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

Filing 603

EXHIBITS re 602 Administrative Motion to File Under Seal re Samsung's January 10, 2012 Filings Exhibit 1 - [Proposed] Public Redacted Version of Samsung's Motion to Compel filed bySamsung Electronics Co. Ltd.(a Korean corporation). (Attachments: # 1 Exhibit Hutnyan Declaration, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, # 10 Exhibit I, # 11 Exhibit J, # 12 Exhibit K, # 13 Exhibit L, # 14 Exhibit M, # 15 Exhibit N, # 16 Exhibit O, # 17 Exhibit P, # 18 Exhibit Q, # 19 Exhibit R, # 20 Exhibit S, # 21 Exhibit T, # 22 Exhibit U, # 23 Exhibit V, # 24 Exhibit W, # 25 Exhibit X, # 26 Exhibit Y, # 27 Exhibit Z, # 28 Exhibit AA, # 29 Exhibit BB, # 30 Exhibit CC, # 31 Proposed Order)(Related document(s) 602 ) (Maroulis, Victoria) (Filed on 1/11/2012)

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1 2 3 4 5 6 7 8 9 UNITED STATES DISTRICT COURT 10 NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION 11 APPLE INC., a California corporation, CASE NO. 11-cv-01846-LHK-PSG 12 Plaintiff, 13 vs. 14 SAMSUNG ELECTRONICS CO., LTD., a 15 Korean business entity; SAMSUNG ELECTRONICS AMERICA, INC., a New 16 York corporation; SAMSUNG TELECOMMUNICATIONS AMERICA, 17 LLC, a Delaware limited liability company, 18 [PROPOSED] ORDER GRANTING SAMSUNG’S MOTION TO COMPEL APPLE TO PRODUCE DOCUMENTS AND THINGS Defendants. 19 20 On January 10, 2012, Defendants Samsung Electronics Co. Ltd., Samsung Electronics 21 America, Inc., and Samsung Telecommunications America, LLC (collectively, “Samsung”) 22 moved this court to compel discovery from Apple Inc. Having reviewed the motion, for good 23 cause shown, the Court ORDERS as follows: 24 25 26 27 28 02198.51855/4544000.1 Case No. 11-cv-01846-LHK -1[PROPOSED] ORDER GRANTING SAMSUNG’S MOTION TO COMPEL APPLE TO PRODUCE DOCUMENTS AND THINGS 1 The Court GRANTS Samsung’s Motion to Compel Apple to produce, by January 31, 2 2012, as detailed in Samsung’s Motion: 3 1. all source code and other technical documents showing the operation of the 4 allegedly infringing product features, including all those corresponding to the baseband processors 5 incorporated in Apple’s products, as required by Patent Local Rule 3-4(a); 6 2. all source code and other technical documents related to known prior art to the 7 asserted patents, as required by Patent Local Rule 3-2(a); 8 3. all emails and documents showing Apple’s analysis and consideration of Samsung 9 and Samsung products, including those resulting from a reasonable search of documents for the 10 party (Samsung) and products at issue, and their aliases; 11 4. all design history documents, including mechanical outlines (“MCOs”), prototypes, 12 whether complete or not, physical models, sketchbooks, and other documents relevant to the 13 validity of Apple’s design patents 14 5. asserted trademark and trade dress rights. all survey and marketing documents related to Apple's alleged design and utility 15 patents, trade dress, and trademarks; and 16 6. all financial documents, relevant to showing the alleged value, or lack thereof, of 17 Apple’s asserted patents. 18 The Court also compels Apple to provide prompt deposition dates for all properly noticed 19 fact witnesses, including Mr. Ive, as well as for all of Samsung's 30(b)(6) deposition topics, by 20 January 22, 2012. 21 IT IS SO ORDERED. 22 23 DATED: ______________________ 24 25 26 HONORABLE PAUL S. GREWAL United States Magistrate Judge 27 28 02198.51855/4544000.1 Case No. 11-cv-01846-LHK -2[PROPOSED] ORDER GRANTING SAMSUNG’S MOTION TO COMPEL APPLE TO PRODUCE DOCUMENTS AND THINGS

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