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 2
REDACTED VERSION

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
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HAROLD J. MCELHINNY (CA SBN 66781)
[e-mail]
MICHAEL A. JACOBS (CA SBN 111664)
[e-mail]
RICHARD S.J. HUNG (CA SBN 197425)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: [phone]

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WILLIAM F. LEE (pro hac vice)
[e-mail]
WILMER CUTLER PICKERING
HALE AND DORR LLP
60 State Street
Boston, Massachusetts 02109
Telephone: [phone]
Facsimile: [phone]
MARK D. SELWYN (SBN 244180)
[e-mail]
WILMER CUTLER PICKERING
HALE AND DORR LLP
950 Page Mill Road
Palo Alto, California 94304
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff and
Counterclaim-Defendant Apple Inc.

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION

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APPLE INC., a California corporation,

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Plaintiffs,

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Civil Action No. 11-CV-01846-LHK

vs.

APPLE INC.’S OBJECTIONS AND
RESPONSES TO SAMSUNG’S FIRST
SET OF REQUESTS FOR ADMISSION

SAMSUNG ELECTRONICS CO., LTD., a
Korean business entity, SAMSUNG
ELECTRONICS AMERICA, INC., a New
York corporation, and SAMSUNG
TELECOMMUNICATIONS AMERICA,
LLC, a Delaware limited liability company,

CONFIDENTIAL UNDER THE
PROTECTIVE ORDER

Defendants.

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APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
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SAMSUNG ELECTRONICS CO., LTD., a
Korean business entity, SAMSUNG
ELECTRONICS AMERICA, INC., a New
York corporation, and SAMSUNG
TELECOMMUNICATIONS AMERICA,
LLC, a Delaware limited liability company, a
California corporation,

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Counterclaim-Plaintiff,

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v.

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APPLE INC., a California corporation,

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Counterclaim-Defendants.

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PLAINTIFF AND COUNTERCLAIM-DEFENDANT APPLE INC.’S
RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION (1-55)

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Under Rules 26 and 36 of the Federal Rules of Civil Procedure and Local Rule 36, Apple

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Inc. (“Apple”) hereby objects and responds to the First Set of Requests for Admission to Apple
Inc. (Nos. 1-55) served by Samsung Electronics Co., Ltd., Samsung Electronic America, Inc. and

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Samsung Telecommunications America, LLC (collectively, “Samsung”) on September 16,
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2011.
GENERAL OBJECTIONS
Apple makes the following general responses and objections (“General Objections”) to
each definition, instruction, and request for admission propounded in Samsung’s First Set of
Requests for Admission to Apple Inc. These General Objections are hereby incorporated into

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each specific response. The assertion of the same, similar or additional objections or partial
responses to individual requests does not waive any of Apple’s General Objections.

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APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
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1.

Apple objects to Samsung’s definitions of “APPLE,” “PLAINTIFF,” “YOU,” and

“YOUR” to the extent they purport to include persons or entities that are separate and distinct
from Apple and are not under Apple’s control. “Apple” refers only to Apple Inc.

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2.

Apple objects to Samsung’s Instruction No. 1 because it is vague, ambiguous,

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overly broad, and unduly burdensome. Apple further objects to this instruction on the ground that

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it purports to impose upon Apple duties and obligations that are inconsistent with and in excess

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of those obligations that are imposed by the Federal Rules of Civil Procedure and the Civil Local

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Rules. Apple further objects to this instruction because it calls for the disclosure of information

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that is privileged and protected by the work product doctrine.

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3.

Apple provides these objections and responses to the best of its current

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knowledge. Discovery or further investigation may reveal additional or different information

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warranting amendment of these objections and responses. Apple reserves the right to produce at

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trial and make reference to any evidence, facts, documents, or information not discovered at this

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time, omitted through good-faith error, mistake, or oversight, or the relevance of which Apple

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has not presently identified.
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4.

By responding to these requests for admission, Apple does not concede the

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relevance or materiality of any of the requests for admission or of the subjects to which it refers.

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Apple’s responses are made subject to, and without waiving any objections as to the competency,

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relevancy, materiality, privilege, or admissibility of any of the responses, or of the subject matter

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to which they concern, in any proceeding in this action or in any other proceeding.

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5.

Apple objects to any request for admission to the extent that it seeks information

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that is protected from disclosure by the attorney-client privilege, the attorney work product

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doctrine, the joint defense or common interest privilege, or any other applicable privilege,

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APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
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doctrine, or discovery immunity. The inadvertent production by Apple of information protected

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from disclosure by any such privilege, doctrine, or immunity shall not be deemed a waiver by

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Apple of such privileges or protections. Pursuant to the parties’ agreement, to the extent any

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request for admission calls for the identification of information dated after April 15, 2011 that is
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protected by such privilege, doctrine, or immunity, such information will not be included on

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Apple’s privilege log.

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6.

Apple objects generally to the Requests for Admission to the extent they seek

confidential, proprietary, or trade secret information of third parties. Apple will endeavor to
work with third parties in order to obtain their consent, if necessary, before providing such

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information. To the extent a request for admission seeks information of a confidential or

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proprietary nature to Apple, or to others to whom Apple is under an obligation of confidentiality,

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Apple will respond pursuant to the terms of the protective order to be entered in this case and

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subject to notice to third parties, as necessary.

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7.

Apple objects to Samsung’s definition of “APPLE ACCUSED PRODUCTS” to

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the extent it is overly broad and unduly burdensome and to the extent it seeks information that is
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neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Apple

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further objects to Samsung’s definition of “Apple Accused Products” to the extent that it requires

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a legal conclusion. For purposes of responding to these Requests, Apple interprets the term

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“Apple Accused Products” to mean those products that are specifically identified and accused in

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Samsung’s Patent Local Rule 3-1 Infringement Contentions, served on September 7, 2011.

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8.

Apple objects to any request for admission to the extent it is premature and/or to

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the extent that it: (a) conflicts with the schedule entered by the Court; (b) conflicts with

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obligations that are imposed by the Federal Rules of Civil Procedure, the Civil Local Rules

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APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
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and/or the Patent Local Rules of this Court, and/or any other applicable rule; (c) seeks

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information that is the subject of expert testimony; (d) seeks information and/or responses that

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are dependent on the Court’s construction of the asserted claims of the patents-in-suit; and/or (e)

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seeks information and/or responses that are dependent on depositions and documents that have
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not been taken or produced.
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Apple objects to each request for admission as overbroad and unduly burdensome

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to the extent that it calls for information that is neither relevant to the claims or defenses of the

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parties nor reasonably calculated to lead to the discovery of admissible evidence.

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10.

Apple objects to each request for admission and to Samsung’s “Definitions” and

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“Instructions” to the extent they are vague, ambiguous, overbroad, or unduly burdensome, or

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purport to impose upon Apple any duty or obligation that is inconsistent with or in excess of

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those obligations that are imposed by the Federal Rules of Civil Procedure, the Civil Local Rules

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and/or the Patent Local Rules of this Court, or any other applicable rule.

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Apple objects to any Request for Admission to the extent it seeks irrelevant

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information about Apple’s products or business operations. Such requests are overbroad and
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unduly burdensome. Apple will only produce information that is relevant to the patents-in-suit,
or that is otherwise related to the claims or defenses asserted by the parties in this litigation.
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Apple objects to each Request for Admission to the extent that it would impose a

duty on Apple to undertake a search for or an evaluation of information, documents, or things for
which Samsung is equally able to search for and evaluate. In particular, Apple objects to each

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request for admission to the extent that it seeks information or documents that are publicly
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available.

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APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
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13.

Apple objects to each Request for Admission to the extent that it seeks

information that can be derived or ascertained from documents that will be produced in
discovery or that are uniquely in Samsung’s possession, custody, and control.

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Apple objects to each Request for Admission to the extent it would require Apple

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to make a legal conclusion or contention to make a proper response.
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Apple objects to any Definition, Instruction or Request for Admission to the

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extent that it purports to require identification of oral communications. Such Definition,

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Instruction or Request for Admission is overbroad, vague, ambiguous, and unduly burdensome.

