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

Filing 621

OPPOSITION to ( 532 Apple's Motion to Strike Evidence Not Disclosed as Required by Patent Local Rule 4-3(b) ) filed by Samsung Electronics Co. Ltd.. (Attachments: # 1 Declaration of Todd M. Briggs, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G)(Briggs, Todd) (Filed on 1/12/2012) Modified text on 1/13/2012 (dhm, COURT STAFF).

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1 QUINN EMANUEL URQUHART & SULLIVAN, LLP Charles K. Verhoeven (Cal. Bar No. 170151) 2 charlesverhoeven@quinnemanuel.com 50 California Street, 22nd Floor 3 San Francisco, California 94111 Telephone: (415) 875-6600 4 Facsimile: (415) 875-6700 5 Kevin P.B. Johnson (Cal. Bar No. 177129) kevinjohnson@quinnemanuel.com 6 Victoria F. Maroulis (Cal. Bar No. 202603) victoriamaroulis@quinnemanuel.com 7 555 Twin Dolphin Drive 5th Floor Redwood Shores, California 94065 8 Telephone: (650) 801-5000 Facsimile: (650) 801-5100 9 Michael T. Zeller (Cal. Bar No. 196417) 10 michaelzeller@quinnemanuel.com 865 S. Figueroa St., 10th Floor 11 Los Angeles, California 90017 Telephone: (213) 443-3000 12 Facsimile: (213) 443-3100 13 Attorneys for SAMSUNG ELECTRONICS CO., LTD., SAMSUNG ELECTRONICS 14 AMERICA, INC. and SAMSUNG TELECOMMUNICATIONS AMERICA, LLC 15 16 UNITED STATES DISTRICT COURT 17 NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION 18 APPLE INC., a California corporation, CASE NO. 11-cv-01846-LHK 19 DECLARATION OF TODD BRIGGS IN SUPPORT OF SAMSUNG’S OPPOSITION TO APPLE’S MOTION TO STRIKE EVIDENCE 20 Plaintiff, vs. 21 SAMSUNG ELECTRONICS CO., LTD., a Korean business entity; SAMSUNG 22 ELECTRONICS AMERICA, INC., a New York corporation; SAMSUNG 23 TELECOMMUNICATIONS AMERICA, LLC, a Delaware limited liability company, 24 Defendants. 25 Date: January 20, 2012 Time: 10:00 a.m. Place: Courtroom 8, 4th Floor Judge: Hon. Lucy H. Koh 26 27 28 02198.51855/4548116.1 Case No. 11-cv-01846-LHK DECLARATION OF TODD BRIGGS 1 I, Todd Briggs, declare: 2 1. I am a partner at Quinn Emanuel Urquhart & Sullivan, LLP, counsel for Samsung 3 Electronics Co., Ltd., Samsung Electronics America, Inc. and Samsung Telecommunications 4 5 America, LLC (collectively, “Samsung”). I am licensed to practice law in the State of California. I submit this declaration in support of Samsung’s Opposition to Apple’s Motion to Strike 6 7 8 Evidence Not Disclosed As Required by Patent Local Rule 4-3(b). I have personal knowledge of the facts set forth in this declaration and, if called upon as a witness, I could and would testify to 9 the following facts. 10 2. Attached hereto as Exhibit A is a true and accurate copy of the cover pleading for 11 Apple’s Patent L.R. 4-2 disclosure. 12 3. Attached hereto as Exhibit C is a true and accurate copy of the cover letter for 13 Samsung’s Patent L.R. 4-2 disclosure. 14 15 4. Attached hereto as Exhibit B is a true and accurate copy of the cover pleading for 16 the Parties Joint Claim Construction Statement. 17 5. Attached hereto as Exhibit D is a true and accurate copy of correspondence from 18 Apple’s counsel serving Dr. Givargis’s declaration in support of Apple’s claim construction, 19 received on November 14, 2011, at 10:17 pm, two hours prior to filing the Parties’ Joint Claim 20 Construction Statement. 21 6. Attached hereto as Exhibit E is a true and accurate copy of the ECF notification 22 23 indicating that the Parties filed their Joint Claim Construction Statement on November 14, 2011, 24 at 11:57 pm. 25 7. Attached hereto as Exhibit F is a true and accurate copy of excerpts from Dr. 26 Givargis’s declaration, served on November 14, 2011, at 10:17 pm. 27 28 02198.51855/4548116.1 -2- Case No. 11-cv-01846-LHK DECLARATION OF TODD BRIGGS 1 8. Attached hereto as Exhibit G is a true and accurate copy of excerpts from Dr. 2 Givargis’s deposition testimony. 3 4 I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. 5 6 Executed in Redwood Shores, California on January 12, 2012. 7 8 9 /s/ Todd Briggs Todd Briggs 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 02198.51855/4548116.1 -3- Case No. 11-cv-01846-LHK DECLARATION OF TODD BRIGGS

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