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

Filing 608

ERRATA re #603 Exhibits,,, Notice of Correction re Samsung's Motion to Compel by Samsung Electronics Co. Ltd.. (Maroulis, Victoria) (Filed on 1/11/2012)

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,
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22

CASE NO. 11-cv-01846-LHK

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.
27
28
02198.51855/4544080.1

Case No. 11-cv-01846-LHK
[CASE TITLE HERE]

1

DEFENDANT SAMSUNG’S NOTICE OF CORRECTION TO SAMSUNG’S MOTION TO

2

COMPEL PRODUCTION OF DOCUMENTS AND THINGS

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4

Defendant Samsung respectfully submits the following corrections to Samsung’s Motion

5 to Compel the Production of Documents and Things.
6
7 First, Samsung wishes to replace the omitted text on page 38, with:
8 RESPONSE TO REQUEST FOR PRODUCTION NO. 252:
9 Apple objects to this request as overly broad, unduly burdensome, and not reasonably
10 calculated to lead to the discovery of admissible evidence.
11 Subject to and without waiving the foregoing General and Specific Objections, Apple has
12 produced or will produce responsive, non-privileged documents in its possession, custody, or
13 control, if any, located after a reasonable search, sufficient to show U.S. sales of accused products
14 over the relevant time period, including information related to revenue and profitability.
15
16 Second, Samsung wishes to replace the omitted text on page 39, with:
17 RESPONSE TO REQUEST FOR PRODUCTION NO. 253:
18 Apple objects to this request as overly broad, unduly burdensome, and not reasonably
19 calculated to lead to the discovery of admissible evidence.
20 Subject to and without waiving the foregoing General and Specific Objections, Apple has
21 produced or will produce responsive, non-privileged documents in its possession, custody, or
22 control, if any, located after a reasonable search, sufficient to show U.S. sales of accused products
23 over the relevant time period, including information related to revenue and profitability.
24
25 Third, Samsung wishes to replace the omitted text on page 39, with:
26 RESPONSE TO REQUEST FOR PRODUCTION NO. 254:
27 Apple objects to this request as overly broad, unduly burdensome, and not reasonably
28 calculated to lead to the discovery of admissible evidence.
02198.51855/4544080.1

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Case No. 11-cv-01846-LHK
[CASE TITLE HERE]

1 Subject to and without waiving the foregoing General and Specific Objections, Apple has
2 produced or will produce responsive, non-privileged documents in its possession, custody, or
3 control, if any, located after a reasonable search, sufficient to show U.S. sales of accused products
4 over the relevant time period, including information related to revenue and profitability.
5
6 Samsung did not realize this error until after its Motion to Compel had been filed.
7
8 DATED: January 11, 2012

Respectfully submitted,

9

QUINN EMANUEL URQUHART &
SULLIVAN, LLP

10
11
12
13
14
15
16
17

By/s/
Charles K. Verhoeven
Kevin P.B. Johnson
Victoria F. Maroulis
Michael T. Zeller
Attorneys for SAMSUNG ELECTRONICS CO.,
LTD., SAMSUNG ELECTRONICS AMERICA,
INC. and SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC

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20
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24
25
26
27
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02198.51855/4544080.1

Case No. 11-cv-01846-LHK
SAMSUNG’S RESPONSE TO APPLE, INC.’S THIRD
SET OF REQUESTS FOR PRODUCTION (NOS. 53-155)

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