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

Filing 648

Declaration of Cyndi Wheeler in Support of #602 Administrative Motion to File Under Seal re Samsung's January 10, 2012 Filings filed byApple Inc.. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8, #9 Exhibit 9, #10 Exhibit 10, #11 Exhibit 11, #12 Exhibit 12, #13 Exhibit 13, #14 Exhibit 14, #15 Exhibit 15, #16 Exhibit 16, #17 Exhibit 17, #18 Proposed Order)(Related document(s) #602 ) (Hung, Richard) (Filed on 1/18/2012)

EXHIBIT 1
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January 5, 2012

Writer’s Direct Contact
415.268.6615
[e-mail]

Via E-Mail ([e-mail])
Diane Hutnyan
Quinn Emanuel
865 S. Figueroa St., 10th Floor
Los Angeles, CA 90017
Re:

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

Dear Diane:
I write in response to your letter of January 2, 2012 setting out Samsung’s agenda items for
the upcoming lead counsel in-person meet-and-confer session. A letter summarizing Apple’s
positions as described in detail below is attached.
Mac OS X (10.0)
Samsung has requested that Apple produce a working computer that was in public use before
July 10, 2001 with a brightness adjustment button and is running the Mac OS X v. 10.0
software that was in public use before July 10, 2001.
Apple originally produced a working 10-year-old computer that it had to piece together from
3 different machines in order to make it operational and source code relating to features at
issue on December 15. Samsung requested more code on December 20, and Apple produced
the requested code the next day.
Samsung now states that the brightness button on the provided computer is nonfunctional
and requests a new system with a working brightness button. Samsung appears to already
have the software and hardware it is seeking, as this function is pictured in Samsung’s
invalidity contentions. Moreover, this issue was raised very close to Apple’s company-wide
shutdown for the holidays, and as a result, we were unable to investigate and determine why
there was no working brightness button on the provided system.
An Apple technician visited our offices today and was not able to resolve the problem. He
will return tomorrow and continue to investigate the issue.

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Diane Hutnyan
January 5, 2012
Page Two
Memory Cards
Samsung has requested that Apple return memory cards containing Samsung’s work product
and confirm that it has destroyed all of Samsung’s work product.
Samsung has picked up the memory cards. Apple will expunge prior produced images from
production.
De-Designation of 035 Model Photographs
Samsung has requested that Apple de-designate certain photographs of the 035 Model.
We have reviewed the photographs that Samsung requests Apple de-designate and concluded
that the photographs have technical information beyond what is available in publicly filed
PTO documents. Specifically, each photograph has information relating to scale that is not
visible in the PTO record. Apple will produce de-designated versions of these photographs
with information relating to scale redacted. The only exceptions are extreme closeups, which
Judge Grewal has already noted contain more information than was available in the publicly
filed photographs.
If Samsung wishes to replicate the PTO photographs without adding additional visual
information or technical detail, Apple will not designate those photographs as confidential.
Source Code and Technical Documents
Samsung claims that Apple has failed to produce source code and technical documents.
This issue was addressed in separate correspondence by Sam Maselli of Wilmer Hale.
Documents Referencing “Samsung” and Other Terms
Samsung claims that Apple has failed to produce documents referencing “Samsung” and
“other relevant terms.”
Apple has already run “Samsung” as a search term on Apple inventor documents and has
been producing those hits.
By January 31, Apple will run “Samsung” as a search term on product marketing,
advertising, and market research files relating to research conducted by Apple. If additional
delimiters are needed to remove large amounts of irrelevant material, we will disclose those
delimiters.

