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

Filing 658

First MOTION for Leave to Supplement Its Infringement Contentions filed by Samsung Electronics Co. Ltd.. (Attachments: #1 Declaration in support, #2 Exhibit A, #3 Exhibit B, #4 Exhibit C, #5 Exhibit D, #6 Exhibit E, #7 Exhibit F, #8 Exhibit G, #9 Exhibit H, #10 Exhibit I, #11 Exhibit J, #12 Exhibit K, #13 Exhibit L, #14 Proposed Order Granting Motion for Leave to Amend)(Maroulis, Victoria) (Filed on 1/25/2012) Modified text on 1/26/2012 (dhm, COURT STAFF).

EXHIBIT E

November 30, 2011
VIA ELECTRONIC MAIL
Victoria Maroulis, Esq.
Quinn Emanuel Urquhart & Sullivan, LLP
555 Twin Dolphin Drive, 5th Floor
Redwood Shores, California 94065
Re:

Apple Inc. v. Samsung Electronics Co. Ltd. et al., Case No. 11-cv-01846-LHK (N.D. Cal.)

Dear Victoria:
We write to respond to your November 22, 2011 letter to Richard Hung in which you
agree to join Apple’s November 9 proposed stipulation adding the Galaxy Tab 8.9, Galaxy Tab
7.0, Galaxy Player 4.0, Galaxy Player 5.0, and Galaxy S II Skyrocket as accused products
provided that “Apple will stipulate to Samsung's adding the iPhone 4S to the action.”
So that we understand the full context of your proposal, we ask you to clarify whether
Samsung seeks to modify in any way its disclosures and contentions set forth on September 7,
2011 pursuant to Patent Local Rule 3-1(a), (c)-(h), or, on the other hand, whether Samsung will
commit in this case to the identical infringement theories for the iPhone 4S as those set forth
against the Apple products previously identified by Samsung pursuant to Patent Local Rule 31(b).
Thank you for your prompt attention to this matter. We look forward to your response.
Yours very truly,

Samuel J. Maselli
cc:

Counsel of Record