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)

quinn emanuel trial lawyers | washington, dc
1299 Pennsylvania Avenue NW, Suite 825, Washington, District of Columbia 20004-2400 | TEL: [phone] FAX: [phone]

November 8, 2011
VIA ELECTRONIC MAIL
Jason Bartlett
Morrison and Foerster
425 Market Street
San Francisco, California 94105-2482
Re:

Apple v. Samsung Elecs. Co. et al., Case No. 11-cv-1846 LHK (N.D. Cal.)

Dear Jason:
I write to follow up on several items which we have recently discussed.
First, on our meet and confer Wednesday, Nov. 2, you indicated that Apple would be
producing the source code for Mac OS 10.0, a working computer loaded with Mac OS 10.0, and
the source code for SuperClock. Please make these available no later than November 11, and let
us know when we can expect them.
Second, Apple indicated on the same meet and confer that it would be producing
documents previously produced in the 794 action in ND Cal by the end of last week. This has
not yet been done. Please produce these documents by November 11.
Third, in your letter dated October 31, 2011, you indicated that Apple would be
supplementing several interrogatories. Please supplement these interrogatories no later than
November 11. In addition, please confirm that you do not intend to supplement any additional
interrogatories, other than those in these supplements, at this time.

quinn emanuel urquhart & sullivan, llp
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Fourth, on November 2, I sent an email to Ms. Mazza regarding redactions on the
document with Bates numbers APLNDC-X4557. She indicated that she was looking into this
matter. Please respond to this email by Friday, November 11.
Fifth, on November 1, Mike Zeller sent Apple a letter regarding certain issues including,
among other things, sketchbooks and Brain Box documents. Please respond to this letter no later
than tomorrow and be prepared to discuss on the meet and confer Wednesday.
Please be prepared to discuss these, and all other pending Apple discovery deficiencies
on the Wednesday meet and confer.
Best regards,

/s/ Marissa R. Ducca
Marissa R. Ducca
MRD

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