEX BAXTER

1

I, Alex Baxter, declare:

2

1.

I am an associate in the law firm of Quinn Emanuel Urquhart & Sullivan, LLP,

3 counsel for Samsung Electronics Co., Ltd., Samsung Electronics America, Inc., and Samsung
4 Telecommunications America, LLC (collectively “Samsung”). I have personal knowledge of the
5 facts set forth in this declaration and, if called upon as a witness, I could and would testify to such
6 facts under oath.
7

2.

Attached hereto as Exhibit 1 is a true and correct copy of an IPR Information

8 Statement and Licensing Declaration, issued by Samsung to the European Telecommunications
9 Standards Institute (“ETSI”) and dated September 19, 2003. This copy of this statement was
10 produced by Apple with Bates Numbers APLNDC-WH-A 0000009375-9396.
11

3.

Attached hereto as Exhibit 2 is a true and correct copy of an IPR Information

12 Statement and Licensing Declaration, issued by Samsung to ETSI and dated May 16, 2006. This
13 copy of this statement was produced by Apple with Bates Numbers APLNDC-WH-A
14 0000009415-9431.
15

4.

Attached hereto as Exhibit 3 is a true and correct copy of an IPR Information

16 Statement and Licensing Declaration, issued by Samsung to ETSI and dated July 8, 2007. This
17 copy of this statement was produced by Apple with Bates Numbers APLNDC-WH-A
18 0000009442-9446.
19

5.

Attached hereto as Exhibit 4 is a true and correct copy of an IPR Information

20 Statement and Licensing Declaration, issued by Samsung to ETSI and dated July 24, 2008. This
21 copy of this statement was produced by Apple with Bates Numbers APLNDC-WH-A
22 0000009482-9486.
23

I declare under penalty of perjury that the foregoing is true and correct. Executed in

24 Redwood Shores, California on January 9, 2012.
25
26
27

/s/ Alex Baxter

28

Alex Baxter

02198.51855/4540340.1

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Case No. 11-cv-01846-LHK
DECLARATION OF ALEX BAXTER

1 GENERAL ORDER ATTESTATION
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I, Victoria Maroulis, am the ECF user whose ID and password are being used to file the
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foregoing document. I hereby attest pursuant to General Order 45.X.B. that concurrence in the
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electronic filing of this document has been obtained from Alex Baxter.
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/s/ Victoria Maroulis
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02198.51855/4540340.1

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Case No. 11-cv-01846-LHK
DECLARATION OF ALEX BAXTER