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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QUINN EMANUEL URQUHART & SULLIVAN, LLP
Charles K. Verhoeven (Bar No. 170151)
[e-mail]
2
50 California Street, 22 nd Floor
3 San Francisco, California 94111
Telephone: [phone]
4 Facsimile: [phone]
Kevin P.B. Johnson (Bar No. 177129)
[e-mail]
Victoria F. Maroulis (Bar No. 202603)
6
victoriamaroulisAquinnemanuel.com
7 555 Twin Dolphin Drive, 5th Floor
Redwood Shores, California 94065-2139
[phone]
8 Telephone:
Facsimile:
[phone]
9
5

Michael T. Zeller (Bar No. 196417)
[e-mail]
11 865 S. Figueroa St., 10th Floor
Los Angeles, California 90017
12 Telephone: [phone]
Facsimile: [phone]
13
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14 Attorneys for SAMSUNG ELECTRONICS CO.,
LTD., SAMSUNG ELECTRONICS AMERICA,
15 INC. and SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC
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17

UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

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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.
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CASE NO. 11-cv-01846-LHK
DECLARATION OF ALEX BAXTER IN
SUPPORT OF DEFENDANT SAMSUNG'S
MOTION TO SUPPLEMENT
INVALIDITY CONTENTIONS

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Date: February 16, 2012
Time: 1:30 p.m.
Place: Courtroom 8, 4th Floor
Judge: Hon. Lucy H. Koh
[PROPOSED] PUBLIC REDACTED
VERSION

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02198.51855/4572767.1

Case No. 11-cv-01846-LHK
DECLARATION OF ALEX BAXTER

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I, Alex Baxter, declare:

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1.

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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
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facts set forth in this declaration and, if called upon as a witness, I could and would testify to such

6 facts under oath.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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

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Case No. 11-cv-01846-LHK
DECLARATION OF ALEX BAXTER

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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.
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17.

Attached hereto as Exhibit P is a true and correct excerpt from the deposition of

10 Bas Ording.
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18.

Attached hereto as Exhibit Q is a true and correct excerpt from the deposition of

12 Steven Christensen.
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19.

Attached hereto as Exhibit R is a true and correct excerpt from the deposition of

14 Richard Woolley.
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20.

Attached hereto as Exhibit S is a true and correct excerpt from the deposition of

16 Shawn Day.
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21.

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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.

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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.

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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.
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02198.51855/4572767.1

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Case No. 11-cv-01846-LHK
DECLARATION OF ALEX BAXTER

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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.
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I declare under penalty of perjury that the foregoing is true and correct. Executed in

6 Redwood Shores, California on January 26, 2012.
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8
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/s/ Alex Baxter

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Alex Baxter

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02198.51855/4572767.1

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Case No. 11-cv-01846-LHK
DECLARATION OF ALEX BAXTER

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GENERAL ORDER ATTESTATION

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I, Victoria Maroulis, am the ECF user whose ID and password are being used to file the
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foregoing document. I hereby attest pursuant to General Order 45.X.B. that concurrence in the
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electronic filing of this document has been obtained from Alex Baxter.
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/s/ Victoria Maroulis
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02198.51855/4572767.1

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Case No. 11-cv-01846-LHK
DECLARATION OF ALEX BAXTER