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

Filing 707

Administrative Motion to File Under Seal Samsung's Unopposed Motion for Issuance of a Request for Judicial Assistance and related exhibits filed by Samsung Electronics America, Inc., Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC. (Attachments: #1 Declaration, #2 Proposed Order, #3 Public Redacted Motion, #4 Declaration, #5 Letter of Request, #6 Proposed Order)(Maroulis, Victoria) (Filed on 2/2/2012)

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

Kevin P.B. Johnson (Bar No. 177129
[e-mail]
Victoria F. Maroulis (Bar No. 202603)

[e-mail]
555 Twin Dolphin Drive, 5th Floor

Redwood Shores, California 94065-2139
[phone]
 Telephone:
Facsimile:
[phone]



Michael T. Zeller (Bar No. 196417)
[e-mail]
865 S. Figueroa St., 10th Floor

Los Angeles, California 90017
 Telephone: [phone]
Facsimile: [phone]

 Attorneys for SAMSUNG ELECTRONICS CO.,
LTD., SAMSUNG ELECTRONICS AMERICA,
 INC. and SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC



UNITED STATES DISTRICT COURT



NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION


 APPLE INC., a California corporation,

CASE NO. 11-cv-01846-LHK



DECLARATION OF SAM STAKE IN
SUPPORT OF SAMSUNG’S UNOPPOSED
MOTION FOR ISSUANCE OF A
REQUEST FOR JUDICIAL ASSISTANCE



Plaintiff,
vs.

 SAMSUNG ELECTRONICS CO., LTD., a
Korean business entity; SAMSUNG
 ELECTRONICS AMERICA, INC., a New
York corporation; SAMSUNG
 TELECOMMUNICATIONS AMERICA,
LLC, a Delaware limited liability company,

Defendant.


Date: March 13, 2012
Time: 10:00 am
Place: Courtroom 5, 4th Floor
Judge: Hon. Paul S. Grewal


Case No. 11-cv-01846-LHK
DECLARATION OF SAM STAKE IN SUPPORT OF SAMSUNG’S UNOPPOSED MOTION FOR ISSUANCE OF
A REQUEST FOR JUDICIAL ASSISTANCE

1

I, Sam Stake, declare:



1.

I am an associate in the law firm of Quinn Emanuel Urquhart & Sullivan, LLP,

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

2.

Attached hereto as Exhibit 1 is a true and correct copy of excerpts from the

 deposition of Joshua Strickon on October 20, 2011.


3.

Attached hereto as Exhibit 2 is a true and correct copy of excerpts from the

 deposition of Brian Huppi on October 18, 2011.


4.

Attached hereto as Exhibit 3 is a true and correct copy of a document entitled

 "Apple Q79 Vision" produced by Apple in this matter.


5.

Attached hereto as Exhibit 4 is a true and correct copy of an email from David

 Bungo on November 20, 2003.


6.

Attached hereto as Exhibit 5 is a true and correct copy of excerpts from the

 deposition of Christopher Stringer on August 3, 2011.


7.

Attached hereto as Exhibit 6 is a true and correct copy of excerpts from the

 deposition of Eugene Whang on October 27, 2011.



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

 Francisco, California on February 3, 2012.



/s/ Sam Stake



Sam Stake





Case No. 11-cv-01846-LHK
DECLARATION OF SAM STAKE IN SUPPORT OF SAMSUNG’S UNOPPOSED MOTION FOR ISSUANCE OF
A REQUEST FOR JUDICIAL ASSISTANCE

1

General Order 45 Attestation

2

I, Victoria F. Maroulis, am the ECF user whose ID and password are being used to e-file

3 this Declaration. In compliance with General Order 45(X)(B), I hereby attest that Scott Hall has
4 concurred in this filing.
5

/s/ Victoria Maroulis

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Case No. 11-cv-01846-LHK
-2DECLARATION OF SAM STAKE IN SUPPORT OF SAMSUNG’S UNOPPOSED MOTION FOR ISSUANCE OF
A REQUEST FOR JUDICIAL ASSISTANCE

EXHIBITS 1-6
FILED UNDER SEAL