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Apple objects to the definition of the terms “referring to,” “relating to,”

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“concerning,” or “regarding” as vague, ambiguous, overbroad, and unduly burdensome to the

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extent that they depart from Apple’s own definitions of these terms, as defined in Apple’s Third

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Set of Interrogatories, dated August 3, 2011.

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Apple objects to the definition of the term “3GPP” as vague, ambiguous,

overbroad and unduly burdensome to the extent it departs from Apple’s own definition of this

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term, as defined in Apple’s Third Set of Requests for Production of Documents.
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Apple objects to the definition of “Software” as overly broad, vague, ambiguous,

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and unduly burdensome, especially with regards to the term “listings.” Apple further objects

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because much of the uncompiled “hardware code, machine code, assembly code” for hardware

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provided by third parties is not within Apple’s possession, custody or control.

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Apple objects to the definition of “Executable Software” as overly broad, vague,

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ambiguous, and unduly burdensome, especially with regards to the phrase “any release notes.”
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APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
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20.

Apple objects to the definition of “Hardware” as overly broad, vague,

ambiguous, and unduly burdensome, especially with regards to the term “hardware-based
capabilities.”

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Apple objects to the definition of “Baseband Processor” because it is inaccurate,

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overly broad, vague, ambiguous, and unduly burdensome, especially with regards to the phrase

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“mainly used to process communication functions.”

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22.

Apple objects to the Requests for Admission to the extent that they purport to

define words or phrases to have a meaning different from their commonly understood meaning,
or to include more than their commonly understood definitions.

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23.

In Apple’s objections, the terms “and” and “or” are intended to be construed

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conjunctively or disjunctively as necessary to make the objections inclusive rather than

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exclusive.

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Apple objects to the Requests for Admission to the extent they purport to require

Apple to identify or describe or identify “every,” “each,” “any,” or other similarly expansive,

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infinite, or all-inclusive terms to the extent that such requests are overly broad and unduly
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burdensome.
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Apple objects to the Requests for Admission to the extent they seek information

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that is not in the possession, custody, or control of Apple, purport to require Apple to speculate

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about the identity of persons who might have responsive documents, and/or purport to call for

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any description of documents that Apple no longer possesses and/or was under no obligation to

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maintain.
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Apple objects to the Requests for Admission to the extent they are not limited in

time and seek information for periods of time that are not relevant to any claim or defense.

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APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
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27.

Apple’s objections as set forth herein are made without prejudice to Apple’s right

to assert any additional or supplemental objections pursuant to Rule 26(e).
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Apple will make, and has made, reasonable efforts to respond to Samsung’s First

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Set of Requests for Admission, to the extent that no objection is made, as Apple reasonably
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understands and interprets each Request for Admission. If Samsung subsequently asserts any

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interpretation of any Request for Admission that differs from the interpretation of Apple, then

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Apple reserves the right to supplement and amend its objections and responses.

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OBJECTIONS AND RESPONSES TO REQUESTS FOR ADMISSION

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Subject to the foregoing qualifications and General Objections and the specific objections

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made below, Apple objects and responds to Samsung Electronics Co. Ltd.’s First Set of Requests

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for Admission to Apple Inc. as follows:

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REQUEST FOR ADMISSION NO. 1:

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Admit that the Baseband Processors in each APPLE ACCUSED PRODUCT use 16QAM
modulation.

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RESPONSE TO REQUEST FOR ADMISSION NO. 1:

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Apple objects to this Request on the grounds that it is overly broad, unduly burdensome,

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and not reasonably calculated to lead to the discovery of admissible evidence to the extent that it

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is not limited in time. Apple objects to this Request to the extent it seeks information that is

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subject to a confidentiality or non-disclosure agreement or governed by a protective order
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preventing its production, or otherwise seeks confidential, proprietary or trade secret information

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of third parties. Apple further objects to this Request for Admission to the extent it requires

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information outside Apple’s possession, custody and control, including, for example, information

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concerning components that Apple has purchased from third parties. REDACTED

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APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
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REDACTED

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REQUEST FOR ADMISSION NO. 2
Admit that the Baseband Processors in the Apple iPhone use 16QAM modulation.
RESPONSE TO REQUEST FOR ADMISSION NO. 2
Apple objects to this Request on the grounds that it is duplicative of Request for

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Admission No. 1. Apple objects to this Request on the grounds that it is overly broad, unduly
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burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the

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extent that it is not limited in time. Apple objects to this Request to the extent it seeks

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information that is subject to a confidentiality or non-disclosure agreement or governed by a

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protective order preventing its production, or otherwise seeks confidential, proprietary or trade

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secret information of third parties. Apple further objects to this Request for Admission to the

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extent it requires information outside Apple’s possession, custody and control, including, for

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example, information concerning components that Apple has purchased from third parties.

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REDACTED

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APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
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REDACTED

REQUEST FOR ADMISSION NO. 3:
Admit that the Baseband Processors in the Apple iPhone 3G use 16QAM modulation.
RESPONSE TO REQUEST FOR ADMISSION NO. 3:

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Apple objects to this Request on the grounds that it is duplicative of Request for
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Admission No. 1. Apple objects to this Request on the grounds that it is overly broad, unduly

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burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the

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extent that it is not limited in time. Apple objects to this Request to the extent it seeks

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information that is subject to a confidentiality or non-disclosure agreement or governed by a
protective order preventing its production, or otherwise seeks confidential, proprietary or trade

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secret information of third parties. Apple further objects to this Request for Admission to the
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extent it requires information outside Apple’s possession, custody and control, including, for

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example, information concerning components that Apple has purchased from third parties.

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REDACTED

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REQUEST FOR ADMISSION NO. 4:
Admit that the Baseband Processors in the Apple iPhone 3GS use 16QAM modulation.
RESPONSE TO REQUEST FOR ADMISSION NO. 4:

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Apple objects to this Request on the grounds that it is duplicative of Request for

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Admission No. 1. Apple objects to this Request on the grounds that it is overly broad, unduly

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burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the

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extent that it is not limited in time. Apple objects to this Request to the extent it seeks

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APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
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information that is subject to a confidentiality or non-disclosure agreement or governed by a

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protective order preventing its production, or otherwise seeks confidential, proprietary or trade

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secret information of third parties. Apple further objects to this Request for Admission to the

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extent it requires information outside Apple’s possession, custody and control, including, for
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example, information concerning components that Apple has purchased from third parties.
REDACTED

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REQUEST FOR ADMISSION NO. 5:

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Admit that the Baseband Processors in the Apple iPhone 4 use 16QAM modulation.
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RESPONSE TO REQUEST FOR ADMISSION NO. 5:

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Apple objects to this Request on the grounds that it is duplicative of Request for

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Admission No. 1. Apple objects to this Request on the grounds that it is overly broad, unduly

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burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the

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extent that it is not limited in time. Apple objects to this Request to the extent it seeks

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information that is subject to a confidentiality or non-disclosure agreement or governed by a

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protective order preventing its production, or otherwise seeks confidential, proprietary or trade

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secret information of third parties. Apple further objects to this Request for Admission to the

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extent it requires information outside Apple’s possession, custody and control, including, for

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example, information concerning components that Apple has purchased from third parties.

