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 L quinn emanuel trial lawyers | silicon valley 555 Twin Dolphin Drive, 5th Floor, Redwood Shores, California 94065-2139 | TEL: (650) 801-5000 FAX: (650) 801-5100 WRITER'S INTERNET ADDRESS January 28, 2012 VIA ELECTRONIC MAIL Mia Mazza Morrison & Foerster LLP 425 Market Street San Francisco, CA 94105-2482 Re: Apple, Inc. v. Samsung Elecs. Co., et al., No. 11-cv-1846-LHK (N.D. Cal.) Dear Mia: I write in response to Marc Pernick’s letter of January 27, 2012 regarding Samsung’s disclosed experts Samuel Lucente and Robert Anders. Thank you for informing us that Apple has withdrawn any objection to Dr. Anders under the protective order. Unfortunately, Apple’s basis for continuing its objection to Mr. Lucente remains wholly unexplained because the only information provided thus far is that Mr. Lucente has a pending patent application for a graphical user interface he invented in the 1990s. That is not a cognizable basis to object to Mr. Lucente’s ability to review confidential Apple materials in connection with his expert work in this case. Moreover, while you have implied that some restriction of his access is necessary, you have not provided Samsung with any understanding as to how you would propose to do so. Because Apple is maintaining its meritless objection to Mr. Lucente, and because lead counsel meet and confer was completed on this issue during the parties’ January 5 and 16, 2012 lead counsel meet and confers, Samsung will be proceeding with motion practice on Monday. Please quinn emanuel urquhart & sullivan, llp LOS ANGELES | 865 South Figueroa Street, 10th Floor, Los Angeles, California 90017-2543 | TEL (213) 443-3000 FAX (213) 443-3100 51 Madison Avenue, 22nd Floor, New York, New York 10010-1601 | TEL (212) 849-7000 FAX (212) 849-7100 SAN FRANCISCO | 50 California Street, 22nd Floor, San Francisco, California 94111-4788 | TEL (415) 875-6600 FAX (415) 875-6700 CHICAGO | 500 W. Madison Street, Suite 2450, Chicago, Illinois 60661-2510 | TEL (312) 705-7400 FAX (312) 705-7401 WASHINGTON, DC | 1299 Pennsylvania Avenue NW, Suite 825, Washington, District of Columbia 20004-2400 | TEL (202) 538-8000 FAX (202) 538-8100 LONDON | 16 Old Bailey, London EC4M 7EG, United Kingdom | TEL +44(0) 20 7653 2000 FAX +44(0) 20 7653 2100 TOKYO | NBF Hibiya Building, 25F, 1-1-7, Uchisaiwai-cho, Chiyoda-ku, Tokyo 100-0011, Japan | TEL +81 3 5510 1711 FAX +81 3 5510 1712 MANNHEIM | Erzbergerstraße 5, 68165 Mannheim, Germany | TEL +49(0) 621 43298 6000 FAX +49(0) 621 43298 6100 MOSCOW | Voentorg Building, 3rd Floor, 10 Vozdvizhenka Street, Moscow 125009, Russia | TEL +7 495 797 3666 FAX +7 495 797 3667 NEW YORK | HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY Mia Mazza January 28, 2012 notify us by noon on Monday, January 30 if we have misunderstood Apple’s position in either of these respects. Otherwise, please note that we would like this issue to be heard on shortened time and hereby request that Apple stipulate to the following schedule: Samsung will file its motion on Monday, January 30 Apple will file its opposition on Thursday, February 2 Hearing before Magistrate Judge Grewal will be set for Tuesday, February 7 at 1:30 p.m. Please inform us of your willingness to stipulate to this schedule by noon on Monday, January 30, 2012. Very truly yours, /s/ Rachel Herrick Kassabian Rachel Herrick Kassabian RHK 02198.51855/4574883.1 2

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