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

Filing 671

EXHIBITS re 667 Administrative Motion to File Under Seal re Samsung's Motion to Supplement Invalidity Contentions (Baxter Declaration in Support of Samsung's Motion to Supplement Invalidity Contentions) filed bySamsung Electronics Co. Ltd.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P, # 17 Exhibit Q, # 18 Exhibit R, # 19 Exhibit S, # 20 Exhibit T, # 21 Exhibit U, # 22 Exhibit V, # 23 Exhibit W, # 24 Exhibit X)(Related document(s) 667 ) (Maroulis, Victoria) (Filed on 1/27/2012)

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1 QUINN EMANUEL URQUHART & SULLIVAN, LLP Charles K. Verhoeven (Bar No. 170151) charlesverhoeven@quinnemanuel.com 2 50 California Street, 22 nd Floor 3 San Francisco, California 94111 Telephone: (415) 875-6600 4 Facsimile: (415) 875-6700 Kevin P.B. Johnson (Bar No. 177129) kevinjohnson@quinnemanuel.com Victoria F. Maroulis (Bar No. 202603) 6 victoriamaroulisAquinnemanuel.com 7 555 Twin Dolphin Drive, 5th Floor Redwood Shores, California 94065-2139 (650) 801-5000 8 Telephone: Facsimile: (650) 801-5100 9 5 Michael T. Zeller (Bar No. 196417) michaelzeller@quinnemanuel.com 11 865 S. Figueroa St., 10th Floor Los Angeles, California 90017 12 Telephone: (213) 443-3000 Facsimile: (213) 443-3100 13 10 14 Attorneys for SAMSUNG ELECTRONICS CO., LTD., SAMSUNG ELECTRONICS AMERICA, 15 INC. and SAMSUNG TELECOMMUNICATIONS AMERICA, LLC 16 17 UNITED STATES DISTRICT COURT 18 NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION 19 20 APPLE INC., a California corporation, Plaintiff, 21 22 VS. SAMSUNG ELECTRONICS CO., LTD., a Korean business entity; SAMSUNG 24 ELECTRONICS AMERICA, INC., a New York corporation; SAMSUNG 25 TELECOMMUNICATIONS AMERICA, LLC, a Delaware limited liability company, 26 Defendant. 27 CASE NO. 11-cv-01846-LHK DECLARATION OF ALEX BAXTER IN SUPPORT OF DEFENDANT SAMSUNG'S MOTION TO SUPPLEMENT INVALIDITY CONTENTIONS 23 Date: February 16, 2012 Time: 1:30 p.m. Place: Courtroom 8, 4th Floor Judge: Hon. Lucy H. Koh [PROPOSED] PUBLIC REDACTED VERSION 28 02198.51855/4572767.1 Case No. 11-cv-01846-LHK DECLARATION OF ALEX BAXTER 1 I, Alex Baxter, declare: 2 1. 3 I am an associate in the law firm of Quinn Emanuel Urquhart & Sullivan, LLP, counsel for Samsung Electronics Co., Ltd., Samsung Electronics America, Inc., and Samsung 4 Telecommunications America, LLC (collectively "Samsung"). I have personal knowledge of the 5 facts set forth in this declaration and, if called upon as a witness, I could and would testify to such 6 facts under oath. 7 2. Attached hereto as Exhibit A is a true and correct copy of a letter from M. Ducca 8 to J. Bartlett, dated 10-18-2011. 9 3. Attached hereto as Exhibit B is a true and correct copy of a letter from M. Ducca 10 to M. Mazza, dated 11-01-2011. 11 4. Attached hereto as Exhibit C is a true and correct copy of a letter from M. Ducca 12 to J. Bartlett, dated 11-10-2011. 13 5. Attached hereto as Exhibit D is a true and correct copy of an email from R. Hung. 14 to M. Ducca, sent on 11-11-2011. 15 6. Attached hereto as Exhibit E is a true and correct copy of a letter from V. Maroulis 16 to J. Bartlett, dated 11-22-2011. 17 7. Attached hereto as Exhibit F is a true and correct copy of a letter from M. Mazza 18 to R. Kassabian, dated 12-15-2011. 