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REDACTED

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APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

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REQUEST FOR ADMISSION NO. 6:
Admit that the Baseband Processors in the iPod Touch use 16QAM modulation.
RESPONSE TO REQUEST FOR ADMISSION NO. 6:
Apple objects to this Request on the grounds that it is duplicative of Request for

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Admission No. 1. Apple objects to this Request on the grounds that it is overly broad, unduly
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burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the

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extent that it is not limited in time. Apple objects to this Request to the extent it seeks

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information that is subject to a confidentiality or non-disclosure agreement or governed by a

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protective order preventing its production, or otherwise seeks confidential, proprietary or trade
secret information of third parties. Apple further objects to this Request for Admission to the

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extent it requires information outside Apple’s possession, custody and control, including, for
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example, information concerning components that Apple has purchased from third parties.
REDACTED

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REQUEST FOR ADMISSION NO. 7:
Admit that the Baseband Processors in the iPad use 16QAM modulation.
RESPONSE TO REQUEST FOR ADMISSION NO. 7:
Apple objects to this Request on the grounds that it is duplicative of Request for
Admission No. 1. Apple objects to this Request on the grounds that it is overly broad, unduly

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APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
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burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the

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extent that it is not limited in time. Apple objects to this Request to the extent it seeks

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information that is subject to a confidentiality or non-disclosure agreement or governed by a

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protective order preventing its production, or otherwise seeks confidential, proprietary or trade
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secret information of third parties. Apple further objects to this Request for Admission to the

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extent it requires information outside Apple’s possession, custody and control, including, for

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example, information concerning components that Apple has purchased from third parties.

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REDACTED

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REQUEST FOR ADMISSION NO. 8:
Admit that the Baseband Processors in the iPad 3G use 16QAM modulation.

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RESPONSE TO REQUEST FOR ADMISSION NO. 8:
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Apple objects to this Request on the grounds that it is duplicative of Request for

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Admission No. 1. Apple objects to this Request on the grounds that it is overly broad, unduly

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burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the

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extent that it is not limited in time. Apple objects to this Request to the extent it seeks

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information that is subject to a confidentiality or non-disclosure agreement or governed by a

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protective order preventing its production, or otherwise seeks confidential, proprietary or trade
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secret information of third parties. Apple further objects to this Request for Admission to the

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APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
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extent it requires information outside Apple’s possession, custody and control, including, for

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example, information concerning components that Apple has purchased from third parties.

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REDACTED

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.

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REQUEST FOR ADMISSION NO. 9:
Admit that the Baseband Processors in the iPad 2 use 16QAM modulation.
RESPONSE TO REQUEST FOR ADMISSION NO. 9:
Apple objects to this Request on the grounds that it is duplicative of Request for
Admission No. 1. Apple objects to this Request on the grounds that it is overly broad, unduly

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burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the
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extent that it is not limited in time. Apple objects to this Request to the extent it seeks

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information that is subject to a confidentiality or non-disclosure agreement or governed by a

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protective order preventing its production, or otherwise seeks confidential, proprietary or trade

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secret information of third parties. Apple further objects to this Request for Admission to the

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extent it requires information outside Apple’s possession, custody and control, including, for

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example, information concerning components that Apple has purchased from third parties.
REDACTED

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APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
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REQUEST FOR ADMISSION NO. 10:
Admit that the Baseband Processors in the iPad 2 3G use 16QAM modulation.
RESPONSE TO REQUEST FOR ADMISSION NO. 10:
Apple objects to this Request on the grounds that it is duplicative of Request for

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Admission No. 1. Apple objects to this Request on the grounds that it is overly broad, unduly
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burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the

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extent that it is not limited in time. Apple objects to this Request to the extent it seeks

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information that is subject to a confidentiality or non-disclosure agreement or governed by a

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protective order preventing its production, or otherwise seeks confidential, proprietary or trade
secret information of third parties. Apple further objects to this Request for Admission to the

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extent it requires information outside Apple’s possession, custody and control, including, for
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example, information concerning components that Apple has purchased from third parties.
REDACTED

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REQUEST FOR ADMISSION NO. 11:

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Admit that the Apple iPhone 3G incorporates the following Baseband Processor: Infineon
PMB 8878 (X-GOLD 608).

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RESPONSE TO REQUEST FOR ADMISSION NO. 11:

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Apple objects to this Request on the grounds that it is overly broad, unduly burdensome,

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and not reasonably calculated to lead to the discovery of admissible evidence to the extent that it
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is not limited in time. Apple objects to this Request to the extent it seeks information that is
subject to a confidentiality or non-disclosure agreement or governed by a protective order

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APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
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preventing its production, or otherwise seeks confidential, proprietary or trade secret information

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of third parties.

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REDACTED

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REQUEST FOR ADMISSION NO. 12:

7

Admit that the Apple iPhone 3G is compliant with 3GPP Technical Specification 25.212
v.6.0.0.

8
RESPONSE TO REQUEST FOR ADMISSION NO. 12:
9
10

Apple objects to this Request on the grounds that the term “compliant” is vague and

11

ambiguous. Apple further objects to this Request on the grounds that it is overly broad, unduly

12

burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the

13

extent that it is not limited in time. Apple also objects to this Request to the extent it seeks

14

information that is subject to a confidentiality or non-disclosure agreement or governed by a

15
protective order preventing its production, or otherwise seeks confidential, proprietary or trade
16
17

secret information of third parties. Apple further objects to this Request for Admission to the

18

extent it requires information outside Apple’s possession, custody and control, including, for

19

example, information concerning components that Apple has purchased from third parties.

20

REDACTED

21
22
23
24

REQUEST FOR ADMISSION NO. 13:

25

Admit that the Baseband Processor used in Apple iPhone 3G is compliant with 3GPP
Technical Specification 25.212 v.6.0.0.

26
27
28
16

APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
1
2
3
4

RESPONSE TO REQUEST FOR ADMISSION NO. 13:
Apple objects to this Request on the grounds that the term “compliant” is vague and
ambiguous. Apple further objects to this Request on the grounds that it is overly broad, unduly
burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the

5
6

extent that it is not limited in time. Apple also objects to this Request to the extent it seeks

7

information that is subject to a confidentiality or non-disclosure agreement or governed by a

8

protective order preventing its production, or otherwise seeks confidential, proprietary or trade

9

secret information of third parties. Apple further objects to this Request for Admission to the

10

extent it requires information outside Apple’s possession, custody and control, including, for

11
example, information concerning components that Apple has purchased from third parties.
12
REDACTED

13
14
15
16
17

REQUEST FOR ADMISSION NO. 14:

18

Admit that the Apple iPhone 3G is compliant with 3GPP Technical Specification 25.212
v.5.0.0.

19

RESPONSE TO REQUEST FOR ADMISSION NO. 14:

20
21
22

Apple objects to this Request on the grounds that the term “compliant” is vague and
ambiguous. Apple further objects to this Request on the grounds that it is overly broad, unduly
burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the

23
24

extent that it is not limited in time. Apple also objects to this Request to the extent it seeks

25

information that is subject to a confidentiality or non-disclosure agreement or governed by a

26

protective order preventing its production, or otherwise seeks confidential, proprietary or trade

27

secret information of third parties. Apple further objects to this Request for Admission to the

28
17

APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
1

extent it requires information outside Apple’s possession, custody and control, including, for

2

example, information concerning components that Apple has purchased from third parties.

3

REDACTED

4
5
6
7

REQUEST FOR ADMISSION NO. 15:

8

Admit that the Baseband Processor used in Apple iPhone 3G is compliant with 3GPP
Technical Specification 25.212 v.5.0.0.

9
10
11

RESPONSE TO REQUEST FOR ADMISSION NO. 15:
Apple objects to this Request on the grounds that the term “compliant” is vague and

12

ambiguous. Apple further objects to this Request on the grounds that it is overly broad, unduly

13

burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the

14

extent that it is not limited in time. Apple also objects to this Request to the extent it seeks

15
information that is subject to a confidentiality or non-disclosure agreement or governed by a
16
17

protective order preventing its production, or otherwise seeks confidential, proprietary or trade

18

secret information of third parties. Apple further objects to this Request for Admission to the

19

extent it requires information outside Apple’s possession, custody and control, including, for

20

example, information concerning components that Apple has purchased from third parties.

21

REDACTED

22
23
24
25

REQUEST FOR ADMISSION NO. 16

26

Admit that the Apple iPhone 3GS incorporates the following Baseband Processor:
Infineon PMB 8878 (X-GOLD 608).

27
28

18

APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
1

RESPONSE TO REQUEST FOR ADMISSION NO. 16

2

Apple objects to this Request on the grounds that it is overly broad, unduly burdensome,

3

and not reasonably calculated to lead to the discovery of admissible evidence to the extent that it

4

is not limited in time. Apple objects to this Request to the extent it seeks information that is

5
6

subject to a confidentiality or non-disclosure agreement or governed by a protective order

7

preventing its production, or otherwise seeks confidential, proprietary or trade secret information

8

of third parties.

9

REDACTED

10
11
REQUEST FOR ADMISSION NO. 17:
12
13
14
15

Admit that the Apple iPhone 3GS is compliant with 3GPP Technical Specification
25.212 v.6.0.0.
RESPONSE TO REQUEST FOR ADMISSION NO. 17:
Apple objects to this Request on the grounds that the term “compliant” is vague and

16
17

ambiguous. Apple further objects to this Request on the grounds that it is overly broad, unduly

18

burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the

19

extent that it is not limited in time. Apple also objects to this Request to the extent it seeks

20

information that is subject to a confidentiality or non-disclosure agreement or governed by a

21

protective order preventing its production, or otherwise seeks confidential, proprietary or trade

22

secret information of third parties. Apple further objects to this Request for Admission to the

23
24
25
26

extent it requires information outside Apple’s possession, custody and control, including, for
example, information concerning components that Apple has purchased from third parties.
REDACTED

27
28
19

APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
1

REDACTED

2
3
4

REQUEST FOR ADMISSION NO. 18:

5

Admit that the Baseband Processor used in Apple iPhone 3GS is compliant with 3GPP
Technical Specification 25.212 v.6.0.0.

6

RESPONSE TO REQUEST FOR ADMISSION NO. 18:

7

Apple objects to this Request on the grounds that the term “compliant” is vague and

8
ambiguous. Apple further objects to this Request on the grounds that it is overly broad, unduly
9
10

burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the

11

extent that it is not limited in time. Apple also objects to this Request to the extent it seeks

12

information that is subject to a confidentiality or non-disclosure agreement or governed by a

13

protective order preventing its production, or otherwise seeks confidential, proprietary or trade

14

secret information of third parties. Apple further objects to this Request for Admission to the

15
16
17
18

extent it requires information outside Apple’s possession, custody and control, including, for
example, information concerning components that Apple has purchased from third parties.
REDACTED

19
20
21

REQUEST FOR ADMISSION NO. 19:

22
23
24
25

Admit that the Apple iPhone 3GS is compliant with 3GPP Technical Specification
25.212 v.5.0.0.
RESPONSE TO REQUEST FOR ADMISSION NO. 19:
Apple objects to this Request on the grounds that the term “compliant” is vague and

26
27

ambiguous. Apple further objects to this Request on the grounds that it is overly broad, unduly

28
20

APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
1

burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the

2

extent that it is not limited in time. Apple also objects to this Request to the extent it seeks

3

information that is subject to a confidentiality or non-disclosure agreement or governed by a

4
protective order preventing its production, or otherwise seeks confidential, proprietary or trade
5
6

secret information of third parties. Apple further objects to this Request for Admission to the

7

extent it requires information outside Apple’s possession, custody and control, including, for

8

example, information concerning components that Apple has purchased from third parties.

9

REDACTED

10
11
12
13

REQUEST FOR ADMISSION NO. 20:

14

Admit that the Baseband Processor used in Apple iPhone 3GS is compliant with 3GPP
Technical Specification 25.212 v.5.0.0.

15
16
17

RESPONSE TO REQUEST FOR ADMISSION NO. 20:
Apple objects to this Request on the grounds that the term “compliant” is vague and

18

ambiguous. Apple further objects to this Request on the grounds that it is overly broad, unduly

19

burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the

20

extent that it is not limited in time. Apple also objects to this Request to the extent it seeks

21

information that is subject to a confidentiality or non-disclosure agreement or governed by a

22
protective order preventing its production, or otherwise seeks confidential, proprietary or trade
23
24

secret information of third parties. Apple further objects to this Request for Admission to the

25

extent it requires information outside Apple’s possession, custody and control, including, for

26

example, information concerning components that Apple has purchased from third parties.

27

REDACTED

28
21

APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
1

REDACTED

2
3
4

REQUEST FOR ADMISSION NO. 21:

5

Admit that the Apple iPad 3G incorporates the following Baseband Processor: Infineon
PMB 8878 (X-GOLD 608).

6

RESPONSE TO REQUEST FOR ADMISSION NO. 21:

7
8

Apple objects to this Request on the grounds that it is overly broad, unduly burdensome,
and not reasonably calculated to lead to the discovery of admissible evidence to the extent that it

9
10

is not limited in time. Apple objects to this Request to the extent it seeks information that is

11

subject to a confidentiality or non-disclosure agreement or governed by a protective order

12

preventing its production, or otherwise seeks confidential, proprietary or trade secret information

13

of third parties.

14

REDACTED

15
16
17
18
19

REQUEST FOR ADMISSION NO. 22:
Admit that the Apple iPad 3G is compliant with 3GPP Technical Specification 25.212
v.6.0.0.
RESPONSE TO REQUEST FOR ADMISSION NO. 22:

20
Apple objects to this Request on the grounds that the term “compliant” is vague and
21
22

ambiguous. Apple further objects to this Request on the grounds that it is overly broad, unduly

23

burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the

24

extent that it is not limited in time. Apple also objects to this Request to the extent it seeks

25

information that is subject to a confidentiality or non-disclosure agreement or governed by a

26

protective order preventing its production, or otherwise seeks confidential, proprietary or trade

27
28
22

APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
1

secret information of third parties. Apple further objects to this Request for Admission to the

2

extent it requires information outside Apple’s possession, custody and control, including, for

3
4

example, information concerning components that Apple has purchased from third parties.
REDACTED

5
6
7
8

REQUEST FOR ADMISSION NO. 23:

9
10

Admit that the Baseband Processor used in Apple iPad 3G is compliant with 3GPP
Technical Specification 25.212 v.6.0.0.

11

RESPONSE TO REQUEST FOR ADMISSION NO. 23:

12
13
14

Apple objects to this Request on the grounds that the term “compliant” is vague and
ambiguous. Apple further objects to this Request on the grounds that it is overly broad, unduly
burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the

15
extent that it is not limited in time. Apple also objects to this Request to the extent it seeks
16
17

information that is subject to a confidentiality or non-disclosure agreement or governed by a

18

protective order preventing its production, or otherwise seeks confidential, proprietary or trade

19

secret information of third parties. Apple further objects to this Request for Admission to the

20

extent it requires information outside Apple’s possession, custody and control, including, for

21
22

example, information concerning components that Apple has purchased from third parties.
REDACTED

23
24
25
26
27
28
23

APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
1

REQUEST FOR ADMISSION NO. 24:

2

Admit that the Apple iPad 3G is compliant with 3GPP Technical Specification 25.212
v.5.0.0.

3
4
5

RESPONSE TO REQUEST FOR ADMISSION NO. 24:
Apple objects to this Request on the grounds that the term “compliant” is vague and

6

ambiguous. Apple further objects to this Request on the grounds that it is overly broad, unduly

7

burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the

8

extent that it is not limited in time. Apple also objects to this Request to the extent it seeks

9
10

information that is subject to a confidentiality or non-disclosure agreement or governed by a

11

protective order preventing its production, or otherwise seeks confidential, proprietary or trade

12

secret information of third parties. Apple further objects to this Request for Admission to the

13

extent it requires information outside Apple’s possession, custody and control, including, for

14
15

example, information concerning components that Apple has purchased from third parties.
REDACTED

16
17
18
19

REQUEST FOR ADMISSION NO. 25:

20

Admit that the Baseband Processor used in Apple iPad 3G is compliant with 3GPP
Technical Specification 25.212 v.5.0.0.

