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)
hmcelhinny@mofo.com
MICHAEL A. JACOBS (CA SBN 111664)
mjacobs@mofo.com
JENNIFER LEE TAYLOR (CA SBN 161368)
jtaylor@mofo.com
ALISON M. TUCHER (CA SBN 171363)
atucher@mofo.com
JASON BARTLETT (CA SBN 197425)
rhung@mofo.com
JASON R. BARTLETT (CA SBN 214530)
jasonbartlett@mofo.com
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: (415) 268-7000
Facsimile: (415) 268-7522
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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)
mark.selwyn@wilmerhale.com
WILMER CUTLER PICKERING
HALE AND DORR LLP
950 Page Mill Road
Palo Alto, California 94304
Telephone: (650) 858-6000
Facsimile: (650) 858-6100
Attorneys for Plaintiff and
Counterclaim-Defendant APPLE INC.
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WILLIAM F. LEE
william.lee@wilmerhale.com
WILMER CUTLER PICKERING
HALE AND DORR LLP
60 State Street
Boston, MA 02109
Telephone: (617) 526-6000
Facsimile: (617) 526-5000
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.
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Attached as Exhibit A is a true and correct copy of correspondence from
Marissa Ducca to Jason Bartlett dated November 8, 2011.
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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.
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Attached as Exhibit E is a true and correct copy of excerpts of the deposition of
Ravin Balakrishnan taken on August 16, 2011.
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Attached as Exhibit F is a true and correct copy of excerpts of a document
subpoena issued to Cirque Corporation on October 26, 2011.
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Attached as Exhibit G is a true and correct copy of excerpts of a deposition
subpoena issued to Cirque Corporation on December 22, 2011.
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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.
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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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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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