Apple Inc. v. Samsung Electronics Co. Ltd. et al
Filing
807
DECLARATION of Mia Mazza in Support of #805 Opposition to Administrative Motion for Temporary Relief from the Lead Counsel Meet and Confer Requirement or Alternatively for an Extension of the Deadline to File Motions to Compel, filed by Apple 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, #11 Exhibit K, #12 Exhibit L, #13 Exhibit M, #14 Exhibit N)(Related document(s) #805 ) (Jacobs, Michael) (Filed on 3/13/2012) Modified text on 3/14/2012 (dhm, COURT STAFF).
Exhibit N
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March 12, 2012
Writer’s Direct Contact
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JasonBartlett@mofo.com
By Email (dianehutnyan@quinnemanuel.com)
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 to respond to your February 13, February 25, February 28, and March 1 letters.
Discovery in this case has been ongoing for ten months. The Court has adjudicated fourteen
motions and cross motions to compel. Apple has produced millions of pages of documents
in this and related actions from more than 150 different custodians. Apple has fully
disclosed the nature and scope of its productions in countless meet and confer sessions
(including multiple lengthy lead counsel sessions), in three sets of detailed transparency
disclosures, and in a six hour 30(b)(6) deposition. Samsung has taken over eighty
depositions (including depositions of over sixty Apple witnesses, many of whom were
deposed more than once) in the Northern District of California action alone. The discovery
period ended Thursday.
Recent correspondence makes plain that Samsung’s primary mission is to derail the orderly
conclusion of discovery. Samsung is now issuing shotgun-blast discovery demands. Its
letters appear to have been drafted without regard to Apple’s actual document production,
Samsung’s document requests, or ten month history of discovery disputes and negotiations
that have taken place.
Apple responds below to each of the issues Samsung raises in its letters below. Many of
these documents could—and should—have been found by Samsung in Apple’s production.
Samsung has even used many documents falling within the categories that it claims Apple
has not produced in recent depositions of Apple witnesses.
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Diane Hutnyan
March 12, 2012
Samsung’s Letter of February 13
Samsung’s Demand
Apple’s Response
Confirm that Apple has complied
with prior court orders by
producing fourteen categories of
documents and things.
Apple responded in detail in a letter of February 23.
All documents concerning the
iPhone design having sharp edges
or injuring a user.
Apple has already produced documents relating to the
iPhone designs at issue as set forth in Apple’s
transparency disclosures.
Documents relating to iPhone sharp edges and user
injuries are not responsive to any Samsung discovery
request (your letter identifies none).
In an effort to avoid unnecessary disputes, Apple has
searched documents of its Industrial Design and
Product Design custodians documents containing the
terms iphone and sharp as well as sharp within 20 of
injur* or wound.
All antenna test reports and issues
relating to antenna malfunctions,
including all documents in the
possession of the “antenna team.”
Apple has already produced documents relating to the
iPhone designs at issue as set forth in Apple’s
transparency disclosures.
Documents relating to antenna function are not
responsive to any Samsung discovery request (your
letter identifies none).
In an effort to avoid unnecessary disputes, Apple has
searched documents of its Industrial Design and
Product Design custodians’ documents containing the
term “antenna” in the file name or path where the text
contains the term “antenna” in a ten word proximity to
the words “performance” or “test”. Apple excluded
from this search documents falling outside the range of
years in which any released iPhone was under
development. Apple excluded from this search
documents containing search terms associated with
unreleased Apple products.
All documents relating to the
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Apple has already produced documents relating to the
Diane Hutnyan
March 12, 2012
Samsung’s Demand
Apple’s Response
“design of the bezel of the
iPhone,” including “bezel test
reports” and “bezel strength
studies.”
iPhone designs at issue as set forth in Apple’s
transparency disclosures. “Bezel,” without further
substantive limitation, was a search term in Apple’s
Industrial Design production.
Documents relating to bezel test reports and “bezel
strength studies” are not responsive to any Samsung
discovery request (your letter identifies none).
