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)

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1 QUINN EMANUEL URQUHART & SULLIVAN, LLP Charles K. Verhoeven (Bar No. 170151) charlesverhoeven@quinnemanuel.com 2 50 California Street, 22nd Floor 3 San Francisco, California 94111 Telephone: (415) 875-6600 4 Facsimile: (415) 875-6700 5 Kevin P.B. Johnson (Bar No. 177129 kevinjohnson@quinnemanuel.com Victoria F. Maroulis (Bar No. 202603) 6 victoriamaroulis@quinnemanuel.com 555 Twin Dolphin Drive, 5th Floor 7 Redwood Shores, California 94065-2139 (650) 801-5000 8 Telephone: Facsimile: (650) 801-5100 9 10 Michael T. Zeller (Bar No. 196417) michaelzeller@quinnemanuel.com 865 S. Figueroa St., 10th Floor 11 Los Angeles, California 90017 12 Telephone: (213) 443-3000 Facsimile: (213) 443-3100 13 14 Attorneys for SAMSUNG ELECTRONICS CO., LTD., SAMSUNG ELECTRONICS AMERICA, 15 INC. and SAMSUNG TELECOMMUNICATIONS AMERICA, LLC 16 17 UNITED STATES DISTRICT COURT 18 NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION 19 20 APPLE INC., a California corporation, 21 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 3 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 -1- 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 18 19 20 21 22 23 24 25 26 27 28 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) -2-

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