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

Filing 613

Administrative Motion to File Under Seal filed by Apple Inc.. (Attachments: #1 Apple's Motion to Compel Production of Documents and Things, #2 Mazza Declaration ISO Apple's Motion to Compel, #3 Ex A to Mazza Decl, #4 Ex B to Mazza Decl, #5 Ex C to Mazza Decl, #6 Ex D to Mazza Decl, #7 Ex E to Mazza Decl, #8 Ex F to Mazza Decl, #9 Ex G to Mazza Decl, #10 Ex H to Mazza Decl, #11 Ex I to Mazza Decl, #12 Ex J to Mazza Decl, #13 Ex K to Mazza Decl, #14 Ex L to Mazza Decl, #15 Ex M to Mazza Decl, #16 Ex N to Mazza Decl, #17 Proposed Order)(Jacobs, Michael) (Filed on 1/11/2012) Modified on 6/8/2012 (ofr, COURT STAFF).

Exhibit G

425 MARKET STREET
SAN FRANCISCO
CALIFORNIA 94105-2482
TELEPHONE: [phone]
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 29, 2011

Writer’s Direct Contact
415.268.6024
[e-mail]

Via E-Mail ([e-mail])
Rachel Herrick Kassabian
Quinn Emanuel
555 Twin Dolphin Dr., 5th Floor
Redwood Shores, California 94065
Re:

Apple v. Samsung, Case No. 11-cv-1846-LHK (PSG) (N.D. Cal.)

Dear Rachel:
It has come to our attention that purchasers of Samsung products are currently being sent a
survey by Samsung regarding their usage of and preferences for various Apple products.
We have not found any surveys of this type in Samsung’s production thus far, although they
(1) are responsive to at least RFPs 16, 29, and 157, and PI RFPs 206 and 214, and (2) fall
squarely within the scope of Judge Grewal’s September 28 Order compelling Samsung to
produce this very type of document.
Please be prepared during tomorrow’s meet-and-confer call to provide a date certain by when
Samsung’s production of these and other survey-related documents will be substantially
complete.
Sincerely,
/s/ Mia Mazza
Mia Mazza
cc:

Samuel Maselli
S. Calvin Walden
Peter Kolovos

sf-3075893