In an effort to avoid unnecessary disputes, Apple has
searched documents of its Industrial Design and
Product Design custodians’ documents containing the
term “bezel” and “strength” in a ten word proximity.
Apple excluded from this search documents falling
outside the range of years in which any released iPhone
was under development. Apple excluded from this
search documents containing search terms associated
with unreleased Apple products.
All documents and things relating
to competitive teardowns.
Apple has already conducted an extensive search for
documents relating to Samsung in the possession of
nearly ninety Apple custodians. Apple’s production of
Samsung-related documents is discussed in more detail
in Apple’s letter of February 23. Across the three
pending cases to which cross-use applies, Apple’s
production of documents containing the word
“Samsung” exceeds two million pages.
Apple’s extensive Samsung-related production includes
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Diane Hutnyan
March 12, 2012
Samsung’s Demand
Apple’s Response
All documents relating to the
design of the iPad’s audio jack.
Your reference to documents relating to iPad’s audio
jack appears to arise
in which Mr. Ive discussed a 2 millimeter
adjustment. Apple disagrees that such documents are
responsive, but has searched Industrial Design and
Product Design collections for documents containing
references to iPad and jack near 15 of margin.
All documents sourced to or
received by each design inventor,
including Steve Jobs, or in the
Human Interface server relating to
the external and UI design of the
iPad, iPhone, or iPod touch.
Apple has produced extensive documents to and from
all of its design inventors and from its Human Interface
server relating to the asserted design patents, as
disclosed in its transparency disclosures. Apple is
reviewing its collections for “exceptions” such as
Photoshop, Illustrator, and other native data, and will
produce if any responsive material is located.
Deposition transcripts for each
design inventor that have been
taken in the ITC.
Samsung already has the deposition transcripts for each
of Apple’s inventors of the design patents-in-suit taken
in the ITC. Samsung has even filed excerpts from those
transcripts as exhibits in this action. Apple is
considering Samsung’s proposal to amend the
Protective Order.
All documentation relating to
source code for the accused
devices, purportedly responsive to
RFP No. 16 (all documents
regarding software for the APPLE
ACCUSED PRODUCTS that
transmits, images, messages, and
addresses by email or multimedia
messages).
Apple has conducted a reasonable search and is
unaware of any documents relating to the source code
for the Apple Accused Products that transmits images,
messages, and addresses by email or multimedia
messages. Apple has made the relevant source code
available.
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Diane Hutnyan
March 12, 2012
Samsung’s Letter of February 25
1. Documents Allegedly Indentified by Freddy Anzures
Freddy Anzures was deposed in mid-October. Samsung waited four months until the eve of
the close of discovery to raise these alleged deficiencies. Apple cannot and will not conduct
new searches and production simply to appease Samsung’s overbroad, last-minute requests
for burdensome productions of irrelevant documents. Doing so would be completely
incompatible with the orderly conclusion of the discovery period.
In addition, Samsung’s latest requests are not responsive to its discovery requests. Your
letter cites two requests. Request 92 requests for documents relating to “performance,
advantages, disadvantages, problems, features . . . benefits, or improvements of any alleged
invention of the APPLE IP.” Request 193 requests documents relating to the “functionality”
of elements in the asserted design patents, trade dress and trademarks.
With respect to Request 92, Apple has searched for documents relating to the asserted Apple
intellectual property, as disclosed in Apple’s transparency disclosures. Most of Apple’s
searches on this topic were disclosed in October and November. Samsung requested that
Apple conduct follow-up searches, and in most cases Apple complied. The parties’ dispute
regarding design-related search terms was the subject of motion practice and orders. It is far
too late for Samsung to conjure entirely new categories of demands for documents relating to
the asserted intellectual property.
With respect Request 193, Samsung’s demand for all documents relating to such diverse
topics as “using empty space to distinguish the dock,” “early Apple touchscreen device
studies,” and the “Dashboard application” on Apple’s Mac OS X computer operating system
(which runs on Apple computers, not phones and tablets) simply proves the overbreadth of
the request as construed by Samsung. Rule 34 requires that document requests identify
“each item” or “category of items” with “reasonable particularity.”