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Diane Hutnyan
January 5, 2012
Page Three
Apple will not run the terms “Android” or “Droid” without additional delimiters. Test
searches reveal that this would result in very large amounts of irrelevant documents from
Apple’s collection, which would take months to review. These are general terms that do not
apply specifically to Samsung, and given the amount of material, applying these search terms
without delimiters would be an undue burden and overly broad.
Surveys and Marketing
Samsung claims that Apple has failed to produce consumer surveys, focus groups, and other
marketing-related documents. Contrary to Samsung’s assertion that customer surveys were
raised in a letter of December 3, 2011, this issue was raised for the first time in a letter of
January 2. There was no mention of a request by Samsung for survey documents in any
letter of December 3, 2011 received by Apple.
Nevertheless, Apple will produce by January 31, 2012 final survey reports, questionnaires,
and raw survey data for all customer surveys conducted by Apple relating to iPhone, iPod
touch, and iPad; and all market research reports purchased by Apple in the ordinary course of
business relating to iPhone, iPod touch, and iPad. If, after reviewing the production,
Samsung seeks more than this, please let us know.
Financial Documents
Samsung claims that Apple has failed to produce relevant financial documents. Like
consumer surveys, production of financial documents was first raised by Samsung in a letter
of January 2. Your letter of January 2 states that this issue was discussed during the parties’
last meet-and-confer, but that is untrue; Samsung did not raise Apple’s production of
financial documents during the meet-and-confer. In fact, this item was not on Samsung’s
agenda at all. Apple raised Samsung’s failure to produce financial documents on the call, and
that is all that was discussed.
Nevertheless, Apple will produce, by the end of next week, at least:
U.S. and worldwide units by quarter from FY 2007 to 2011 for iPhone, iPod touch,
and iPad
U.S. and worldwide revenue by quarter from FY 2007 to 2011 for iPhone, iPod
touch, and iPad
GAAP line of business reports setting forth Standard Margins, Adjusted Standard
Margins, Gross Margins, allocated SG&A, and Research and Development Costs for
iPhone, iPod, and iPad for FY 2007 to 2011

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Diane Hutnyan
January 5, 2012
Page Four
Bills of Materials for all accused Apple products, including line item cost information
Capital expenditure data for the U.S. and worldwide relating to iPhone, iPad, and
iPod
Apple will produce, by January 31, responsive documents from Apple’s product marketing
team, including strategic planning documents and market requirements documents.
Apple will produce market research documents as discussed above.
If, after reviewing the production, Samsung seeks more than this, please let us know.
REDAC Working
TED
REDACTED

Prototypes, and Models

These items were first requested by Samsung on December 3, 2011.
Apple has already produced a very large number of design-related materials, including CAD
for the original iPhone produced during the preliminary injunction phase; CAD for all other
announced iPhone, iPod touchy, and iPad products produced by December 30, 2011;
sketchbooks relating to announced iPhone, iPod touch, and iPad products produced by
December 30, 2011; and e-mails and electronic files of industrial designers substantially
completed by October 2011.
Apple will produce, per Judge Grewal’s December 22 order, all models, partial models, and
parts relating to announced iPhone, iPod touch, and iPad products by January 15, 2012.

REDACTED
REDACTED

Apple has a limited number of working prototypes, and will produce the prototypes it finds
after a reasonable search. Please confirm Samsung will do the same.
NeXT OS Source Code
Samsung claims that Apple has failed to produce requested NeXT OS source code.
Apple will produce all available NeXT OS source code by January 13. We understand that
this resolves Samsung’s request.

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Diane Hutnyan
January 5, 2012
Page Five
Mac OS Tiger
Samsung claims that Apple has failed to produce source code for Mac OS Tiger.
Apple understands that Samsung alleges certain “dashboard icons” appearing in Tiger
inspired a design patent covering iOS icons. Apple will bring a copy of a released version of
Tiger with a screenshot to the conference tomorrow.
Apple will not produce “all documents” relating to Tiger, a request that is significantly
overbroad given that the asserted relevance detailed above and goes beyond Samsung’s own
requests for production.
REDACTED