19 8. Attached hereto as Exhibit G is a true and correct copy of a letter from J. Bartlett 20 to M. Ducca, dated 12-22-2011. 21 9. Attached hereto as Exhibit H is a true and correct copy of a letter from T. Briggs to 22 R. Hung, dated 1-5-2012. 23 10. Attached hereto as Exhibit I is a true and correct copy of a letter from M. Mazza to 24 T. Briggs, dated 1-8-2012. 25 11. Attached hereto as Exhibit J is a true and correct copy of a letter from J. Bartlett to 26 D. Hutnyan, dated 1-12-2012. 27 12. Attached hereto as Exhibit K is a true and correct copy of a letter from T. Briggs to 28 R. Hung, dated 1-24-2012. 02198.51855/4572767.1 -1- Case No. 11-cv-01846-LHK DECLARATION OF ALEX BAXTER 1 13. Attached hereto as Exhibit L is a true and correct copy of a letter from M. Ducca 2 to M. Mazza, dated 10-24-2011. 3 14. Attached hereto as Exhibit M is a true and correct copy of an email sent from M. 4 Mazza to M. Ducca, dated 10-24-11. 5 15. Attached hereto as Exhibit N is a true and correct copy of a letter from R. Hung to 6 T. Briggs, dated 1-26-2011. 7 16. Attached hereto as Exhibit 0 is a true and correct excerpt from the deposition of 8 Imran Chaudhri. 9 17. Attached hereto as Exhibit P is a true and correct excerpt from the deposition of 10 Bas Ording. 11 18. Attached hereto as Exhibit Q is a true and correct excerpt from the deposition of 12 Steven Christensen. 13 19. Attached hereto as Exhibit R is a true and correct excerpt from the deposition of 14 Richard Woolley. 15 20. Attached hereto as Exhibit S is a true and correct excerpt from the deposition of 16 Shawn Day. 17 21. 18 Attached hereto as Exhibit T is a true correct copy of the produced by Cirque Corporation as CIRQUE0024988-25094, and marked as 19 Exhibit 5 to the Deposition of Richard Woolley. 20 22. 21 Attached hereto as Exhibit U is a true correct copy of the produced by Cirque Corporation as CIRQUE0051482- 22 51503, and marked as Exhibit 6 to the Deposition of Richard Woolley. 23 23. 24 Attached hereto as Exhibit V is a true correct copy of the produced by Cirque Corporation as CIRQUE0051639- 25 51657, and marked as Exhibit 7 to the Deposition of Richard Woolley. 26 24. Attached hereto as Exhibit W is a true and correct copy of Apple's Objections and 27 Responses to Samsung's First Set of Interrogatories, served by Apple on September 12, 2011. 28 02198.51855/4572767.1 -2- Case No. 11-cv-01846-LHK DECLARATION OF ALEX BAXTER 1 25. Attached hereto as Exhibit X is a true and correct copy of "Apple's Stipulation as 2 to Mac OS 10.0," signed by both parties on January 26, 2011. 3 4 5 I declare under penalty of perjury that the foregoing is true and correct. Executed in 6 Redwood Shores, California on January 26, 2012. 7 8 9 /s/ Alex Baxter 10 Alex Baxter 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 02198.51855/4572767.1 -3- Case No. 11-cv-01846-LHK DECLARATION OF ALEX BAXTER 1 GENERAL ORDER ATTESTATION 2 I, Victoria Maroulis, am the ECF user whose ID and password are being used to file the 3 foregoing document. I hereby attest pursuant to General Order 45.X.B. that concurrence in the 4 electronic filing of this document has been obtained from Alex Baxter. 5 6 /s/ Victoria Maroulis 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 02198.51855/4572767.1 -4- Case No. 11-cv-01846-LHK DECLARATION OF ALEX BAXTER

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