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 G

December 14, 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 in response to your December 5 letter regarding proposed reciprocal
stipulations to amend the parties’ infringement contentions.
Your letter, which was sent in response to my November 30, 2011 letter, does not answer
the questions I asked. While you say that “Samsung believes that the contentions under Local
P.R. 3-1 need to be amended for each added product,” you do not explain in what respect(s)
Samsung seeks to amend its infringement contentions. We understand that Samsung wants to
amend its contentions to identify the iPhone 4S as an accused product. My question was whether
Samsung seeks to amend any other aspect of its contentions.
Accordingly, I ask again that you please let us know as soon as possible 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.
Finally, in response to your question of how Apple intends to proceed, as noted in the
proposed stipulation that we circulated on November 9, Apple plans to proceed under our
previously disclosed theories with respect to the additional Samsung products.
Yours very truly,
/s/ Samuel J. Maselli
Samuel J. Maselli
cc:

Counsel of Record