Advertising Documents
Samsung claims that Apple has failed to produce all relevant documents identified during
Sissie Twiggs’ deposition. Again, this issue was raised for the first time in a letter of
December 30.
There is no basis for Samsung’s claim that documents should have been produced before the
preliminary injunction deposition of Sissie Twiggs. The scope of preliminary injunction
production was negotiated between the parties, and the Twiggs deposition occurred months
ago.
Nevertheless, Apple will produce:
Print, television, and outdoor advertisements by January 13, 2012
Database reports of iPhone, iPad, and iPod touch use in media by January 13, 2012
Media plans and “click count” reports for search engine marketing by January 20,
2012
Advertising campaign binders by January 31, 2012
Online display advertisements by January 31, 2012
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Diane Hutnyan
January 5, 2012
Page Six
Audits of media as run by January 31, 2012
Apple has not found any items called “builds.” Samsung’s request for media “builds”
appears to be based on a misreading of Ms. Twiggs’ testimony.
Samsung’s request for demographic studies is addressed above under “Surveys and
Marketing.”
If Samsung seeks more than this, please let us know.
Sketchbooks from 2002
Samsung has requested that Apple produce sketchbooks from January 2002 through January
2003.
Samsung’s letter of December 30 is the first time Samsung has made the request for
sketchbooks dating back to 2002. Apple disclosed on September 15 that it used a 2003 date
cut-off in connection with Industrial Designer document productions. The parties discussed
Apple’s 2003 date cut-off on sketchbooks specifically during a meet-and-confer on
December 21. Apple invited Samsung to name a date that it considered early enough.
Samsung declined to do so. Instead, Samsung asked Apple to confirm in writing what date it
used as a cut-off for production of sketchbooks. Apple did so in a letter of December 24,
then proceeded to complete scanning and processing of sketchbooks over the Christmas
holiday.
Samsung has articulated no basis for its untimely and arbitrary request for pre-January 2003
sketchbooks. Apple sees no evidence that any industrial designer was involved in anything
relating to the RED project, which led to tablet design, until the fall of 2003. As a result,
ACT
Apple will not produce 2002 sketchbooks.
Keyword Searches of Inventor Documents
Samsung took issue with certain of Apple’s searches in a letter of November 29, 2011 and
asked Apple to run 114 new searches. Apple subsequently ran almost all of them. In a letter
of December 24, Apple counterproposed search terms in a handful of instances where
Samsung’s terms were overbroad, e.g., “look” and “feel.” Samsung submitted a countercounter proposal on December 30. A table setting out these positions and Apple’s current
offer is below.
Search terms for industrial design inventors:

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Diane Hutnyan
January 5, 2012
Page Seven
Term Suggested by
Samsung

Delimited Term

Counter-counter
proposal by
Samsung

Corner or radius

corner within 25 of
radius

corner* within 25 of
(radi* or sharp or
round*)

corner* within 5 of
(radi* or sharp or
round*)

balanc*

balanc* within 10 of
(design or border)

balanc* within 25 of
(feel or look or
design or border or
impression)

acceptable

thin or light

thin within 10 of
light

(thin* or light* or
thick*) within 25 of
(design or form or
factor or profile or
phone)

(thin* or light* or
thick*) within 5 of
(form or factor or
profile or phone)

concept

concept within 10 of
design

concept within 10 of
(design or iPhone or
iPad orREDACTED

(concept or pond or
puddle or oily)
within 10 of (design
or iPhone or iPad or

or
phone or screen)

REDACTED

Specific concepts to
search: pond or
puddle or oily

Apple’s Reply

or phone or
screen)

target

none - no basis for
relevance

target within 25
(audience or
customer or user or
purchaser)

acceptable

mask

mask and glass and
(tablet or display or
screen or edge or
perimeter)

mask

Will provide in
separate
correspondence

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Please provide
examples of false hits
if Apple claims this
term is overly

Diane Hutnyan
January 5, 2012
Page Eight
burdensome
look or feel

look within 10 of feel Apple’s proposed
search is sufficient

N/A

simpl*

simpl* within 10 of
design

simpl* within 10 of
(design or form or
factor or appearance
or impression or
phone)

simpl* within 10 of
(design or form or
factor or appearance
or impression)

minimal*

minimal* within 10
of design

minimal* within 10
of (design or form or
factor or appearance
or impression or
phone)

acceptable

speaker or slot

speaker within 25 of
slot

(speaker or “ear
piece”) within 25
(slot or opening or
location or shape)

acceptable

bezel

bezel and (iPhone or
REDACTED
iPad or

bezel and (iPhone or
iPad orREDACTED

acceptable

or
phone or screen or
glass)
chamfer

chamfer within 25 of
(bezel or rim or
receiver)

