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 E

quinn emanuel

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November 22, 2011

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Richard Hung
Morrison & Foerster LLP
425 Market St.
San Francisco, CA 94105-2482
Re:

Apple v. Samsung Electronics, et al., No. 5:11-cv-01846-LHK (N.D. Cal.)

Dear Rich:
I write regarding Apple’s November 9 proposed stipulation adding several Samsung products to
the litigation, namely the Galaxy Tab 8.9, Galaxy Tab 7.0, Galaxy Player 4.0, Galaxy Player 5.0,
and Galaxy S II Skyrocket. Samsung has considered Apple’s proposal and will join the
stipulation so long as Apple will stipulate to Samsung’s adding the iPhone 4S to the action.
Please let us know if Apple will accept this compromise.
On a separate note, please let us know as soon as practicable whether Apple will stipulate to
Samsung’s serving supplemental invalidity contentions under Patent Local Rule 3-6. On
November 10, 2011, Jason Bartlett was sent a letter from Marissa Ducca describing several
supplemental invalidity contentions regarding prior art discovered through the recent depositions
of Apple’s inventors. In particular, Samsung would like to supplement its contentions for the
’891, ’002, ’828, ’163, and ’129 patents. The letter from Ms. Ducca provides the details of these
contentions as well as ample reasons why Apple would not be unduly prejudiced by them.
Sincerely,
/s/ Victoria F. Maroulis
Victoria F. Maroulis
quinn emanuel urquhart & sullivan, llp
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