Samsung also continues to ignore the law of the case. Simply asserting that an element of a
product has a “function” within the common meaning of that word does not make that
element “functional” within the meaning of trade dress and design patent law. The Court
already rejected Samsung’s misguided view of the functionality doctrine in its order on
Apple’s motion for preliminary injunction [Dkt. No. 452], citing a Federal Circuit opinion
that held that the relevant inquiry with respect to a design patent is not “the utility of each of
the various elements,” but rather whether the design as a whole is dictated by function. The
Court ruled that design elements such as rounded corners, speaker shapes, screen size and
placement, the presence of buttons, and the concept of minimalism itself were not
“functional.”
Functionality, the Court held, could dictate that the “smartphone is small enough to be
handheld,” that the screen be “relatively large” and “encompass a large portion of the front
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Diane Hutnyan
March 12, 2012
face,” and that the “speaker” be placed in the “upper portion of the front face” to allow the
slot to line up with the user’s ear. Id. These may be examples of form “dictated” by
function. In responding to Samsung’s Request 193, Apple is guided by, and will continue to
be guided by, the Court’s order.
Responding specifically to Samsung’s requests relating to documents identified by Mr.
Anzures:
Samsung’s Demand
Apple’s Response
Documents relating to the
Dashboard application in Mac OS
X.
Documents relating to the “Dashboard” application in
Apple’s Mac OS X computer operating system are not
responsive to any Samsung request, nor are they
relevant. The “Dashboard” is a program that allows
users to install and run small applications (called
“widgets”) from a special screen on Apple desktop and
laptop computers. This suit does not implicate Apple
computers or computer software, let alone “widgets.”
Samsung’s request is also extremely untimely,
particularly considering that the parties already litigated
the issue of production of documents relating to Apple
OS X “Tiger” icons.
Early Apple touchscreen device
studies.
Documents relating to “touchscreen device studies” are
not responsive to requests 92 or 193.
Apple has already searched for and produced
documents relating to
an early
project involving multitouch touchscreen technology.
Documents debating a list vs. icon
approach to the
homescreen/springboard
Documents relating to the list vs. icon approach to the
homescreen/springboard are not responsive to requests
92 or 193.
Apple has already produced responsive documents
relating to the relevant projects which led to the
claimed Graphical User Interface design.
Documents discussing viable icon
sizes and how icon size needs to
match finger size
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Documents discussing how icon size needs to match
finger size are not responsive to requests 92 or 193.
Moreover, contrary to your assertion, Apple does not
see any testimony by Mr. Anzures that this category of
Diane Hutnyan
March 12, 2012
Samsung’s Demand
Apple’s Response
documents exists.
Apple has already produced responsive documents
relating to the relevant projects which led to the
claimed Graphical User Interface design.
Documents discussing reasons for
grid layout for icons
Documents discussing reasons for a grid layout for
icons are not responsive to requests 92 or 193.
Moreover, contrary to your assertion, Apple does not
see any testimony by Mr. Anzures that this category of
documents exist.
Apple has already produced responsive documents
relating to the relevant projects which led to the
claimed Graphical User Interface design.
Documents discussing familiarity
of particular Apple iOS icons
The implicit suggestion in your request that “familiar”
equals “functional” is incorrect. Moreover, as with
several categories above, contrary to your assertion,
Apple sees no testimony by Mr. Anzures that this
category of documents exists.
Documents discussing dock
function, in particular discussions
of using empty space to
distinguish dock and how dock
icons could be selected by thumb
when device is held in one hand
Again, Apple sees no testimony by Mr. Anzures that
this category of documents exists. In fact, in response
to questioning regarding empty space, Mr. Anzures
replied, “We didn’t have a conversation about that
particular aspect of the design.”
The only discussion of the thumb arises from the
questioner—not Mr. Anzures—who asks whether the
dock is in a “logical position” because it can be reached
by the thumb.
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Diane Hutnyan
March 12, 2012
2. Documents Allegedly Identified by Douglas Satzger
You request two categories of documents allegedly identified in Mr. Satzger’s deposition in
early November. You offer no explanation as to why you waited three and a half months to
request these documents.
Apple will not produce “standard material reports” or materials specifications. Materials are
not at issue in this litigation, and this category of documents is not relevant or responsive to
any request. Apple will produce an example of a color control specification not withstanding
its irrelevance and non-responsiveness. Please review it and reconsider your request.
Samsung also requests documents relating to the “black mask” covering the LCD circuitry
outside the area of the display and documents relating to the “function” of the mask. Such
documents are not responsive to Samsung’s request. A mask is not “functional,” as is made
clear by the Court’s Order and explained above, and Apple is aware of no testimony that the
mask serves any non-cosmetic purpose.
3. Documents Allegedly Identified by Richard Dinh
You request “surface files” relating to the iPhone and iPad generated by the Industrial Design
team CAD group and sent to the Product Design team. Over several months of discovery,
Apple already produced all industrial design CAD, all sketches, all industrial design models,
and even MCOs relating to the external design of the products at issue, including early
iPhone designs. As the parties have previously discussed at great length, that is already more
than sufficient to satisfy any reasonable demand for documents pertaining to the designs at
issue. Nevertheless, in an attempt to avoid unnecessary disputes, Apple produced on
February 28 surface files exchanged between the Product Design and Industrial Design group
for Samsung’s inspection. (See 2-28-2012 Bartlett Letter to Hutnyan producing files for
inspection).
You next request eleven separate categories of documents which, like your request for
documents allegedly identified by Freddy Anzures, serve only to demonstrate the
overbreadth of Samsung’s requests. A single request for documents relating to
“functionality” is not a “reasonabl[y] particular[]” request within the meaning of Rule 34 for
a hodgepodge of documents as diverse as:
strategies for fitting components
into products
antenna tests
storage tests
build test reports
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repeated drop tests
heat soak tests
Diane Hutnyan
March 12, 2012
drop tests
acoustic tests
temperature tests
post-drop functionality tests
dust tests
Such extensive testing documentation is completely irrelevant. Does Samsung seriously
contend that the Apple iPhone design is dictated by the need to resist heat and dust, send and
receive radio signals, emit sound, and withstand drops? And if that is Samsung’s contention,
why did Samsung fail to request such documents seven months ago? Apple cannot
undertake the burden to respond to these broad requests at this, the close of the discovery
period.
Samsung next requests documents relating to eleven alleged “problems with the iPhone 4
and 4S” including problems with “proximity sensors,” “ambient light sensors,” the “gasket
on the home button,” to name a few. There is no Apple IP at issue in this case relating to
proximity sensors, ambient light sensors, or the home button gasket. Apple cannot
comprehend what relevance such documents could have or what requests they would respond
to.
Samsung’s list concludes with fifteen additional categories of documents alleged to have
been identified by Mr. Dinh (though Samsung fails to cite any relevant transcript excerpts).
Responding to each:
Samsung’s Demand
Apple’s Response
Surface files relating to iPhone
and iPad
As discussed above, Apple produced such files for
Samsung’s inspection on February 28. (See 2/28/2012
Bartlett Letter to Hutnyan.)
Cosmetic models, button models,
and ID models.
As discussed in extensively in correspondence, lead
trial counsel meet and confer sessions, briefing, and
court orders, Apple produced for inspection all of its ID
models relating to iPhone, iPad, and iPod touch.
Apple’s production included 1,230 models, 263 partial
models, and 537 bags of miscellaneous parts and small
samples. Apple’s ID models have been kept available
for Samsung’s inspection for seven weeks at great
expense to Apple, and are still available in escrow to
this day.
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Diane Hutnyan
March 12, 2012
Samsung’s Demand
Documents related to the “zerogap”
Apple’s Response
It is astonishing that you are asking for documents
relating to the “zero-gap” based on Mr. Dinh’s
testimony when Mr. Dinh testified explicitly that he
could think of no functional reason for the zero-gap.
He testified, “I wouldn’t want a zero-gap,” “I can’t
think of an engineering or manufacturing advantage,”
and that the only reason he could think of would be “to
be beautiful or to be good looking.”
