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

Filing 799

Administrative Motion to File Under Seal filed by Apple Inc.(a California corporation). (Attachments: #1 Proposed Order, #2 [Redacted Public Version] Apple's Combined Reply, #3 Proposed Order, #4 [Redacted Public Version] Declaration of Mia Mazza in Support of Apple's Combined Reply, #5 Exhibit 1 to [Redacted Public Version] of Declaration of Mia Mazza, #6 Exhibit 2 to [Redacted Public Version] of Declaration of Mia Mazza, #7 Exhibit 3 to [Redacted Public Version] of Declaration of Mia Mazza, #8 Exhibit 4 to [Redacted Public Version] of Declaration of Mia Mazza, #9 Exhibit 33 to [Redacted Public Version] of Declaration of Mia Mazza)(Jacobs, Michael) (Filed on 3/12/2012)

Exhibit 33

755 PAGE MILL ROAD
PALO ALTO
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FACSIMILE: 650.494.0792
WWW.MOFO.COM

February 27, 2012

MORRISON & FOERSTER LLP
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LOS ANGELES, PALO ALTO,
SACRAMENTO, SAN DIEGO,
DENVER, NORTHERN VIRGINIA,
WASHINGTON, D.C.
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Writer’s Direct Contact
650.813.5718
[e-mail]

Via E-Mail ([e-mail])
Rachel Herrick Kassabian
Quinn Emanuel
555 Twin Dolphin Drive, Fifth Floor
Redwood Shores, CA 94065
Re:

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

Dear Rachel:
We write to ensure that Heon-Seok Lee is prepared to testify about his designated Topics 710 and 25-34 from Apple’s 6th Rule 30(b)(6) Deposition Notice.
To be clear, Apple is not by this letter restricting itself in terms of the questions it will ask or
subjects it will cover in Mr. Lee’s deposition. Apple’s intent here is to put Samsung on clear
notice of the sort of information Apple will seek from Mr. Lee so that Samsung can make
sure that Mr. Lee is prepared for his deposition. As particular examples that are not meant to
be exhaustive, here are some of the areas Apple intends to address with Mr. Lee:
•

Identification of the touchscreen controller chip and firmware used for each device
accused of infringing Apple’s patents-in-suit.

•

Identification and explanation of the role and interaction of Samsung’s source code
with the touchscreen controller module.

•

Identification of where Samsung manufactures and tests the full functioning
capability of each device accused of infringing and as to the subject matter of Apple’s
patents-in-suit.

I also again point out that Samsung withdrew Mr. Lee as its corporate designee on
Topics 11-12 from Apple's 6th Rule 30(b)(6) Deposition Notice. Apple repeats its request
that Samsung designate a witness on these topics. Please get back to us immediately on this.

pa-1514508

Rachel Herrick Kassabian
February 27, 2012
Page Two

Sincerely,
/s/ Marc J. Pernick
Marc J. Pernick
cc:

Peter Kolovos
S. Calvin Walden

pa-1514508