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

Filing 600

Administrative Motion to File Under Seal Apples Motion to Compel Discovery Relating to Its Affirmative Defenses and Counterclaims filed by Apple Inc.(a California corporation). (Attachments: *** #1 Motion to Compel, #2 Maselli Declaration PURSUANT TO ORDER #804 DOCUMENT REMOVED.*** , #3 Ex A, #4 Ex B, #5 Ex C, #6 Ex D, #7 Ex E, #8 Ex F, #9 Ex G, #10 Ex H, #11 Ex I, #12 Ex J, #13 Ex K, #14 Ex L, #15 Ex M, #16 Ex N, #17 Ex O, #18 Ex P, #19 Ex Q, #20 Ex R, #21 Ex S, #22 Ex T, #23 Ex U, #24 Ex V, #25 Ex W, #26 Ex X, #27 Ex Y, #28 Ex Z, #29 Ex AA, #30 Ex BB, #31 Ex CC, #32 Ex DD, #33 Ex EE*** PURSUANT TO ORDER #804 DOCUMENT REMOVED. *** #34 , Ex FF #(35) Ex GG, #36 Proposed Order)(Selwyn, Mark) (Filed on 1/10/2012) Modified on 1/11/2012 (ewn, COURT STAFF). Modified on 1/11/2012 (feriab, COURT STAFF). Modified on 1/11/2012 (ewn, COURT STAFF). (Attachment 1 replaced on 3/13/2012) (sp, COURT STAFF). (Attachment 2 replaced on 3/13/2012) (sp, COURT STAFF). (Attachment 33 replaced on 3/13/2012) (sp, COURT STAFF). Modified on 3/13/2012 (sp, COURT STAFF). Modified on 3/13/2012 (sp, COURT STAFF). Modified on 6/8/2012 (ofr, COURT STAFF).

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EXHIBIT Y 425 MARKET STREET SAN FRANCISCO CALIFORNIA 94105-2482 TELEPHONE: 415.268.7000 FACSIMILE: 415.268.7522 MO RRI SO N & F O E RST E R L LP 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. 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 WWW.MOFO.COM November 23, 2011 Writer’s Direct Contact 415.268.6024 By Email ( Rachel Herrick Kassabian Quinn Emanuel 555 Twin Dolphin Dr., 5th Floor Redwood Shores, CA 94065 Re: Apple v. Samsung, Case No. 11-cv-1846-LHK (PSG) (N.D. Cal.) Dear Rachel: I write to confirm the parties’ agreement to take this week’s meet-and-confer call off calendar in light of the Thanksgiving holiday. Please note that Apple expects to receive at least the following documents and information from Samsung no later than the evening before the next meet-and-confer call (on November 30), as discussed on our call of November 16 and in recent correspondence: Samsung’s redline of the reciprocity charts attached to Wes Overson’s letters of November 10 and November 22 labeled “Exhibit A” and “Exhibit B;” A response to Wes Overson’s letter of November 9 identifying source code and other technical documents related to the accused features that Samsung has not produced but that Apple is entitled to receive, and designation of a date certain by which Samsung’s production of the listed items will be substantially complete; Substantially complete production of documents referencing “Apple” from “each of Samsung[‘s] designers of Samsung’s Galaxy S 4G and Infuse 4G, Droid Charge phones, and Galaxy Tab 10.1 table computer identified in Samsung’s Rule 26(a) disclosures or interrogatory responses” (language taken from the Court’s Order of September 28, 2011); Substantially complete production of survey documents pursuant to the Court’s September 28th Order; Full and complete supplemental responses to Interrogatories 2 through 6; sf-3074506 Rachel Herrick Kassabian November 23, 2011 Page Two Full and complete supplemental responses to Preliminary Injunction Interrogatories 12 through 14; Designation of a date certain by which Samsung’s production of standards-related documents will be substantially complete; A response to Sam Maselli’s November 15 letter regarding Samsung’s overbroad assertions of privilege; and A response to Apple’s proposal that each party agree to notify the other party in advance where possible when they become aware that productions are going to be untimely. Sincerely, /s/ Mia Mazza Mia Mazza sf-3074506

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