As with many of your requests above, despite your
assertion that Mr. Dinh testified to the existence of this
“categor[y] of information,” Mr. Dinh testified to no
such thing.
Additional drop testing results
Apple’s response to Samsung’s requests for various
“testing reports” is set out above.
Costing analyses relating to
components and labor
As you know, Apple has produced cost-related
documents including costed Bills of Material. The
scope of Apple’s production of cost-related information
has been previously litigated and resolved.
Documents discussing plan to
have single horizontal slot
These documents are not responsive to Samsung’s
requests, and Mr. Dinh did not testify to their existence.
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Diane Hutnyan
March 12, 2012
Samsung’s Demand
Apple’s Response
aperture for sensors and receivers
Documents discussing mesh and
acoustic transparency
Mesh is not an element of Apple’s asserted design
patents or trade dress. Moreover, the assertion that
these documents relate to functionality is misguided.
Samsung cannot credibly assert that the iPhone design
is dictated by acoustic transparency concerns.
High level charts for executives
discussing trade-offs of different
design options
Apple performed searches relating to the design of the
products at issue as disclosed in its transparency
disclosures. As part of that production, Apple searched
for and produced executive reviews.
Results of acoustic simulations
This request is exceedingly vague and overbroad. Once
again, Samsung cannot credibly assert that the iPhone
trade dress is dictated by acoustics.
Studies relating to curved glass
This request is not responsive to Samsung’s requests,
and Mr. Dinh did not testify that such documents exist.
Samsung’s Letter of February 28
Like the letters discussed above, Samsung’s letter regarding the depositions of Jonathan Ive
and Scott Forstall relies on an overbroad and legally incorrect reading of “functionality” in
an attempt to justify a massive fishing expedition late in the case.
Samsung’s Demand
Apple’s Response
Documents pertaining to stress
tests, drop testing, bezel strength,
still images and video footage
from the Reliability Group
Apple’s response to Samsung’s requests for various
“testing reports” is set out above.
Surface studies
e
”
,
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Diane Hutnyan
March 12, 2012
Apple has produced ID CAD and all ID models,
including partial models. Samsung’s demand for
additional documents relating to “surface studies” is
baseless and unduly burdensome.
“Description of revision”
drawings, Pro/E, Unigraphics
drawings of the iPhone and iPad,
“Design of experiments” work,
“final assembly, test and pack.”
The documents requested in your letter are vague,
overbroad, irrelevant, and nonresponsive to Samsung’s
requests. As explained in more detail above, Apple has
made an extensive production including all ID CAD, all
ID models, MCOs bearing directly on the external
designs of the products at issue, surface files, and is
reviewing “exceptions” such as Photoshop, Illustrator,
and other native data, and will produce if any
responsive material is located. Apple’s production of
“drawings” related to the products at issue is more than
complete.
Specs for Apple devices provided
to Apple by wireless carriers
Samsung cannot seriously contend that the design of
Apple’s phones is dictated by specs provided by
wireless carriers. The multitude of alternative designs
Apple has cited throughout this proceeding, operating
on the same wireless carriers as Apple, disproves that
baseless theory. This request has no relevance to
Samsung’s “functionality” defense and is
nonresponsive to Samsung’s requests.
Samsung’s Letter of March 1
Samsung’s letter of March 1 seems to be a hastily prepared list of documents mentioned in
the February 23 and 24 deposition of Greg Joswiak without regard to or understanding of
Apple’s document production. Samsung identifies thirteen categories of documents that
Samsung says Apple does not “appear to have produced.” Apple cannot understand how
Samsung could have made such a claim in good faith if it had actually reviewed Apple’s
production.
Samsung’s Demand
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Apple’s Response
Diane Hutnyan
March 12, 2012
Samsung’s Demand
Documents related to Apple’s
market share in various sectors,
including quarterly reports and
documents prepared by third
parties regarding Apple’s market
share.
Apple’s Response
Apple has made an extensive production of internal and
third-party market, consumer, and market share studies.