Apple’s proposed
response is sufficient

N/A

button

button within 10 of
(home or menu or
volume or hold)

button within 10 of
(home or menu or
volume or hold or
locat* or recess* or
concave or circ*& or
quit or calm or lent*)

acceptable

tablet

tablet within 10 of

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Diane Hutnyan
January 5, 2012
Page Nine
computer

Search terms for Messrs. Chaudhri and Anzures:
grid

grid within 20 of
icon

grid within 20 of
(icon* or pattern* or
layout or display or
align* or line* or
springboard or row)

grid within 20 of
(icon* or pattern* or
layout or display or
align* or springboard
or row)

array

array within 20 of
icon

array within 20 of
(icon* or pattern* or
layout or display or
align* or line* or
grid or springboard
or row)

acceptable

columns

columns within 20 of
icon

column* within 20 of
(icon* or pattern* or
layout or display or
align* or line* or
grid or springboard
or row)

column* within 10 of
(icon* or pattern* or
layout or display or
align* or line* or
grid or springboard
or row)

message within 20 of
(icon or metaphor)

none — no basis for
relevance

message within 20 of
(icon or metaphor)

“message icon” or
message within 20 of
metaphor

These terms are
relevant to the text
message (or instant
message) icon
depicted in the
patented designs, as
well as the
trademark for the
messaging icon.
dock

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dock within 10 of
(icon or bottom or

dock within 20 of
(icon* or bottom or
row or phone or

dock within 10 of
(icon* or bottom or
row or phone or

Diane Hutnyan
January 5, 2012
Page Ten
row)

status within 5 of bar

homescreen or
springboard or
place* or arrang* or
config* or layout or
transparen* or thumb
or convenien* or
locat*)

homescreen or
springboard or
place* or arrang* or
config* or layout or
transparen* or thumb
or convenien* or
locat*)

none – no basis for
relevance

status within 5 of bar

status bar within 5 of
(icon or design)

These terms are
relevant to the status
bar at the top of the
homescreen, which is
depicted in the UI
design patents.
springboard

springboard within
springboard within
10 of (icon or GUI or 20 of (phone or
interface)
iphone or icon* or
GUI or UI or
interface or design or
patent* or grid or
column* or look or
dock or dots or
intuitive or function*
or intent* or easy or
convenien* or thumb
or navigate or unique
or novel or wada)

springboard within 5
of (phone or iphone
or icon* or GUI or
UI or interface or
design or patent* or
grid or column* or
dock or dots or
intuitive or function*
or intent* or easy or
convenien* or thumb
or navigate or unique
or novel or wada)

target

none — no basis for
relevance

acceptable

target within 25
(audience or user or
customer or
purchaser)

Apple’s Responses to Certain RFPs
Samsung requests that Apple confirm it is “producing all documents and tangibles” relating
to several specifically enumerated requests for production relating to willful infringement by
Samsung of Apple’s trade dress, trademarks, and design patents, namely Request Nos. 146,
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Diane Hutnyan
January 5, 2012
Page Eleven
152, 154, 156, 157, 159, 162, 165, 179, 181, 182, and 192. This issue was raised by
Samsung for the first time by letter on December 30, and is unripe for lead counsel meetand-confer or a motion to compel.
It is unclear to Apple why Samsung has suddenly taken issue, without any meet-and-confer,
with these specific requests for production. Nor is it clear what Samsung seeks by its
requested confirmation. As stated in Apple’s responses to the relevant requests for
production, subject to and without waiving its objections, Apple has produced or will
produce responsive, non-privileged documents in its possession, custody, or control, if any,
located after a reasonable search.
Ive Deposition
Samsung has requested a second day of deposition with Jonathan Ive. Again, this is an
unripe issue raised for the first time in Samsung’s letter of December 31. Samsung has set
out no basis for its request, simply stating that it needs another day of deposition with
Mr. Ive and demanding a deposition within the next two weeks.
Samsung had its full measure of deposition time with Mr. Ive. Samsung chose when to take
the deposition. Apple will not present Mr. Ive for another day of deposition.
Stanford Archive
Samsung claims that Apple has failed to make available documents and things in the
Stanford archive. Yet again, this is an issue raised for the first time in Samsung’s letter of
January 1, 2012. There has been no prior correspondence on this and no meet-and-confer.
Samsung is seeking Apple’s assistance to access a “large collection of the company’s
historical documents and artifacts” donated to Stanford.
Apple will send a letter to the archive asking Stanford to give access to Samsung. Please let
us know the names of the attorneys who will conduct the review. Please also confirm that
Samsung will timely produce any documents or things that it obtains from the archive.
****
Six of Samsung’s eighteen topics—the most substantive—were raised for the first time on
the last days of December or first days of January with no prior correspondence and no meetand-confer. It is a waste of both Mr. McElhinny’s and Mr. Verhoeven’s time for one party to
bombard the other with letters that simultaneously a) raise issues for the first time and b)
purport to tee them up for lead-counsel meet-and-confer. Please refrain from this abusive
attempt to circumvent the meet-and-confer process in the future.

