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)

EXHIBIT G

Brett Arnold
From:
Sent:
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Mazza, Mia [[e-mail]]
Tuesday, January 17, 2012 3:37 PM
Rachel Herrick Kassabian
AppleMoFo; Samsung v. Apple; Maselli, Samuel
Apple v. Samsung: Discovery Correspondence - Samuel Lucente
2012-01-16 Ltr Mazza to Kassabian re Lucente.pdf

<<2012-01-16 Ltr Mazza to Kassabian re Lucente.pdf>>
Hi Rachel,
Attached please find correspondence regarding Samsung's expert Samuel Lucente.
Regards,
Mia Mazza
Morrison & Foerster LLP
San Francisco
[phone] office
[phone] mobile
[phone] fax

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January 16, 2012

Writer’s Direct Contact
[phone]
[e-mail]

By Email ([e-mail])
Rachel Herrick Kassabian
Quinn Emanuel
555 Twin Dolphin Drive, Fifth Floor
Redwood Shores, CA 94065
Re:

Apple v. Samsung, Case No. 11-cv-1846-LHK (N.D. Cal.)
CONFIDENTIAL—For Attorneys’ Eyes Only—Subject to Protective Order

Dear Rachel:
It has just come to our attention that Samsung’s proposed expert, Samuel Lucente, may
personally hold ownership interest in two U.S. patents directed to user interface technologies:
U.S. Patent Nos. 7,559,039 and 6,583,800—on which he is also listed as an inventor.
Please provide us with information regarding (1) Mr. Lucente’s ownership interest in these
two patents, including whether he has assigned that interest to any third party in whole or in
part; and (2) whether there are any pending U.S. or foreign patent applications claiming
priority to either of these two U.S. patents, their priority applications, or corresponding PCT
applications.
This information about Mr. Lucente’s patents has only recently surfaced. With apologies,
Apple is unable to lift its objection regarding Mr. Lucente until the requested information is
received from Samsung.
Sincerely,
/s/ Mia Mazza
Mia Mazza
cc:

Samuel Maselli
S. Calvin Walden
Peter Kolovos

sf-3094995