21
22
23

RESPONSE TO REQUEST FOR ADMISSION NO. 25:
Apple objects to this Request on the grounds that the term “compliant” is vague and

24

ambiguous. Apple further objects to this Request on the grounds that it is overly broad, unduly

25

burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the

26

extent that it is not limited in time. Apple also objects to this Request to the extent it seeks

27
28
24

APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
1

information that is subject to a confidentiality or non-disclosure agreement or governed by a

2

protective order preventing its production, or otherwise seeks confidential, proprietary or trade

3

secret information of third parties. Apple further objects to this Request for Admission to the

4
extent it requires information outside Apple’s possession, custody and control, including, for
5
6
7

example, information concerning components that Apple has purchased from third parties.
REDACTED

8
9
10

REQUEST FOR ADMISSION NO. 26:

11
12

Admit that the Apple iPhone 4 incorporates the following Baseband Processor: Infineon
(X-GOLD 616).

13

RESPONSE TO REQUEST FOR ADMISSION NO. 26:

14

Apple objects to this Request on the grounds that the term “Infineon” is vague and

15
ambiguous. Apple further objects to this Request on the grounds that it is overly broad, unduly
16
17

burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the

18

extent that it is not limited in time. Apple also objects to this Request to the extent it seeks

19

information that is subject to a confidentiality or non-disclosure agreement or governed by a

20

protective order preventing its production, or otherwise seeks confidential, proprietary or trade

21
22

secret information of third parties.
REDACTED

23
24
25

REQUEST FOR ADMISSION NO. 27:
Admit that the Apple iPhone 4 is compliant with 3GPP Technical Specification 25.212

26
27

v.6.0.0.

28
25

APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
1
2
3
4

RESPONSE TO REQUEST FOR ADMISSION NO. 27:
Apple objects to this Request on the grounds that the term “compliant” is vague and
ambiguous. Apple further objects to this Request on the grounds that it is overly broad, unduly
burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the

5
6

extent that it is not limited in time. Apple also objects to this Request to the extent it seeks

7

information that is subject to a confidentiality or non-disclosure agreement or governed by a

8

protective order preventing its production, or otherwise seeks confidential, proprietary or trade

9

secret information of third parties. Apple further objects to this Request for Admission to the

10

extent it requires information outside Apple’s possession, custody and control, including, for

11
example, information concerning components that Apple has purchased from third parties.
12
REDACTED

13
14
15
16
17

REQUEST FOR ADMISSION NO. 28:

18

Admit that the Baseband Processor used in Apple iPhone 4 is compliant with 3GPP
Technical Specification 25.212 v.6.0.0.

19

RESPONSE TO REQUEST FOR ADMISSION NO. 28:

20
21
22

Apple objects to this Request on the grounds that the term “compliant” is vague and
ambiguous. Apple further objects to this Request on the grounds that it is overly broad, unduly
burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the

23
24

extent that it is not limited in time. Apple also objects to this Request to the extent it seeks

25

information that is subject to a confidentiality or non-disclosure agreement or governed by a

26

protective order preventing its production, or otherwise seeks confidential, proprietary or trade

27

secret information of third parties. Apple further objects to this Request for Admission to the

28
26

APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
1

extent it requires information outside Apple’s possession, custody and control, including, for

2

example, information concerning components that Apple has purchased from third parties.

3

REDACTED

4
5
6
7

REQUEST FOR ADMISSION NO. 29:
Admit that the Apple iPhone 4 is compliant with 3GPP Technical Specification 25.212

8
9
10
11

v.5.0.0.
RESPONSE TO REQUEST FOR ADMISSION NO. 29:
Apple objects to this Request on the grounds that the term “compliant” is vague and

12

ambiguous. Apple further objects to this Request on the grounds that it is overly broad, unduly

13

burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the

14

extent that it is not limited in time. Apple also objects to this Request to the extent it seeks

15
information that is subject to a confidentiality or non-disclosure agreement or governed by a
16
17

protective order preventing its production, or otherwise seeks confidential, proprietary or trade

18

secret information of third parties. Apple further objects to this Request for Admission to the

19

extent it requires information outside Apple’s possession, custody and control, including, for

20

example, information concerning components that Apple has purchased from third parties.

21

REDACTED

22
23
24
25

REQUEST FOR ADMISSION NO. 30:

26

Admit that the Baseband Processor used in Apple iPhone 4 is compliant with 3GPP
Technical Specification 25.212 v.5.0.0.

27
28

27

APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
1
2
3

RESPONSE TO REQUEST FOR ADMISSION NO. 30:
Apple objects to this Request on the grounds that the term “compliant” is vague and
ambiguous. Apple further objects to this Request on the grounds that it is overly broad, unduly

4
burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the
5
6

extent that it is not limited in time. Apple also objects to this Request to the extent it seeks

7

information that is subject to a confidentiality or non-disclosure agreement or governed by a

8

protective order preventing its production, or otherwise seeks confidential, proprietary or trade

9

secret information of third parties. Apple further objects to this Request for Admission to the

10

extent it requires information outside Apple’s possession, custody and control, including, for

11
12
13

example, information concerning components that Apple has purchased from third parties.
REDACTED

14
15
16
17

REQUEST FOR ADMISSION NO. 31:

18

Admit that the Apple iPad 2 incorporates the following Baseband Processor: Infineon (XGOLD 616).

19

RESPONSE TO REQUEST FOR ADMISSION NO. 31:

20
21

Apple objects to this Request on the grounds that the term “Infineon” is vague and
ambiguous. Apple further objects to this Request on the grounds that it is overly broad, unduly

22
burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the
23
24

extent that it is not limited in time. Apple also objects to this Request to the extent it seeks

25

information that is subject to a confidentiality or non-disclosure agreement or governed by a

26

protective order preventing its production, or otherwise seeks confidential, proprietary or trade

27

secret information of third parties.

28
28

APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
1
2
3

REDACTED

REQUEST FOR ADMISSION NO. 32:

4

Admit that the Apple iPad 2 is compliant with 3GPP Technical Specification 25.212
v.6.0.0.

5

RESPONSE TO REQUEST FOR ADMISSION NO. 32:

6
7

Apple objects to this Request on the grounds that the term “compliant” is vague and
ambiguous. Apple further objects to this Request on the grounds that it is overly broad, unduly

8
burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the
9
10

extent that it is not limited in time. Apple also objects to this Request to the extent it seeks

11

information that is subject to a confidentiality or non-disclosure agreement or governed by a

12

protective order preventing its production, or otherwise seeks confidential, proprietary or trade

13

secret information of third parties. Apple further objects to this Request for Admission to the

14

extent it requires information outside Apple’s possession, custody and control, including, for

15
16
17

example, information concerning components that Apple has purchased from third parties.
REDACTED

18

REQUEST FOR ADMISSION NO. 33:

19

Admit that the Baseband Processor used in Apple iPad 2 is compliant with 3GPP
Technical Specification 25.212 v.6.0.0.

20
21
22

RESPONSE TO REQUEST FOR ADMISSION NO. 33:
Apple objects to this Request on the grounds that the term “compliant” is vague and

23

ambiguous. Apple further objects to this Request on the grounds that it is overly broad, unduly

24

burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the

25

extent that it is not limited in time. Apple also objects to this Request to the extent it seeks

26
information that is subject to a confidentiality or non-disclosure agreement or governed by a
27
28
29

APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
1

protective order preventing its production, or otherwise seeks confidential, proprietary or trade

2

secret information of third parties. Apple further objects to this Request for Admission to the

3

extent it requires information outside Apple’s possession, custody and control, including, for

4
example, information concerning components that Apple has purchased from third parties.
5
REDACTED

6
7

REQUEST FOR ADMISSION NO. 34:

8

Admit that the Apple iPad 2 is compliant with 3GPP Technical Specification 25.212
v.5.0.0.

9
10
11

RESPONSE TO REQUEST FOR ADMISSION NO. 34:
Apple objects to this Request on the grounds that the term “compliant” is vague and

12

ambiguous. Apple further objects to this Request on the grounds that it is overly broad, unduly

13

burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the

14

extent that it is not limited in time. Apple also objects to this Request to the extent it seeks

15
information that is subject to a confidentiality or non-disclosure agreement or governed by a
16
17

protective order preventing its production, or otherwise seeks confidential, proprietary or trade

18

secret information of third parties. Apple further objects to this Request for Admission to the

19

extent it requires information outside Apple’s possession, custody and control, including, for

20

example, information concerning components that Apple has purchased from third parties.

