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 H

quinn emanuel

trial lawyers | silicon valley

555 Twin Dolphin Drive, 5th Floor, Redwood Shores, California 94065-2139 | TEL: [phone] FAX: [phone]

December 22, 2011
VIA E-MAIL
Samuel J. Maselli
950 Page Mill Road
Palo Alto, CA 94304
Re:

Apple, Inc. v. Samsung Elecs. Co. et al., Case No. 11-cv-1846 LHK

Dear Sam:
I write in response to your December 14, 2011 letter, regarding proposed reciprocal
stipulations to amend the parties’ infringement contentions and our conversations this week
regarding the same.
As you are aware, Samsung is seeking to amend its infringement contentions to identify
the iPhone 4S as an accused product. Samsung plans to proceed under its previously disclosed
theories for 9 of the 12 Samsung patents with respect to the additional Apple iPhone 4S product.
For the remaining 3 patents, Samsung’s theories will be essentially the same with the minor
modifications described below.
In regards to the ‘460 and ‘893 patents, the currently accused Apple products display
left/right arrow keys whereas the iPhone 4S does not. Samsung’s supplemental infringement
contentions would account for this change to the iPhone 4S. In regards to the ’871 patent,
Samsung’s supplemental infringement contentions would account for the new way in which the
iPhone 4S divides the display window into first and second display windows.

quinn emanuel urquhart & sullivan, llp
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I look forward to hearing from you regarding proposed reciprocal stipulations to amend
the parties’ infringement contentions. Please let us know by December 28 whether Apple is
willing to enter into this stipulation.

Very truly yours,

/s/
Todd Briggs

02198.51855/4520889.2

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