Apple essentially produced its entire server of thirdparty materials in this area as well as voluminous
documents created internally. This totaled thousands of
documents, including APLNDC-X0000313770314368; APLNDC-X0000051955-69414; APLNDCY0000023661-Y0000029204; and APLNDCY0000029205-29227 and included documents from
nearly fifty different independent market research firms.
It is frankly unbelievable that in the face of this
production, you are asserting Apple has failed to
produce documents prepared by third parties regarding
Apple’s market share, or that Samsung needs more.
Marketing presentations, product
presentations and brain dumps
Apple has searched for documents relating to marketing
of the products at issue as disclosed in Apple’s
transparency disclosures. Apple has produced many
“brain dump” and “brain dump”-related documents,
which Samsung can identify by searching Apple’s
production. For examples, see APLNDC0001921587
and APLNDC0001837450. The category “marketing
presentations” is too vague and would cover far too
many produced documents to list here, but documents
that would fit this definition can be found throughout
Apple’s production from product marketing custodians,
which Samsung can search itself.
Product briefs
Apple has produced all product briefs found after a
reasonable search in accordance with Apple’s
transparency disclosures. See, e.g., APL-ITC7960000174523 and 400744 as well as
APLNDC0002007938, 2008237, 1922005, 1925874,
1897457, and 1960538.
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Diane Hutnyan
March 12, 2012
Samsung’s Demand
Apple’s Response
.
Documents relating to store
displays and point of sale presence
Apple has produced many such documents, sourced to
its MarCom Server, containing logical keywords such
as “display,” “channel,” and “sign.” For example, see
APLNDC0002630301, 2630303, 2630261, 26302532630256, 2630237-2630238, 2630233, 2630224,
2630221, 2630220, 2630205-2630206, 26301972630198, 2630194, 2630183, 2630165, 2630109,
2630081, 2630075, 2630060-2630062, and 26300302630031. These documents are easily located in
Apple’s production.
Communications between Apple
and third-party channel partners
regarding market share and
competitor performance
Apple’s production of market share and market
research studies, including information on the
performance of competitors, is beyond extensive. As
detailed above, it includes thousands of studies across
Apple’s internal research department and nearly fifty
outside vendors. Samsung cannot possibly need more
market share information. Apple’s communications
with channel partners regarding market share and
competitor performance are irrelevant.
Observations of Apple employees
reviewing competitor products
Apple employees’ informal evaluations of newly
released competitive products, which Mr. Joswiak
described as playing with, using, and looking at
products (2-23-12 Joswiak Deposition 136:8-10) are
irrelevant to this matter and not responsive to any
Samsung requests.
Moreover, your claim that Mr. Joswiak testified to such
a “categor[y] of documents” is directly contradicted by
the transcript itself.
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Diane Hutnyan
March 12, 2012
Samsung’s Demand
Apple’s Response
Trademark and icon guidelines
provided to third-party application
developers
Apple’s iOS Human Interface Guidelines, including
guidelines for using Apple’s icons and for creating
custom icons, as well as Apple’s Trademark Guidelines
are publicly available and many versions have been
produced. As just one example, see
APLNDC0001359149, a document directed at thirdparty application developers with sections entitled
“Using System-Provided Buttons and Icons” and
“Creating Custom Icons and Images.” Samsung can
easily find this document, and many other such
documents, in Apple’s production.
Documents, tools, and screenshots
of the “portal” used by third-party
application developers
Apple’s third-party application developer “portal” is
publicly available at developer.apple.com.
Weekly sales reports of product
sales and spreadsheets containing
sales and quarterly forecasts
We are addressing the production of financial data,
which you have addressed in more detail separately, via
separate letter. In short, Apple has produced extensive
financial documents. You have provided no basis for a
need for weekly numbers, nor for the claim that
Samsung needs forecasts.
This letter responds to each of Samsung’s 88 separate document production–related
complaints raised in the last three weeks. We trust that your alleged concerns about Apple’s
production are now resolved.
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Diane Hutnyan
March 12, 2012
Sincerely,
/s/ Jason R. Bartlett
Jason R. Bartlett
cc:
Peter Kolovos
S. Calvin Walden
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