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

Filing 728

*** FILED IN ERROR. REFER TO DOCUMENT #730 . *** Declaration of Marc J. Pernick in Support of #727 Reply to Opposition/Response, filed byApple Inc.. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8, #9 Exhibit 9, #10 Exhibit 10, #11 Exhibit 11, #12 Exhibit 12, #13 Exhibit 13)(Related document(s) #727 ) (Hung, Richard) (Filed on 2/13/2012) Modified on 2/14/2012 (feriab, COURT STAFF).

EXHIBIT 10

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December 27, 2011

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Via E-Mail ([e-mail])
Melissa N. Chan
Quinn Emanuel
555 Twin Dolphin Drive, 5th Floor
Redwood Shores, California 94065
Re:

Apple v. Samsung, Case No. 11-cv-1846-LHK (PSG) (N.D. Cal.)

Dear Melissa:
I write regarding Samsung’s December 13, 2011, disclosure of Samuel Lucente as an expert
in this case. We did not receive responses to Matthew Ahn’s email requests on December 19
and 20 to discuss Mr. Lucente’s disclosure, and so there are still questions that must be
answered before Apple has sufficient information to evaluate whether or not Mr. Lucente has
a conflict that should bar him from viewing Apple’s confidential information. Until
Samsung is willing to discuss Mr. Lucente’s disclosure, Apple objects to the disclosure of its
confidential information to Mr. Lucente.
To expedite the completion of Apple’s review process, please let us know as soon as possible
whether Mr. Lucente has ever participated in, or consulted on, developing or designing a
mobile phone. In addition, please provide us with a list of clients of Lucente Design.
Sincerely,
/s/ Mia Mazza
Mia Mazza
cc:

Samuel Maselli
S. Calvin Walden
Peter Kolovos

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