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Diane Hutnyan
January 5, 2012
Page Twelve
Sincerely,
/s/ Jason R. Bartlett
Jason R. Bartlett
Attachment

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Diane Hutnyan
January 5, 2012
Page Thirteen

Samsung Request
Mac OS 10.0
working
computer with
brightness
adjustment
button

Memory card
containing
Samsung
photographs of
Apple tablet
models.
De-designated
photographs of
the 035 Model

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What Apple Has Produced or Will
What Apple Will Not
Produce
Produce
Source code relating to feature at
N/A
issue (12/15)
Working computer loaded with OS
10.0 (12/15)
Follow-up production of requested
additional code (12/23)
Apple is continuing to investigate
the brightness button issue.
Memory card (1/3/2012)
De-designated photographs of the
035 Model with information going
beyond PTO record redacted

De-designated
photographs with
unredacted scale
information or
closeups showing
more information
than is present in
PTO record

Diane Hutnyan
January 5, 2012
Page Fourteen
Samsung Request
Documents
containing the
search term
“Samsung”

Customer
Surveys and
other market
research

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What Apple Has Produced or Will
What Apple Will Not
Produce
Produce
Searches for Apple documents
Search for
containing the term “Samsung”
“Android” or
conducted on Apple inventor
“Droid” without
documents
additional
delimiters
Searches for Apple documents
containing the term “Samsung”
will be conducted on product
marketing, advertising, and market
research files relating to research
conducted by Apple by January
31, 2012.
Searches for Apple documents
containing the term “Android” or
“Droid” with the delimiter
DomainSender = Apple, as absent
a delimiter, such a search returns
tens of thousands of irrelevant
documents that would take months
to review.
Final survey reports,
“All” documents
questionnaires and raw survey data
relating to
for all customer surveys conducted
customer surveys
by Apple relating to iPhone, iPod
(overbroad,
touch and iPad (1/31/2012)
unreasonably
duplicative,
All market research reports
burdensome)
purchased by Apple in the
ordinary course of business
relating to iPhone, iPod touch and
iPad. (1/31/2012)

Diane Hutnyan
January 5, 2012
Page Fifteen
Samsung Request
Financial
Documents

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What Apple Has Produced or Will
Produce
U.S. and world wide units by
quarter from FY 2007 to 2011 for
iPhone, iPod touch and iPad
(1/13/2012)
U.S. and world wide revenue by
quarter from FY 2007 to 2011 for
iPhone, iPod touch and iPad
(1/13/2012)
GAAP line of business reports
setting forth Standard Margins,
Adjusted Standard Margins, Gross
Margins, allocated SG&A, and
Research and Development Costs
for iPhone, iPad and iPod for
FY2007 to 2011 (1/13/2012)
Bill of Materials for all accused
Apple products (including line
item cost information) (1/13/2012)
Capital expenditure data for the
U.S. and world wide relating to
iPhone, iPad and iPod (1/13/2012)

What Apple Will Not
Produce
“All” Financial
Documents
(unreasonably
duplicative,
burdensome, and
unreliable)

