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

Filing 636

DECLARATION in Opposition to #602 Administrative Motion to File Under Seal re Samsung's January 10, 2012 Filings Bartlett and Mazza Declarations in Support of Apple's Opposition to Samsung's Motion to Compel filed byApple Inc.. (Attachments: #1 Exhibit 1 to Bartlett Declaration, #2 Exhibit 2 to Bartlett Declaration, #3 Exhibit 3 to Bartlett Declaration, #4 Exhibit 4 to Bartlett Declaration, #5 Exhibit 5 to Bartlett Declaration, #6 Exhibit 6 to Bartlett Declaration, #7 Exhibit 7 to Bartlett Declaration, #8 Exhibit 8 to Bartlett Declaration, #9 Mazza Declaration, #10 Exhibit A to Mazza Declaration, #11 Proposed Order)(Related document(s) #602 ) (Hung, Richard) (Filed on 1/17/2012)

Exhibit 4

Apple to Launch 3G iPhone at $199
June 11, 2008 - IDC Link
Comment by Shiv Bakhshi

At its Worldwide Developers' Conference at Moscone Center in San Francisco, Apple announced that it
would be launching its 3G iPhone in 22 countries on July 11, reaching a total of 70 countries across the
globe in subsequent months. The iPhone has been officially launched in six counties to date.
In sharp contrast to the launch price of the current iPhone, the 8Gb 3G iPhone will be priced at $199, with
the 16Gb version priced at $299.
The 3G iPhone will be a shade thicker than the current EDGE version (at 12.3 mm vis-à-vis the 11.6 mm
of the original) but will be thinner at the edges to give it a sleeker look. The new phone will have a 3.5 inch
screen like the original version, but a better battery life. Per Apple, the new device will have a stand-by
time of up to 300 hours, 3G talk time of up to 5 hours, browsing time of up to six hours, as well as up to
20 hours of audio and even hours of video.
The 3G iPhone will support tri-band HSDPA and quad-band GSM/EDGE connectivity on the cellular side,
as well as 802.11 b/g for WLAN. The Bluetooth 2.0 device will also come equipped with GPS (Global
Positioning System) capability; Apple sees location-based services and navigation as major applications,
in both the consumer and the enterprise contexts.
At the conference, Apple also officially announced iPhone 2.0, the new software platform for its
smartphone which it had unveiled in March earlier this year, and which will be available in early July. The
company also discussed its SDK and emphasized the iPhone's push in the enterprise space with its
support for Microsoft Exchange that enables enterprises to push e-mail and sync contacts and calendars
over the air. The company also announced its support for Cisco IPsec VPN for encrypted access to
corporate networks.
The software platform includes a software developer kit (SDK), complete with native APIs that application
developers may use to write mobile apps, including apps that take advantage of the iPhone's multi-touch
and multimedia capabilities. The platform also allows full contact search, language support for several
European and Asian languages (including finger writing for Chinese characters), a scientific calculator and
parental controls. Apps under 10 Mb may be downloaded on cellular and WiFi networks as well as through
iTunes; apps over 10 MB may only be downloaded through WiFi Networks and iTunes.
The company invited a whole slew of partners to demonstrate how well its device and the software platform
lent themselves to a wide variety of applications, from location-based services, photo blogging and social
networking to health services, music, education and gaming. IDC believes that the iPhone mobile platform
will attract a host of developers to its mobile platform, particularly those geared to exploit its multimedia
capabilities.
The company said developers will be able to sell their applications for 3G iPhones through its online App
Store that can be accessed by users in 62 countries.
Apple also announced MobileMe, a web service that company officials characterized as "having Exchange
for the rest of us." The service allows individuals and small and medium-sized enterprises to get push email and synchronize calendar and contact information wirelessly on the go. The MobileMe service also

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accommodates sharing of photos and documents. The service replaces Apple's .Mac (dotMac) online
service. Current .Mac users will be automatically upgraded to MobileMe.
IDC believes Apple's push into the enterprise space and the launch of the MobileMe, which addresses
individuals and SMBs, is a timely move in the right direction. It recognizes, appropriately, the increasing
blurring of boundaries between consumer and enterprise usage, and the fact that improved device
attributes — such as displays, storage, processing, etc. — might equally profitably be placed in the service
of efficiency as well as entertainment. Apple's push in the enterprise and prosumer space will likely benefit
from its partnership with AT&T, which is fairly well entrenched in, and aggressively seeking to grow its
presence in, this space. IDC's review of the Apple SDK and the company's enterprise push may be viewed
at iPhone Open for Business with SDK Release and Corporate Email (IDC #211307, March 2008).
However, the big news of the day was not the expected announcement of the 3G iPhone but rather the
price point at which it will be available across the world and the geographic scope of its distribution (i.e.,
its launch across 70 countries presumably by year end). IDC believes Apple has done well to price the 3G
iPhone at $199/$299 since this will make it more affordable for consumers and likely drive mass adoption
of the device and, with it, specially given the appealing user interface and the associated ease of use,
likely drive mobile data usage.
IDC believes at this price point, the iconic iPhone — which has captured the world's imagination – might
well emerge as a seriously disruptive influence for some of the more established device vendors whose
high-end devices are priced between $500 and $800. On the positive side, however, the 3G iPhone should
help usher in — actually, speed up — a culture of mobile data consumption that should have a salutary
effect on the industry.
The operators should see greater data usage, and hence higher ARPUs. Competing device vendors
should benefit from consumers' heightened awareness of the possibilities of mobile devices, particularly
the smartphones. A rising tide does tend to raise all boats after all — although not in the same manner
and not to the same extent. But some of the leading device vendors, with their sophisticated user
segmentations and broad product portfolios, may be well positioned to exploit the heightened awareness
created by Apple to their own benefit.
The event was remarkable as much for what was announced by Apple as for what was left unsaid. There
was no mention of a changed business model, for instance. The 3G iPhone will not come wrapped in the
same revenue share model that Apple enjoyed with the launch of the current iPhone last year. Not every
operator across the world is particularly keen to enter in the data plan revenue share model, in part because
of competitive pressure in their respective countries and in part because of low operating margins and low
ARPUs. This is specially true in emerging markets of Asia and Latin America.
AT&T in the US, seeking greater data usage and driven by a desire to further reduce customer churn, has
said that it will subsidize the 3G iPhone — like it subsidizes most of the other mobile devices it offers its
users. Customers will have to sign up for a two-year contract as well as a $30 monthly unlimited data plan
to get the 3G iPhone at $199/$299. Revenue share on specific services that may be offered through iTunes
is still unclear. It is unclear whether, and to what extent, might the 3G iPhone be subsidized in different
countries.
Also unclear is the way the device activation will take place on different networks across the world. Apple
had made history by wrangling away from its first operator partner, AT&T in the US, the privilege of
activating a mobile device on the operator network. Since then, some things have changed. In some
countries today, device activation is initiated in the store but completed on iTunes. It is not clear how this
will work in many of the countries where Apple plans to take its 3G iPhone, given that Apple does not have
iTunes presence in some of these countries.
One can only assume that Apple's intent to roll out the 3G iPhone only gradually in countries that are not
on the July 11 list is informed as much by the need to firm up the details of operator contracts as by the
desire to build an iTunes presence in those markets.

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But while there are many things that are still unclear, and various details that have yet to be worked out,
and shared, one thing seems clear: With its 3G iPhone, specially at the announced price point, Apple may
yet once again significantly redefine how we interact with and consume information in the mobile
environment.
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