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).

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP
Charles K. Verhoeven (Cal. Bar No. 170151)
2 [e-mail]
50 California Street, 22nd Floor
3 San Francisco, California 94111
Telephone: [phone]
4 Facsimile: [phone]
5 Kevin P.B. Johnson (Cal. Bar No. 177129)
[e-mail]
6 Victoria F. Maroulis (Cal. Bar No. 202603)
[e-mail]
7 555 Twin Dolphin Drive 5th Floor
Redwood Shores, California 94065
8 Telephone: [phone]
Facsimile: [phone]
9
Michael T. Zeller (Cal. Bar No. 196417)
10 [e-mail]
865 S. Figueroa St., 10th Floor
11 Los Angeles, California 90017
Telephone: [phone]
12 Facsimile: [phone]
13 Attorneys for SAMSUNG ELECTRONICS
CO., LTD., SAMSUNG ELECTRONICS
14 AMERICA, INC. and SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

18 APPLE INC., a California corporation,

CASE NO. 11-cv-01846-LHK

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DECLARATION OF TODD BRIGGS
IN SUPPORT OF SAMSUNG’S
OPPOSITION TO APPLE’S MOTION TO
STRIKE EVIDENCE

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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,
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Defendants.
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Date: January 20, 2012
Time: 10:00 a.m.
Place: Courtroom 8, 4th Floor
Judge: Hon. Lucy H. Koh

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02198.51855/4548116.1

Case No. 11-cv-01846-LHK
DECLARATION OF TODD BRIGGS

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I, Todd Briggs, declare:

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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
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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

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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.
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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.
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3.

Attached hereto as Exhibit C is a true and accurate copy of the cover letter for

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Samsung’s Patent L.R. 4-2 disclosure.
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4.

Attached hereto as Exhibit B is a true and accurate copy of the cover pleading for

16 the Parties Joint Claim Construction Statement.
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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
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Construction Statement.

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6.

Attached hereto as Exhibit E is a true and accurate copy of the ECF notification

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indicating that the Parties filed their Joint Claim Construction Statement on November 14, 2011,

24 at 11:57 pm.
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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.
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02198.51855/4548116.1

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Case No. 11-cv-01846-LHK
DECLARATION OF TODD BRIGGS

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8.

Attached hereto as Exhibit G is a true and accurate copy of excerpts from Dr.

2 Givargis’s deposition testimony.
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I declare under penalty of perjury under the laws of the United States that the foregoing is
true and correct.

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Executed in Redwood Shores, California on January 12, 2012.

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/s/ Todd Briggs
Todd Briggs

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02198.51855/4548116.1

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Case No. 11-cv-01846-LHK
DECLARATION OF TODD BRIGGS