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

Filing 637

Administrative Motion to File Under Seal filed by Apple Inc.. (Attachments: #1 Wheeler Declaration ISO Motion to Seal, #2 Proposed Order ISO Motion to Seal, #3 Bartlett Declaration ISO Opposition to Motion to Enforce, #4 Ex A to Bartlett Decl, #5 Ex B to Bartlett Decl, #6 Ex C to Bartlett Decl, #7 Ex D to Bartlett Decl, #8 Ex E to Bartlett Decl, #9 Ex F to Bartlett Decl, #10 Ex G to Bartlett Decl, #11 Ex H to Bartlett Decl, #12 Ex I to Bartlett Decl, #13 Ex J to Bartlett Decl, #14 Ex K to Bartlett Decl, #15 Opposition to Motion to Enforce, #16 Maselli Decl ISO Opposition to Motion to Compel, #17 Ex A Maselli Decl, #18 Ex B Maselli Decl, #19 Ex C Maselli Decl, #20 Ex D Maselli Decl, #21 Ex E Maselli Decl, #22 Opposition to Motion to Compel, #23 Mazza Declaration ISO Opposition to Motion for Clarification, #24 Ex A Mazza Decl, #25 Ex B Mazza Decl, #26 Ex C Mazza Decl)(Jacobs, Michael) (Filed on 1/17/2012)

Exhibit A

From:
To:
cc:
Subject:
Date:
Attachments:

Maselli, Samuel
"[e-mail]";
"[e-mail]"; "AppleMoFo";
WH Apple Samsung NDCal Service;
FW: Apple v. Samsung: discovery correspondence
Tuesday, December 06, 2011 7:16:05 PM
12-2-2011 M Chan letter to W Overson.pdf

Melissa,
I write in response to your attached December 2 letter seeking, among other
things, Apple's confirmation that it will be producing various categories of source
code and other technical documents related to the Accused Products.
With regard to Samsung's requested production of Apple's source code, please be
advised that Apple is currently prepared to produce the following responsive
source code in accordance with the terms of the Interim Protective Order:
• Portions of the Photos app, Photo Bucket app, and Camera app source
code that relate to capturing images, displaying images, and attaching
images to e-mail;
• Portions of the iPod and Music app source code that relate to playing
music;
• Portions of the Clock app source code that relate to a world clock and
time information;
• Portions of the Messages app source code that relate to display of
incoming and outgoing messages; and
• Portions of Apple's source code relating to display of the app
multitasking bar shown when a user double-clicks the Home button.
Moreover, as we have discussed, many of the categories of technical documents
identified in your attached letter have been produced in the 794 investigation, and
will be available for your use in this action subject to our imminent agreement on
cross-use. (See 12/6/11 E-mail from Maselli to Kassabian.) In addition, Apple's
production efforts are ongoing in this action, and, subject to its objections and the
parties' meet and confer discussions (and related agreements), Apple will continue
to produce non-privileged documents in response to Samsung's requests to the
extent they are in Apple's possession, custody or control and can be identified
after a reasonable search, including the identified categories of documents in your
letter.
Regards,

Sam Maselli

Samuel Maselli | WilmerHale
950 Page Mill Road
Palo Alto, CA 94304 USA
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From: Melissa Chan [mailto:[e-mail]]
Sent: Friday, December 02, 2011 5:19 PM
To: 'Overson, Wesley E.'; 'Mazza, Mia'
Cc: Rachel Herrick Kassabian; Diane Hutnyan; Joby Martin; 'AppleMoFo'; WH Apple
Samsung NDCal Service
Subject: Apple v. Samsung: discovery correspondence

Counsel,
Please see the attached correspondence.
Thanks,
Melissa
Melissa Chan
Quinn Emanuel Urquhart & Sullivan, LLP
555 Twin Dolphin Drive, 5th Floor
Redwood Shores, CA 94065
650-801-5004 Direct
650.801.5000 Main Office Number

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