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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January 24, 2012

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By Email ([e-mail])
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