21

REDACTED

22
23
24
25

REQUEST FOR ADMISSION NO. 35:
Admit that the Baseband Processor used in Apple iPad 2 is compliant with 3GPP
Technical Specification 25.212 v.5.0.0.
RESPONSE TO REQUEST FOR ADMISSION NO. 35:

26
27
28
30

APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
Apple objects to this Request on the grounds that the term “compliant” is vague and

1
2
3

ambiguous. Apple further objects to this Request on the grounds that it is overly broad, unduly
burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the

4
extent that it is not limited in time. Apple also objects to this Request to the extent it seeks
5
6

information that is subject to a confidentiality or non-disclosure agreement or governed by a

7

protective order preventing its production, or otherwise seeks confidential, proprietary or trade

8

secret information of third parties. Apple further objects to this Request for Admission to the

9

extent it requires information outside Apple’s possession, custody and control, including, for

10

example, information concerning components that Apple has purchased from third parties.

11
REDACTED

12
13

REQUEST FOR ADMISSION NO. 36:

14

Admit that Apple has tested the iPhone 3G in the United States for compliance with
3GPP standards.

15
16

RESPONSE TO REQUEST FOR ADMISSION NO. 36:
Apple objects to this Request on the grounds that the terms “compliance” and “3GPP

17
18

standards” are vague and ambiguous. Apple further objects to this Request on the grounds that it

19

is overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of

20

admissible evidence to the extent that it is not limited in time. Apple also objects to this Request

21

to the extent it seeks information that is subject to a confidentiality or non-disclosure agreement

22
or governed by a protective order preventing its production, or otherwise seeks confidential,
23
24

proprietary or trade secret information of third parties. Apple further objects to this Request for

25

Admission to the extent it requires information outside Apple’s possession, custody and control,

26

including, for example, information concerning components that Apple has purchased from third

27

parties.

28
31

APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
1

REDACTED

2
3
4
REQUEST FOR ADMISSION NO. 37:
5
6
7
8

Admit that Apple has tested the iPhone 3G in the United States for compliance with a
3GPP carrier’s network.
RESPONSE TO REQUEST FOR ADMISSION NO. 37:
Apple objects to this Request on the grounds that the terms “compliance” and “3GPP

9
10

carrier’s network” are vague and ambiguous. Apple further objects to this Request on the

11

grounds that it is overly broad, unduly burdensome, and not reasonably calculated to lead to the

12

discovery of admissible evidence to the extent that it is not limited in time. Apple also objects to

13

this Request to the extent it seeks information that is subject to a confidentiality or non-

14

disclosure agreement or governed by a protective order preventing its production, or otherwise

15
seeks confidential, proprietary or trade secret information of third parties. Apple further objects
16
17

to this Request for Admission to the extent it requires information outside Apple’s possession,

18

custody and control, including, for example, information concerning components that Apple has

19

purchased from third parties.

20

REDACTED

21
22
23
24

REQUEST FOR ADMISSION NO. 38:

25

Admit that a third party has tested the iPhone 3G in the United States for compliance with
3GPP standards.

26
27
28
32

APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
1

RESPONSE TO REQUEST FOR ADMISSION NO. 38:

2

Apple objects to this Request on the grounds that the terms “compliance” and “3GPP

3

standards” are vague and ambiguous. Apple further objects to this Request that the phrase “a

4

third party” is vague, ambiguous and overly broad. Apple further objects to this Request on the

5
6

grounds that it is overly broad, unduly burdensome, and not reasonably calculated to lead to the

7

discovery of admissible evidence to the extent that it is not limited in time. Apple also objects to

8

this Request to the extent it seeks information that is subject to a confidentiality or non-

9

disclosure agreement or governed by a protective order preventing its production, or otherwise

10

seeks confidential, proprietary or trade secret information of third parties. Apple further objects

11
to this Request for Admission to the extent it requires information outside Apple’s possession,
12
13
14
15

custody and control, including, for example, information concerning components that Apple has
purchased from third parties.
REDACTED

16
17
18
19
20

REQUEST FOR ADMISSION NO. 39:

21

Admit that a third party has tested the iPhone 3G in the United States for compliance with
a 3GPP carrier’s network.

22
RESPONSE TO REQUEST FOR ADMISSION NO. 39:
23
24

Apple objects to this Request on the grounds that the terms “compliance” and “3GPP

25

carrier’s network” are vague and ambiguous. Apple further objects to this Request that the

26

phrase “a third party” is vague, ambiguous and overly broad. Apple further objects to this

27

Request on the grounds that it is overly broad, unduly burdensome, and not reasonably calculated

28
33

APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
1

to lead to the discovery of admissible evidence to the extent that it is not limited in time. Apple

2

also objects to this Request to the extent it seeks information that is subject to a confidentiality or

3

non-disclosure agreement or governed by a protective order preventing its production, or

4
otherwise seeks confidential, proprietary or trade secret information of third parties. Apple
5
6

further objects to this Request for Admission to the extent it requires information outside Apple’s

7

possession, custody and control, including, for example, information concerning components that

8

Apple has purchased from third parties.

9

REDACTED

10
11
12
13
14

REQUEST FOR ADMISSION NO. 40:

15

Admit that Apple has tested the iPhone 3GS in the United States for compliance with
3GPP standards.

16
17
18

RESPONSE TO REQUEST FOR ADMISSION NO. 40:
Apple objects to this Request on the grounds that the terms “compliance” and “3GPP

19

standards” are vague and ambiguous. Apple further objects to this Request on the grounds that it

20

is overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of

21

admissible evidence to the extent that it is not limited in time. Apple also objects to this Request

22
to the extent it seeks information that is subject to a confidentiality or non-disclosure agreement
23
24

or governed by a protective order preventing its production, or otherwise seeks confidential,

25

proprietary or trade secret information of third parties. Apple further objects to this Request for

26

Admission to the extent it requires information outside Apple’s possession, custody and control,

27
28
34

APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
1

including, for example, information concerning components that Apple has purchased from third

2

parties.

3

REDACTED

4
5
6
7

REQUEST FOR ADMISSION NO. 41:

8

Admit that Apple has tested the iPhone 3GS in the United States for compliance with a
3GPP carrier’s network.

9
10
11

RESPONSE TO REQUEST FOR ADMISSION NO. 41:
Apple objects to this Request on the grounds that the terms “compliance” and “3GPP

12

carrier’s network” are vague and ambiguous. Apple further objects to this Request on the

13

grounds that it is overly broad, unduly burdensome, and not reasonably calculated to lead to the

14

discovery of admissible evidence to the extent that it is not limited in time. Apple also objects to

15
this Request to the extent it seeks information that is subject to a confidentiality or non16
17

disclosure agreement or governed by a protective order preventing its production, or otherwise

18

seeks confidential, proprietary or trade secret information of third parties. Apple further objects

19

to this Request for Admission to the extent it requires information outside Apple’s possession,

20

custody and control, including, for example, information concerning components that Apple has

21
22

purchased from third parties.
REDACTED

23
24
25
26
27
28
35

APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
1

REQUEST FOR ADMISSION NO. 42:

2

Admit that a third party has tested the iPhone 3GS in the United States for compliance
with 3GPP standards.

3
4

RESPONSE TO REQUEST FOR ADMISSION NO. 42:

5

Apple objects to this Request on the grounds that the terms “compliance” and “3GPP

6

standards” are vague and ambiguous. Apple further objects to this Request that the phrase “a

7

third party” is vague, ambiguous and overly broad. Apple further objects to this Request on the

8

grounds that it is overly broad, unduly burdensome, and not reasonably calculated to lead to the

9
10

discovery of admissible evidence to the extent that it is not limited in time. Apple also objects to

11

this Request to the extent it seeks information that is subject to a confidentiality or non-

12

disclosure agreement or governed by a protective order preventing its production, or otherwise

13

seeks confidential, proprietary or trade secret information of third parties. Apple further objects

14

to this Request for Admission to the extent it requires information outside Apple’s possession,

15
custody and control, including, for example, information concerning components that Apple has
16
17
18

purchased from third parties.
REDACTED

19
20
21
22
23
24

REQUEST FOR ADMISSION NO. 43:
Admit that a third party has tested the iPhone 3GS in the United States for compliance
with a 3GPP carrier’s network.

