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

Filing 721

AFFIDAVIT in Opposition re #667 Administrative Motion to File Under Seal re Samsung's Motion to Supplement Invalidity Contentions DECLARATION OF RICHARD S.J. HUNG IN SUPPORT OF APPLES OPPOSITION TO SAMSUNGS MOTION TO SUPPLEMENT INVALIDITY CONTENTIONS filed byApple Inc.. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Exhibit J)(Related document(s) #667 ) (Hung, Richard) (Filed on 2/9/2012)

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HAROLD J. MCELHINNY (CA SBN 66781)
[e-mail]
MICHAEL A. JACOBS (CA SBN 111664)
[e-mail]
JENNIFER LEE TAYLOR (CA SBN 161368)
[e-mail]
ALISON M. TUCHER (CA SBN 171363)
[e-mail]
JASON BARTLETT (CA SBN 197425)
[e-mail]
JASON R. BARTLETT (CA SBN 214530)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: [phone]

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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MARK D. SELWYN (SBN 244180)
[e-mail]
WILMER CUTLER PICKERING
HALE AND DORR LLP
950 Page Mill Road
Palo Alto, California 94304
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff and
Counterclaim-Defendant APPLE INC.

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WILLIAM F. LEE
[e-mail]
WILMER CUTLER PICKERING
HALE AND DORR LLP
60 State Street
Boston, MA 02109
Telephone: [phone]
Facsimile: [phone]

APPLE INC., a California corporation,
Plaintiff,
v.
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,

Case No.

11-cv-01846-LHK

DECLARATION OF
RICHARD S.J. HUNG IN
SUPPORT OF APPLE’S
OPPOSITION TO SAMSUNG’S
MOTION TO SUPPLEMENT
INVALIDITY CONTENTIONS

Defendants.

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DECLARATION OF R. HUNG ISO APPLE’S OPPOSITION TO SAMSUNG’S MOTION TO SUPPLEMENT INVALIDITY
CASE NO. 11-cv-01846-LHK
sf-3104469

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I, Richard S.J. Hung, do hereby declare as follows:

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1.

I am a partner at the law firm of Morrison & Foerster LLP, attorneys of record in

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this action for Apple Inc. (“Apple”). I submit this declaration in support of Apple’s Opposition to

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Samsung’s Motion for Leave to Supplement Its Infringement Contentions. Unless otherwise

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indicated, I have personal knowledge of the matters set forth below. If called as a witness, I could

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and would testify competently as follows.

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2.

On October 7, 2011, Samsung served its 60-page initial Invalidity Contentions

with 79 invalidity claim charts.
3.

Attached as Exhibit A is a true and correct copy of correspondence from

Marissa Ducca to Jason Bartlett dated November 8, 2011.
4.

Attached as Exhibit B is a true and correct copy of correspondence from

Jason Bartlett to Rachel Kassabian dated November 20, 2011.
5.

Attached as Exhibit C is a true and correct copy of excerpts of the deposition of

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Imran Chaudhri taken on October 14, 2011. Page 13, lines 1-2 have been redacted as irrelevant to

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avert the need to file under seal.

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6.

Attached as Exhibit D is a true and correct copy of excerpts of the deposition of

Steven Christensen taken on October 26, 2011.
7.

Attached as Exhibit E is a true and correct copy of excerpts of the deposition of

Ravin Balakrishnan taken on August 16, 2011.
8.

Attached as Exhibit F is a true and correct copy of excerpts of a document

subpoena issued to Cirque Corporation on October 26, 2011.
9.

Attached as Exhibit G is a true and correct copy of excerpts of a deposition

subpoena issued to Cirque Corporation on December 22, 2011.
10.

Attached as Exhibit H is a true and correct copy of excerpts of the deposition of

Richard Woolley of Cirque Corporation taken on January 19, 2012.
11.

Attached as Exhibit I is a true and correct copy of excerpts of a deposition

subpoena issued to Synaptics, Inc. on December 7, 2011.

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DECLARATION OF R. HUNG ISO APPLE’S OPPOSITION TO SAMSUNG’S MOTION TO SUPPLEMENT INVALIDITY
CASE NO. 11-cv-01846-LHK
sf-3104469

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12.

Attached as Exhibit J is a true and correct copy of excerpts of the deposition of

Shawn P. Day of Synaptics, Inc. taken on January 19, 2012.
I declare under the penalty of perjury that the foregoing is true and correct. Executed on
February 9, 2012 at San Francisco, California.

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/s/ Richard S.J. Hung
Richard S.J. Hung

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DECLARATION OF R. HUNG ISO APPLE’S OPPOSITION TO SAMSUNG’S MOTION TO SUPPLEMENT INVALIDITY
CASE NO. 11-cv-01846-LHK
sf-3104469

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