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 B

quinn emanuel

trial lawyers | washington, dc

1299 Pennsylvania Avenue NW, Suite 825, Washington, District of Columbia 20004-2400 | TEL: [phone] FAX: [phone]

November 1, 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:
Although I will address many documents identified throughout the inventor depositions
that Apple failed to produce in a later letter, I am writing regarding several specific document
production issues from the ’002 and ’891 patent depositions.
The ’891 Patent
During the depositions of the ’891 inventors, we discovered that Mac OS 10.0, released
before the priority date of the ’891 patent, is prior art. Please produce (1) the source code for
Mac OS 10.0 and (2) a computer with a functional copy of Mac OS 10.0 installed on it. The
Mac OS 10.0 source code and computer with software is responsive to at least the following
Requests for Production, served on Apple on August 3, 2011:
96.

All prior art to the APPLE IP identified at any time to Apple as potentially or
allegedly invalidating prior art to the APPLE IP.

98.

All documents and things relating to any information, including patents,
publications, prior knowledge, public uses, sales, or offers for sale, that may
constitute, contain, disclose, refer to, relate to, or embody any prior art to any

quinn emanuel urquhart & sullivan, llp
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alleged invention claimed by the Apple IP.
Please produce this source code and computer immediately.
The ’002 Patent
First, during his deposition, Mr. Christensen testified regarding a heavily redacted
document that was marked as Exhibit 979 (Bates Nos. APLNDC-X0000002308-2312). This
document is not privileged, and should be produced in its entirety. Please produce an unredacted
version of the document marked as Exhibit 979 immediately. Counsel requested this document
in its unredacted form at that deposition. See Christensen Dep. at 63:9-11.
Second, during his deposition, Mr. Christensen testified regarding Super Clock, and we
requested the source code for this application. See Christensen Dep. at 184:1-2. The Super
Clock source code is at least responsive to Requests for Production 96 and 98 reproduced above.
Please produce the Super Clock source code immediately.
I look forward to your response.
Best regards,
/s/ Marissa R. Ducca
Marissa R. Ducca

cc:

Todd Briggs
Alan Whitehurst
Vicki Maroulis
Rachel Herrick Kassabian

02198.51855/4423629.1

02198.51855/4423629.1

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