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

Filing 713

OPPOSITION to ( #658 First MOTION for Leave to Supplement Its Infringement Contentions ) filed by Apple Inc.. (Attachments: #1 Hung Declaration, #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)(Hung, Richard) (Filed on 2/3/2012) Modified text on 2/6/2012 (dhm, COURT STAFF).

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Hung, Richard S. J.
From:

Todd Briggs [[e-mail]]

Sent:

Friday, February 03, 2012 10:03 AM

To:

Hung, Richard S. J.; Victoria Maroulis

Cc:

Jacobs, Michael A.; '[e-mail]'; Monach, Andrew E.; Ow, Eric W

Subject: RE: Apple v. Samsung -- Revised New Products Stipulation

Rich,
Where do we stand on this? As I mentioned last night, Samsung is fine with last part of the
stipulation so long as you include the “absent good cause” language. Please let me know if that
will work for Apple. It is now Saturday in Korea, so I will have a very difficult time today
working out this stipulation if we cannot settle on that language.
Thanks, Todd
From: Hung, Richard S. J. [mailto:[e-mail]]
Sent: Thursday, February 02, 2012 10:19 PM
To: Todd Briggs; Victoria Maroulis
Cc: Jacobs, Michael A.; [e-mail]; Monach, Andrew E.; Ow, Eric W
Subject: Apple v. Samsung -- Revised New Products Stipulation

Todd -Here you go. Attached is a draft deleting "substantially" from both parties' sections, as discussed. It
includes our revised proposal re: additional discovery (to replace our prior "good cause" language). I
think that the latter point is the only (but significant) point on which we disagree.
Please let me know your thoughts.
Rich
___________________________
Richard S.J. Hung
Morrison & Foerster LLP
425 Market Street
San Francisco, CA 94105
[phone] (direct)
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2/3/2012