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)

EXHIBIT K

quinn emanuel

trial lawyers | silicon valley

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WRITER'S INTERNET ADDRESS
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January 24, 2012
VIA E-MAIL
Richard Hung
Morrison & Foerster
425 Market Street
San Francisco, CA 94105-2482
Re:

Apple v. Samsung Elecs. Co., et al., No. 5:11-cv-01846-LHK (N.D. Cal.)
Additional Supplemental Invalidity Contentions

Dear Rich:
Further to my January 5, 2012 letter, I write to ask whether Apple will stipulate to the service of
supplemental invalidity contentions to include one additional reference – U.S. Patent No.
7,030,860 to Synaptics Incorporated (“the ’860 patent”).
Samsung has good cause to supplement its invalidity contentions to include this additional prior
art reference. For example, the ’860 patent was recently produced by Synaptics on
December 23, 2011 as part of its its third-party production to Samsung. In addition, Shawn P.
Day, the CTO of Synaptics, was recently deposed and provided additional testimony relating to
the ’860 patent on January 19, 2012. I also note that the ’860 patent was already included in
Samsung’s initial invalidity contentions in Exhibit Q as potentially relevant to the validity of
Apple’s ’607 patent.
Please let us know by Wednesday, January 25, whether Apple will agree to this supplemental
contention. Otherwise, Samsung will assume that Apple opposes any stipulation and proceed to
file a motion with the court.
quinn emanuel urquhart & sullivan, llp
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Very truly yours,

Todd M. Briggs

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