25
26
27
28
36

APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
1
2
3
4

RESPONSE TO REQUEST FOR ADMISSION NO. 43:
Apple objects to this Request on the grounds that the terms “compliance” and “3GPP
carrier’s network” are vague and ambiguous. Apple further objects to this Request that the
phrase “a third party” is vague, ambiguous and overly broad. Apple further objects to this

5
6

Request on the grounds that it is overly broad, unduly burdensome, and not reasonably calculated

7

to lead to the discovery of admissible evidence to the extent that it is not limited in time. Apple

8

also objects to this Request to the extent it seeks information that is subject to a confidentiality or

9

non-disclosure agreement or governed by a protective order preventing its production, or

10

otherwise seeks confidential, proprietary or trade secret information of third parties. Apple

11
further objects to this Request for Admission to the extent it requires information outside Apple’s
12
13
14
15

possession, custody and control, including, for example, information concerning components that
Apple has purchased from third parties.
REDACTED

16
17
18
19
20

REQUEST FOR ADMISSION NO. 44:

21

Admit that Apple has tested the iPad 3G in the United States for compliance with 3GPP
standards.

22
RESPONSE TO REQUEST FOR ADMISSION NO. 44:
23
24

Apple objects to this Request on the grounds that the terms “compliance” and “3GPP

25

standards” are vague and ambiguous. Apple further objects to this Request on the grounds that it

26

is overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of

27

admissible evidence to the extent that it is not limited in time. Apple also objects to this Request

28
37

APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
1

to the extent it seeks information that is subject to a confidentiality or non-disclosure agreement

2

or governed by a protective order preventing its production, or otherwise seeks confidential,

3

proprietary or trade secret information of third parties. Apple further objects to this Request for

4
Admission to the extent it requires information outside Apple’s possession, custody and control,
5
6

including, for example, information concerning components that Apple has purchased from third

7

parties.

8

REDACTED

9
10

REQUEST FOR ADMISSION NO. 45:

11
12

Admit that Apple has tested the iPad 3G in the United States for compliance with a 3GPP
carrier’s network.

13

RESPONSE TO REQUEST FOR ADMISSION NO. 45:

14

Apple objects to this Request on the grounds that the terms “compliance” and “3GPP

15
carrier’s network” are vague and ambiguous. Apple further objects to this Request on the
16
17

grounds that it is overly broad, unduly burdensome, and not reasonably calculated to lead to the

18

discovery of admissible evidence to the extent that it is not limited in time. Apple also objects to

19

this Request to the extent it seeks information that is subject to a confidentiality or non-

20

disclosure agreement or governed by a protective order preventing its production, or otherwise

21

seeks confidential, proprietary or trade secret information of third parties. Apple further objects

22
to this Request for Admission to the extent it requires information outside Apple’s possession,
23
24

custody and control, including, for example, information concerning components that Apple has

25

purchased from third parties.

26

REDACTED

27
28
38

APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
1

REQUEST FOR ADMISSION NO. 46:

2

Admit that a third party has tested the iPad 3G in the United States for compliance with
3GPP standards.

3
4

RESPONSE TO REQUEST FOR ADMISSION NO. 46:

5

Apple objects to this Request on the grounds that the terms “compliance” and “3GPP

6

standards” are vague and ambiguous. Apple further objects to this Request that the phrase “a

7

third party” is vague, ambiguous and overly broad. Apple further objects to this Request on the

8

grounds that it is overly broad, unduly burdensome, and not reasonably calculated to lead to the

9
10

discovery of admissible evidence to the extent that it is not limited in time. Apple also objects to

11

this Request to the extent it seeks information that is subject to a confidentiality or non-

12

disclosure agreement or governed by a protective order preventing its production, or otherwise

13

seeks confidential, proprietary or trade secret information of third parties. Apple further objects

14

to this Request for Admission to the extent it requires information outside Apple’s possession,

15
custody and control, including, for example, information concerning components that Apple has
16
17
18

purchased from third parties.
REDACTED

19
20
21
22
23
24

REQUEST FOR ADMISSION NO. 47:
Admit that a third party has tested the iPad 3G in the United States for compliance with a
3GPP carrier’s network.

25
26
27
28
39

APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
1
2
3
4

RESPONSE TO REQUEST FOR ADMISSION NO. 47:
Apple objects to this Request on the grounds that the terms “compliance” and “3GPP
carrier’s network” are vague and ambiguous. Apple further objects to this Request that the
phrase “a third party” is vague, ambiguous and overly broad. Apple further objects to this

5
6

Request on the grounds that it is overly broad, unduly burdensome, and not reasonably calculated

7

to lead to the discovery of admissible evidence to the extent that it is not limited in time. Apple

8

also objects to this Request to the extent it seeks information that is subject to a confidentiality or

9

non-disclosure agreement or governed by a protective order preventing its production, or

10

otherwise seeks confidential, proprietary or trade secret information of third parties. Apple

11
further objects to this Request for Admission to the extent it requires information outside Apple’s
12
13
14
15

possession, custody and control, including, for example, information concerning components that
Apple has purchased from third parties.
REDACTED

16
17
18
19
20

REQUEST FOR ADMISSION NO. 48:

21

Admit that Apple has tested the iPhone 4 in the United States for compliance with 3GPP
standards.

22
RESPONSE TO REQUEST FOR ADMISSION NO. 48:
23
24

Apple objects to this Request on the grounds that the terms “compliance” and “3GPP

25

standards” are vague and ambiguous. Apple further objects to this Request on the grounds that it

26

is overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of

27

admissible evidence to the extent that it is not limited in time. Apple also objects to this Request

28
40

APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
1

to the extent it seeks information that is subject to a confidentiality or non-disclosure agreement

2

or governed by a protective order preventing its production, or otherwise seeks confidential,

3

proprietary or trade secret information of third parties. Apple further objects to this Request for

4
Admission to the extent it requires information outside Apple’s possession, custody and control,
5
6

including, for example, information concerning components that Apple has purchased from third

7

parties.

8

REDACTED

9
10

REQUEST FOR ADMISSION NO. 49:

11
12

Admit that Apple has tested the iPhone 4 in the United States for compliance with a
3GPP carrier’s network.

13

RESPONSE TO REQUEST FOR ADMISSION NO. 49:

14

Apple objects to this Request on the grounds that the terms “compliance” and “3GPP

15
carrier’s network” are vague and ambiguous. Apple further objects to this Request on the
16
17

grounds that it is overly broad, unduly burdensome, and not reasonably calculated to lead to the

18

discovery of admissible evidence to the extent that it is not limited in time. Apple also objects to

19

this Request to the extent it seeks information that is subject to a confidentiality or non-

20

disclosure agreement or governed by a protective order preventing its production, or otherwise

21

seeks confidential, proprietary or trade secret information of third parties. Apple further objects

22
to this Request for Admission to the extent it requires information outside Apple’s possession,
23
24

custody and control, including, for example, information concerning components that Apple has

25

purchased from third parties.

26

REDACTED

27
28
41

APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
1

REQUEST FOR ADMISSION NO. 50:

2

Admit that a third party has tested the iPhone 4 in the United States for compliance with
3GPP standards.

