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 L

quinn emanuel

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October 24, 2011
VIA ELECTRONIC MAIL
Mia Mazza
Morrison & Foerster
425 Market Street
San Francisco, California 94105-2482

Re:

Apple v. Samsung Elecs. Co. et al., Case No. 11-cv-1846 LHK (N.D. Cal.)

Dear Mia:
Bas Ording’s deposition is scheduled for tomorrow, yet Apple has not produced any documents
reflecting Mr. Ording's work relating to the '891 patent. This is despite Apple's commitment to
providing relevant documents five days before an inventor's deposition, and Samsung's October
18 letter informing Apple of the severe deficiencies in its inventor productions.
Similarly, Steven Christensen’s deposition is scheduled for Wednesday. However, Apple has
not produced any documents reflecting Mr. Christensen's work on the '002 patent. Apple has
also not produced the exhibits attached to Mr. Christensen's deposition of September 27, 2011 in
Apple v. Motorola. We had previously requested production of these documents during the
plenary meet and confer session on Wednesday, October 19.
Please immediately produce documents relevant to Mr. Ording's and Mr. Christensen's
depositions by 5 PM, today, October 24, or confirm in writing that Apple has no such
documents. If Apple believes it has already produced such documents, please immediately
indicate their Bates ranges today. Given Apple's deficient production, Samsung reserves the
right to recall Mr. Ording and Mr. Christensen to the extent that any later produced documents
quinn emanuel urquhart & sullivan, llp
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are relevant to their testimony.
Best regards,
/s/ Marissa R. Ducca
Marissa R. Ducca
cc:

Todd Briggs
Alan Whitehurst
Sara Jenkins

02198.51855/4413264.1

02198.51855/4413264.1

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