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

Filing 782

Administrative Motion to File Under Seal re Samsung's Motion Compel Production Materials From Related Proceedings and to Enforce 12/22/11 Court Order filed by Samsung Electronics America, Inc., Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC. (Attachments: #1 Proposed Order Granting Samsung's Motion to Seal, #2 Exhibit 1 to Motion to Seal: Redacted Motion to Compel re Related Proceedings, #3 Exhibit 2 to Motion to Seal: Redacted Diane Hutnyan Declaration ISO Motion to Compel re Related Proceedings, #4 Exhibit A to Hutnyan Declaration, #5 Exhibit B to Hutnyan Declaration, #6 Exhibit C to Hutnyan Declaration, #7 Exhibit D to Hutnyan Declaration, #8 Exhibit E to Hutnyan Declaration, #9 Exhibit F to Hutnyan Declaration, #10 Exhibit G to Hutnyan Declaration, #11 Exhibit H to Hutnyan Declaration, #12 Exhibit I to Hutnyan Declaration, #13 Exhibit J to Hutnyan Declaration, #14 Exhibit K to Hutnyan Declaration, #15 Exhibit L to Hutnyan Declaration, #16 Exhibit M to Hutnyan Declaration, #17 Exhibit N to Hutnyan Declaration, #18 Proposed Order Granting Samsung's Motion to Compel Production Materials From Related Proceedings and to Enforce 12/22/11 Court Order)(Maroulis, Victoria) (Filed on 3/7/2012)

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EXHIBIT J 425 MARKET STREET SAN FRANCISCO CALIFORNIA 94105-2482 TELEPHONE: 415.268.7000 FACSIMILE: 415.268.7522 MO RRI SO N & F O E RST E R L LP N E W YO RK , SAN F RAN C I SCO , L O S A N G E L E S, P A L O A L T O , SAC RAME N T O , SAN D I E G O , D E N VE R, N O RT H E RN VI RG I N I A, WASH I N G T O N , D .C. T O K YO , L O N D O N , BR U SSE L S, BE I JI N G , SH AN G H AI , H O N G K O N G WWW.MOFO.COM February 10, 2012 By Email ( Writer’s Direct Contact 415.268.6615 Diane Hutnyan Quinn Emanuel 865 South Figueroa St., 10th Floor Los Angeles, CA 90017-2543 Re: Apple v. Samsung, Case No. 11-cv-1846 LHK (N.D. Cal.) Dear Diane: I write in response to your February 3, 2012, and February 8, 2012, letters requesting documents from proceedings involving the patents-in-suit. It appears from your letters that Samsung has been aware of all related proceedings involving the patents-in-suit or related patents. Samsung has listed all such proceedings in both its Request for Production No. 75 and again in its February 8 letter. Apple is not aware of any other proceedings that involve the patents-in-suit or related patents. As for your request that Apple produce “materials” from “any other cases having a technological nexus to the issues in this case,” Apple declines to do so. Pursuant to the Court’s January 15, 2012 Order, Apple will only produce the deposition transcripts of Apple witnesses bearing a “technological nexus” to the patents-in-suit. Your document requests do not seek all materials from cases with a “technological nexus” with this case. Your sudden expansion of your request to include all such documents appears to be for the purpose of harassment. Furthermore, Samsung appears to have done nothing for several months despite Judge Grewal ordering Samsung to take on the tasks of obtaining third party approval. As stated in the February 6, 2012, meet-and-confer with lead counsel, Samsung needs to obtain this consent before Apple can produce unredacted confidential documents. Once Samsung obtains this consent, Apple will promptly produce such documents. Sincerely, /s/ Jason R. Bartlett Jason R. Bartlett cc: Peter Kolovos, S. Calvin Walden sf-3105887

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