3
4

RESPONSE TO REQUEST FOR ADMISSION NO. 50:

5

Apple objects to this Request on the grounds that the terms “compliance” and “3GPP

6

standards” are vague and ambiguous. Apple further objects to this Request that the phrase “a

7

third party” is vague, ambiguous and overly broad. Apple further objects to this Request on the

8

grounds that it is overly broad, unduly burdensome, and not reasonably calculated to lead to the

9
10

discovery of admissible evidence to the extent that it is not limited in time. Apple also objects to

11

this Request to the extent it seeks information that is subject to a confidentiality or non-

12

disclosure agreement or governed by a protective order preventing its production, or otherwise

13

seeks confidential, proprietary or trade secret information of third parties. Apple further objects

14

to this Request for Admission to the extent it requires information outside Apple’s possession,

15
custody and control, including, for example, information concerning components that Apple has
16
17
18

purchased from third parties.
REDACTED

19
20
21
22
23
24

REQUEST FOR ADMISSION NO. 51:
Admit that a third party has tested the iPhone 4 in the United States for compliance with a
3GPP carrier’s network.

25
26
27
28
42

APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
1
2
3
4

RESPONSE TO REQUEST FOR ADMISSION NO. 51:
Apple objects to this Request on the grounds that the terms “compliance” and “3GPP
carrier’s network” are vague and ambiguous. Apple further objects to this Request that the
phrase “a third party” is vague, ambiguous and overly broad. Apple further objects to this

5
6

Request on the grounds that it is overly broad, unduly burdensome, and not reasonably calculated

7

to lead to the discovery of admissible evidence to the extent that it is not limited in time. Apple

8

also objects to this Request to the extent it seeks information that is subject to a confidentiality or

9

non-disclosure agreement or governed by a protective order preventing its production, or

10

otherwise seeks confidential, proprietary or trade secret information of third parties. Apple

11
further objects to this Request for Admission to the extent it requires information outside Apple’s
12
13
14
15

possession, custody and control, including, for example, information concerning components that
Apple has purchased from third parties.
REDACTED

16
17
18
19
20

REQUEST FOR ADMISSION NO. 52:

21

Admit that Apple has tested the iPad 2 in the United States for compliance with 3GPP
standards.

22
RESPONSE TO REQUEST FOR ADMISSION NO. 52:
23
24

Apple objects to this Request on the grounds that the terms “compliance” and “3GPP

25

standards” are vague and ambiguous. Apple further objects to this Request on the grounds that it

26

is overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of

27

admissible evidence to the extent that it is not limited in time. Apple also objects to this Request

28
43

APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
1

to the extent it seeks information that is subject to a confidentiality or non-disclosure agreement

2

or governed by a protective order preventing its production, or otherwise seeks confidential,

3

proprietary or trade secret information of third parties. Apple further objects to this Request for

4
Admission to the extent it requires information outside Apple’s possession, custody and control,
5
6

including, for example, information concerning components that Apple has purchased from third

7

parties.

8
9
10

REDACTED

REQUEST FOR ADMISSION NO. 53:

11

Admit that Apple has tested the iPad 2 in the United States for compliance with a 3GPP
carrier’s network.

12

RESPONSE TO REQUEST FOR ADMISSION NO. 53:

13
14

Apple objects to this Request on the grounds that the terms “compliance” and “3GPP
carrier’s network” are vague and ambiguous. Apple further objects to this Request on the

15
grounds that it is overly broad, unduly burdensome, and not reasonably calculated to lead to the
16
17

discovery of admissible evidence to the extent that it is not limited in time. Apple also objects to

18

this Request to the extent it seeks information that is subject to a confidentiality or non-

19

disclosure agreement or governed by a protective order preventing its production, or otherwise

20

seeks confidential, proprietary or trade secret information of third parties. Apple further objects

21

to this Request for Admission to the extent it requires information outside Apple’s possession,

22
custody and control, including, for example, information concerning components that Apple has
23
24
25

purchased from third parties.
REDACTED

26
27
28
44

APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
1

REQUEST FOR ADMISSION NO. 54:

2

Admit that a third party has tested the iPad 2 in the United States for compliance with
3GPP standards.

3
4

RESPONSE TO REQUEST FOR ADMISSION NO. 54:
Apple objects to this Request on the grounds that the terms “compliance” and “3GPP

5
6

standards” are vague and ambiguous. Apple further objects to this Request on the grounds that it

7

is overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of

8

admissible evidence to the extent that it is not limited in time. Apple also objects to this Request

9
10

to the extent it seeks information that is subject to a confidentiality or non-disclosure agreement

11

or governed by a protective order preventing its production, or otherwise seeks confidential,

12

proprietary or trade secret information of third parties. Apple further objects to this Request for

13

Admission to the extent it requires information outside Apple’s possession, custody and control,

14

including, for example, information concerning components that Apple has purchased from third

15
parties.
16
REDACTED

17
18

REQUEST FOR ADMISSION NO. 55:

19

Admit that a third party has tested the iPad 2 in the United States for compliance with a
3GPP carrier’s network.

20
21
22

RESPONSE TO REQUEST FOR ADMISSION NO. 55:
Apple objects to this Request on the grounds that the terms “compliance” and “3GPP

23

carrier’s network” are vague and ambiguous. Apple further objects to this Request on the

24

grounds that it is overly broad, unduly burdensome, and not reasonably calculated to lead to the

25

discovery of admissible evidence to the extent that it is not limited in time. Apple also objects to

26

this Request to the extent it seeks information that is subject to a confidentiality or non-

27
28
45

APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
1

disclosure agreement or governed by a protective order preventing its production, or otherwise

2

seeks confidential, proprietary or trade secret information of third parties. Apple further objects

3

to this Request for Admission to the extent it requires information outside Apple’s possession,

4
custody and control, including, for example, information concerning components that Apple has
5
6

purchased from third parties.

7

REDACTED

8

Dated: October 26, 2011

/s/ Mark D. Selwyn
Mark D. Selwyn (SBN 244180)
([e-mail])
WILMER CUTLER PICKERING
HALE AND DORR LLP
950 Page Mill Road
Palo Alto, California 94304
Telephone: [phone]
Facsimile: [phone]

9
10
11
12
13

William F. Lee (admitted pro hac vice)
([e-mail])
WILMER CUTLER PICKERING
HALE AND DORR LLP
60 State Street
Boston, Massachusetts 02109
Telephone: [phone]
Facsimile: [phone]

14
15
16
17
18
19

Harold J. McElhinny (SBN 66781)
([e-mail])
Michael A. Jacobs (SBN 111664)
([e-mail])
Richard S.J. Hung (CA SBN 197425)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105
Telephone: ( 415) 268-7000
Facsimile: [phone]

20
21
22
23
24
25
26

Attorneys for Plaintiff and
Counterclaim-Defendant Apple Inc.

27
28
46

APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

SUBJECT TO PROTECTIVE ORDER
CONTAINS CONFIDENTIAL INFORMATION
1
2

CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the above and foregoing

3
document has been served on October 26, 2011 by electronic mail upon the following:
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19

Charles Kramer Verhoeven (Cal. Bar No. 170151)
([e-mail])
Quinn Emanuel Urquhart & Sullivan LLP
50 California Street, 22nd Floor
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
Kevin P.B. Johnson (Cal. Bar No. 177129)
([e-mail])
Victoria F. Maroulis (Cal. Bar No. 202603)
([e-mail])
Quinn Emanuel Urquhart & Sullivan LLP
555 Twin Dolphin Drive 5th Floor
Redwood Shores, California 94065
Telephone: [phone]
Facsimile: [phone]
Edward J. DeFranco (Cal. Bar No. 165596)
([e-mail])
Quinn Emanuel Urquhart & Sullivan LLP
51 Madison Avenue, 22nd Floor
New York, New York 10010
Telephone: [phone]
Facsimile: [phone]

20
21
22
23
24

Michael T. Zeller (Cal. Bar No. 196417)
([e-mail])
Quinn Emanuel Urquhart & Sullivan LLP
865 S. Figueroa St., 10th Floor
Los Angeles, California 90017
Telephone: [phone]
Facsimile: [phone]

25
26

/s/ Mark. D Selwyn
Mark D. Selwyn

27
28
47

APPLE INC.’S RESPONSES TO SAMSUNG’S
FIRST SET OF REQUESTS FOR ADMISSION
Case No. 11-cv-01846 (LHK)

OPPOS
FOR