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

Filing 691

MOTION to Permit Samsung's Expert Samuel Lucente to Review Materials Designated Under the Protective Order filed by Samsung Electronics America, Inc., Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC. Motion Hearing set for 2/7/2012 10:00 AM in Courtroom 5, 4th Floor, San Jose before Magistrate Judge Paul Singh Grewal. Responses due by 2/3/2012. Replies due by 2/6/2012. (Attachments: #1 Declaration of Albert P. Bedecarre, #2 Exhibit A, #3 Exhibit B, #4 Exhibit C, #5 Exhibit D, #6 Exhibit E, #7 Exhibit F, #8 Exhibit G, #9 Exhibit H, #10 Exhibit I, #11 Exhibit J, #12 Exhibit K, #13 Exhibit L, #14 Exhibit M, #15 Proposed Order)(Maroulis, Victoria) (Filed on 1/30/2012)

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EXHIBIT J 755 PAGE MILL ROAD PALO ALTO CALIFORNIA 94304-1018 TELEPHONE: 650.813.5600 FACSIMILE: 650.494.0792 WWW.MOFO.COM January 24, 2012 MORRISON & FOERSTER LLP NEW YORK, SAN FRANCISCO, LOS ANGELES, PALO ALTO, SACRAMENTO, SAN DIEGO, DENVER, NORTHERN VIRGINIA, WASHINGTON, D.C. TOKYO, LONDON, BRUSSELS, BEIJING, SHANGHAI, HONG KONG Writer’s Direct Contact 650.813.5718 By Email ( Alex Binder Quinn Emanuel 50 California Street, 22nd Floor San Francisco, California 94111 Re: Apple v. Samsung, Case No. 11-cv-1846-LHK (PSG) (N.D. Cal.) Dear Alex: I write in response to Samsung’s disclosure of Robert Anders as a proposed expert and to Rachel Kassabian’s letter of today concerning Samuel Lucente. Regarding Mr. Anders, please confirm that he is not an inventor of, and does not have any interest in, any patents or pending patent applications (U.S. or foreign) related to smartphones or tablet computers. Please also confirm that Mr. Anders does not have any current engagements with any smartphone or tablet computer companies (other than Samsung). Pending Apple’s receipt of and ability to consider this information, Apple objects to the disclosure of its confidential information to Mr. Anders. As for Mr. Lucente, we have concerns regarding Mr. Lucente’s ownership of pending patent applications relating to user interfaces—particularly as Samsung presumably intends to offer Mr. Lucente to opine regarding Apple’s and Samsung’s user interfaces and related designs. We are willing to consider, however, reasonable restrictions on the disclosure to Mr. Lucente of Apple’s Highly Confidential Attorneys' Eyes Only materials (as with Mr. Sherman). Please advise. Sincerely, /s/ Marc Pernick Marc Pernick sf-3098374 January 24, 2012 Page Two cc: Samuel Maselli S. Calvin Walden Peter Kolovos sf-3098374

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