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 20004-2544 | TEL: [phone]

CHARLES A. BASINGER
[phone]
[e-mail]

October 26, 2011
Cirque Corporation
2463 South 3850 West
Salt Lake City, UT 84120-2335
Re:

Apple Inc. v. Samsung Electronics Co., Ltd., No. 11-CV-01846-LHK (N.D. Cal.)

Dear Sir or Madam:
Enclosed please find a Subpoena to Produce Documents, Information, or Objects, issued by the
United States District Court for the District of Utah. These documents are being sought by
Samsung Electronics, Co., Ltd. in connection with litigation against Apple Inc., Apple Inc. v.
Samsung Electronics Co., Ltd., No. 11-CV-01846-LHK (N.D. Cal.).
Although Samsung has not sought to subpoena deposition testimony from any employees of your
company at this time, Samsung expressly reserves the right to do so once counsel for Samsung
has had the opportunity to review all documents and materials responsive to the enclosed
subpoena.
Please do not hesitate to contact me with questions or concerns; we look forward to working with
you to make this process as expedient and convenient for you as possible.

Very truly yours,

Charles A. Basinger
quinn emanuel urquhart & sullivan, llp
LOS ANGELES | 865 South Figueroa Street, 10th Floor, Los Angeles, California 90017-2543 | TEL [phone] FAX [phone]
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TOKYO | NBF Hibiya Bldg., 25F, 1-1-7, Uchisaiwai-cho, Chiyoda-ku, Tokyo 100-0011, Japan | TEL [phone] FAX [phone]

AO 88B (Rev. 06/09) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action

UNITED STATES DISTRICT COURT
for the
District of Utah
Apple, Inc.
Plaintiff

v.
Samsung Electronics Co. Ltd.
Defendant

)
)
)
)
)
)

Civil Action No.

5:11-cv-01846

(If the action is pending in another district, state where:
_____
_____ District of ____
______

)

SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS
OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION
To: Cirque Corporation
Production: YOU ARE COMMANDED to produce at the time, date, and place set forth below the following
documents, electronically stored information, or objects, and permit their inspection, copying, testing, or sampling of the
material:
See Attachment A

Place:

Quinn Emanuel Urquhart & Sullivan, LLP
1299 Pennsylvania Ave. NW, Suite 825
Washington D.C., 20004

Date and Time:
11/7/2011 12:00 PM

Inspection of Premises: YOU ARE COMMANDED to permit entry onto the designated premises, land, or
other property possessed or controlled by you at the time, date, and location set forth below, so that the requesting party
may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it.

Place:

Date and Time:

The provisions of Fed. R. Civ. P. 45(c), relating to your protection as a person subject to a subpoena, and Rule 45
(d) and (e), relating to your duty to respond to this subpoena and the potential consequences of not doing so, are attached.
Date:
CLERK OF COURT
OR
Signature of Clerk or Deputy Clerk

Attorney’s signature

The name, address, e-mail, and telephone number of the attorney representing (name of party)
Samsung Electronics Co. Ltd.
, who issues or requests this subpoena, are:
Charles A. Basinger, Quinn Emanuel Urquhart & Sullivan, LLP, 1299 Pennsylvania Ave. NW, Suite 825, Washington
DC 20004; E-mail: [e-mail]; Telephone: [phone]

AO 88B (Rev. 06/09) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action (Page 2)

Civil Action No.

5:11-cv-01846

PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)
This subpoena for (name of individual and title, if any)
was received by me on (date)

.

I served the subpoena by delivering a copy to the named person as follows:

on (date)

; or

I returned the subpoena unexecuted because:
.
Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also
tendered to the witness fees for one day’s attendance, and the mileage allowed by law, in the amount of
$
My fees are $

.
for travel and $

for services, for a total of $

I declare under penalty of perjury that this information is true.

Date:
Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc: