Apple Inc. v. Samsung Electronics Co. Ltd. et al

Filing 672

*** EXHIBIT 4 FILED IN ERROR WITH CONFIDENTIAL INFORMATION . DOCUMENT LOCKED. DOCUMENT TO BE REFILED LATER.. *** EXHIBITS re #667 Administrative Motion to File Under Seal re Samsung's Motion to Supplement Invalidity Contentions (Briggs Declaration in Support of Samsung's Motion to Supplement Invalidity Contentions) filed bySamsung Electronics Co. Ltd.. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8, #9 Exhibit 9, #10 Exhibit 10, #11 Exhibit 11)(Related document(s) #667 ) (Maroulis, Victoria) (Filed on 1/27/2012) Modified on 1/27/2012 (feriab, COURT STAFF).

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP
Charles K. Verhoeven (Bar No. 170151)
[e-mail]
2
50 California Street, 22nd Floor
3 San Francisco, California 94111
Telephone: [phone]
4 Facsimile: [phone]
5

Kevin P.B. Johnson (Bar No. 177129
[e-mail]
Victoria F. Maroulis (Bar No. 202603)
6
[e-mail]
555 Twin Dolphin Drive, 5th Floor
7
Redwood Shores, California 94065-2139
[phone]
8 Telephone:
Facsimile:
[phone]
9
10

Michael T. Zeller (Bar No. 196417)
[e-mail]
865 S. Figueroa St., 10th Floor
11
Los Angeles, California 90017
12 Telephone: [phone]
Facsimile: [phone]
13
14 Attorneys for SAMSUNG ELECTRONICS CO.,
LTD., SAMSUNG ELECTRONICS AMERICA,
15 INC. and SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC
16
17

UNITED STATES DISTRICT COURT

18

NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

19
20 APPLE INC., a California corporation,

CASE NO. 11-cv-01846-LHK

21

DECLARATION OF TODD BRIGGS IN
SUPPORT OF SAMSUNG'S MOTION TO
SUPPLEMENT INVALIDITY
CONTENTIONS

22

Plaintiff,
vs.

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

28
02198.51855/4572766.1

Case No. 11-cv-01846-LHK
DECLARATION OF TODD BRIGGS IN SUPPORT OF SAMSUNG'S MOTION TO SUPPLEMENT
INVALIDITY CONTENTIONS

1

I, Todd Briggs, declare:

2

1.

I am a partner in the law firm of Quinn Emanuel Urquhart & Sullivan, LLP,

3 counsel for Samsung Electronics Co., Ltd., Samsung Electronics America, Inc., and Samsung
4 Telecommunications America, LLC (collectively “Samsung”). I have personal knowledge of the
5 facts set forth in this declaration and, if called upon as a witness, I could and would testify to such
6 facts under oath.
7

2.

Attached hereto as Exhibit 1 is a true and correct copy of Exhibit V-4 from

8 Samsung’s invalidity contentions for the ’129 Patent, citing U.S. Patent No. 5,565,658.
9

3.

Attached hereto as Exhibit 2 is a true and correct copy of Exhibit P-9 from

10 Samsung’s invalidity contentions for the ’607 Patent, citing A.K. Leeper, “Integration of a Clear
11 Capacitive Touch Screen with a 1/8-VGA FSTN-LCD to Form LCD-Based Touchpad.”
12

4.

Attached hereto as Exhibit 3 is a true and correct copy of Exhibit Q from

13 Samsung’s invalidity contentions for the ’607 Patent, citing U.S. Patent No. 7,030,860.
14

5.

Attached hereto as Exhibit 4 is a true and correct copy of Samsung’s intended

15 supplemental invalidity contentions for the ’891 Patent, Exhibit M-15, showing Mac OS X version
16 10.0.
17

6.

Attached hereto as Exhibit 5 is a true and correct copy of Samsung’s intended

18 supplemental invalidity contentions for the ’002 Patent, Exhibit D-8, showing SuperClock.
19

7.

Attached hereto as Exhibit 6 is a true and correct copy of Samsung’s intended

20 supplemental invalidity contentions for the ’381 Patent, Exhibit G-8, showing Glimpse.
21

8.

Attached hereto as Exhibit 7 is a true and correct copy of Samsung’s intended

22 supplemental invalidity contentions for the ’129 Patent, Exhibit V-10, showing the Cirque
23 GlidePoint.
24

9.

Attached hereto as Exhibit 8 is a true and correct copy of Samsung’s intended

25 supplemental invalidity contentions for the ’607 Patent, Exhibit P-12, showing U.S. Patent No.
26 7,030,860.
27

10.

Attached hereto as Exhibit 9 is a video clip showing the operation of the Mac OS

28 10.0 “brightness window.”
02198.51855/4572766.1

Case No. 11-cv-01846-LHK

1

11.

Attached hereto as Exhibit 10 is a video clip showing the operation of SuperClock.

2

12.

Attached hereto as Exhibit 11 is a video clip showing the operation of Glimpse.

3
4

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

5 Redwood Shores, California on January 26, 2012.
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/s/ Todd Briggs

9

Todd Briggs

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02198.51855/4572766.1

Case No. 11-cv-01846-LHK
-2DECLARATION OF TODD BRIGGS IN SUPPORT OF SAMSUNG'S MOTION TO SUPPLEMENT
INVALIDITY CONTENTIONS

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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 Todd Briggs.
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/s/ Victoria Maroulis
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02198.51855/4572766.1

Case No. 11-cv-01846-LHK
-3DECLARATION OF TODD BRIGGS IN SUPPORT OF SAMSUNG'S MOTION TO SUPPLEMENT
INVALIDITY CONTENTIONS