Diane Hutnyan
January 5, 2012
Page Sixteen
Samsung Request
REDA
CTED

Working Apple
prototypes
Models

What Apple Has Produced or Will
Produce
CAD for original iPhone
(produced during PI phase)
CAD for all other announced
iPhone, iPod touch, and iPad
products (12/30/2011)
Sketchbooks relating to announced
iPhone, iPod touch, and iPad
products (12/30/2011)
All emails and electronic files of
Industrial Designers (rolling
production substantially completed
in October 2011)
All models, partial models, and
parts relating to announced
iPhone, iPod touch and iPad
products (1/15/2012)

What Apple Will Not
Produce
N/A

REDACTED

NeXT OS
Source Code

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Working prototypes
All available NeXT OS source
code (1/13/2012)

N/A

Diane Hutnyan
January 5, 2012
Page Seventeen
Samsung Request
All documents
relating to Tiger
operating system
(Mac OS 10.4)

REDACTED

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What Apple Has Produced or Will
Produce
Copy of Mac OS Tiger with
screenshot showing “dock” icons.

REDACTED

What Apple Will Not
Produce
“All” documents
relating to Tiger
(burdensome,
irrelevant; theory
of relevance is
some icons in iOS,
shown in asserted
design patent, are
were found in
Tiger “dock”; no
reason to produce
any source code,
much less “all
documents relating
to Tiger” based on
that)
N/A

Diane Hutnyan
January 5, 2012
Page Eighteen
Samsung Request
Advertising
Documents

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What Apple Has Produced or Will
Produce
Representative advertising relating
to iPhone and iPod touch
(produced during PI phase)
Advertising campaign binders
(1/31/2011)
Media plans (1/20/2011)
Print advertisements (1/13/2011)
Television advertisements
(1/13/2011)
Outdoor advertisements
(1/13/2011)
Report of database of iPhone, iPad
and iPod touch in media
(1/13/2011)
“Click count” reports for Search
Engine Marketing (1/20/2011)
Online display advertisements
(1/31/2011)
Direct marketing messages
(1/31/2011)
Billets reports (audit of advertising
as run) (1/31/2011)
Also, primary and secondary
market research data as discussed
below (see customer surveys and
market research)

What Apple Will Not
Produce
“All” documents
relating to
advertising
“builds,” as Apple
has not found any
such document
type.
“All” documents
relating to
advertising and
marketing
generally (vague,
overbroad)

Diane Hutnyan
January 5, 2012
Page Nineteen
Samsung Request
Industrial
Designer
sketchbooks
dated between
1/2002 and
1/2003

What Apple Has Produced or Will
Produce
Industrial Designer Sketchbooks
dated from 1/2003 to the present
to the extent related to announced
iPhone, iPod touch, and iPad
products (rolling production
concluded 12/30/2011)

Keyword
Searches of
Inventor
Documents

All electronic searches Samsung
requested in its letter of November
29 except for certain overbroad
search terms (e.g. “look” and
“feel”).
Apple proposed alternatives to
Samsung’s overbroad searches in
its letter of December 24.
Samsung submitted a
counterproposal on December 30.

Certain Samsung
RFPs Relating to
Infringement /
Willful
Infringement.

Have already produced nonprivileged Samsung negotiations
documents
Any other responsive documents
located will be produced as they
are found after a reasonable
search.

sf-3090097

What Apple Will Not
Produce
Sketchbooks dating
from January 2002
to January 2003
(Samsung could
have specifically
requested much
earlier, but did not.
Samsung has
provided no reason
to think that preJanuary 2003
sketchbooks are
relevant).
Apple’s position
on Samsung’s
counterproposal is
in the letter to
which this chart is
attached.

N/A

Diane Hutnyan
January 5, 2012
Page Twenty
Samsung Request
A second day of
deposition with
J. Ive
(12/31/2012

Access to the
Stanford Archive
of Apple
materials
(1/1/2012)

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What Apple Has Produced or Will
Produce
Depositions of every inventor on
every asserted patent, including all
Industrial Designers

Apple will send a letter to the
archive asking Stanford to give
access to Samsung.

What Apple Will Not
Produce
A second
deposition of J. Ive
(Samsung’s
request, raised just
days ago, failed to
state any basis)
N/A