Apple Inc. v. Samsung Electronics Co. Ltd. et al
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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WRITER'S INTERNET ADDRESS
October 21, 2011
VIA ELECTRONIC MAIL
S. Calvin Walden
Wilmer Cutler Pickering Hale and Dorr LLP
399 Park Avenue
New York, New York 10022
Apple Inc. v. Samsung Elecs. Co., et al., Case No. 11-CV-01846-LHK (N.D. Cal.)
I write in response to your October 13, 2011, letter to Victoria Maroulis on Requests for
Production Nos. 53-155.
Documents Relating to Inventor and Prosecuting Attorney Depositions
For documents relating to the inventors and prosecuting attorney depositions that are scheduled
to occur during the month of November, either (1) we have already produced such documents
with Samsung’s infringement contentions or (2) we will produce them five days in advance of
the deposition date, per the parties’ agreement. We reiterated that on the meet and confer call on
October 19, 2011.
Regarding Samsung’s licenses and license-related documents or documents relating to standards
organizations, we intend to produce documents relevant and responsive to such requests, subject
to our written objections. However, we do not anticipate that such productions will occur before
all of the depositions of Samsung’s inventors and prosecuting attorneys. If you believe that these
documents are relevant to the depositions that must be conducted per Court order by December
1, 2011, please explain in detail the basis of your position, including an explanation of how such
documents are relevant to one or more of those depositions.
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“Meet and Confer” Responses to Requests for Production
As we’ve discussed during several meet and confer conferences, Samsung is collecting and will
produce relevant, non-privileged documents, subject to its written objections. Based on our
preliminary review of the categories in your letter, we have concerns about many of the requests,
including requests where you seek information that is subject to work product privileges or
otherwise are or will be included with filed or served documents (see, e.g., RFP Nos. 61, 94, 95,
96, 110, 111), or requests where you seek information about employee compensation and
bonuses, which are irrelevant and implicate privacy concerns (see, e.g. RFP Nos. 76-78, 140,
141). We are unclear as to what you are seeking in Request No. 155, where you ask for “[a]ll
documents relating to any Samsung policy or practice for compliance with any federal state
antitrust, unfair competition, or unfair trade practices law.” For the other requests, we are
investigating, searching for and collecting relevant documents.
We are willing to let you know which additional requests, if any, for which Samsung does not
intend to produce any documents and requires a meet and confer for clarification, if Apple will
do the same (as we have been requesting for weeks now). Please advise.
Finally, since the parties have agreed to a standing weekly meet and confer time, we can address
issues with Apple’s deficient document production as well.
Very truly yours,
QUINN EMANUEL URQUHART & SULLIVAN, LLP
/s/ Melissa N. Chan
Melissa N. Chan
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