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

Filing 819

Administrative Motion to File Under Seal filed by Samsung Electronics America, Inc., Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC. (Attachments: #1 Declaration of Kang ISO Motion to Seal DECLARATION UNDER SEAL, #2 Exhibit 1 to Kang: Redacted Samsung's Reply ISO Motion for Protective Order, #3 Exhibit 2 to Kang: Declaration of Kang ISO Samsung's Reply ISO Motion for Protective Order, #4 Declaration of Kassabian ISO Samsung's Reply ISO Motion for Protective Order, #5 Exhibit A to Kassabian, #6 Exhibit B to Kassabian, #7 Exhibit C to Kassabian, #8 Exhibit D to Kassabian, #9 Exhibit E to Kassabian, #10 Exhibit F to Kassabian, #11 Exhibit G to Kassabian, #12 Exhibit H to Kassabian, #13 Exhibit I to Kassabian, #14 Exhibit J to Kassabian, #15 Exhibit K to Kassabian, #16 Exhibit L to Kassabian, #17 Exhibit M to Kassabian, #18 Exhibit N to Kassabian, #19 Exhibit O to Kassabian, #20 Exhibit P to Kassabian, #21 Exhibit Q to Kassabian, #22 Exhibit R to Kassabian, #23 Exhibit S to Kassabian, #24 Exhibit T to Kassabian, #25 Exhibit U to Kassabian, #26 Proposed Order Granting Motio to Seal, #27 Proposed Order Granting's Samsung's Motion for Protective Order Precluding the Depositions of Six High Ranking Executives)(Maroulis, Victoria) (Filed on 3/20/2012) Modified on 3/21/2012 Sealing Declaration of Kang (dhm, COURT STAFF).

EXHIBIT 2

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP
Charles K. Verhoeven (Bar No. 170151)
[e-mail]

50 California Street, 22nd Floor
 San Francisco, California 94111
Telephone: [phone]
 Facsimile: [phone]


Kevin P.B. Johnson (Bar No. 177129
[e-mail]
Victoria F. Maroulis (Bar No. 202603)

[e-mail]
555 Twin Dolphin Drive, 5th Floor

Redwood Shores, California 94065-2139
[phone]
 Telephone:
Facsimile:
[phone]



Michael T. Zeller (Bar No. 196417)
[e-mail]
865 S. Figueroa St., 10th Floor

Los Angeles, California 90017
 Telephone: [phone]
Facsimile: [phone]

 Attorneys for SAMSUNG ELECTRONICS CO.,
LTD., SAMSUNG ELECTRONICS AMERICA,
 INC. and SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC



UNITED STATES DISTRICT COURT



NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION


 APPLE INC., a California corporation,

CASE NO. 11-cv-01846-LHK



DECLARATION OF HANKIL KANG IN
SUPPORT OF SAMSUNG’S REPLY IN
SUPPORT OF ITS MOTION FOR A
PROTECTIVE ORDER PRECLUDING
THE DEPOSITIONS OF SIX HIGHRANKING SAMSUNG EXECUTIVES



Plaintiff,
vs.

 SAMSUNG ELECTRONICS CO., LTD., a
Korean business entity; SAMSUNG
 ELECTRONICS AMERICA, INC., a New
York corporation; SAMSUNG
 TELECOMMUNICATIONS AMERICA,
LLC, a Delaware limited liability company,

Defendant.


02198.51855/4662841.1

DECLARATION OF HANKIL KANG

1

DECLARATION OF HANKIL KANG

2

I, Hankil Kang, declare as follows:

3

1.

I am Legal Counsel for Samsung Electronics Co., Ltd., in the above-entitled

4 action. I make this declaration of personal, first-hand knowledge, and if called and sworn as a
5 witness, I could and would testify competently thereto.
6

2.

Based on my role as Legal Counsel, I am familiar with the organizational

7 and reporting structure for Samsung Electronics Co., Ltd. (“SEC”) and its subsidiary, Samsung
8 Telecommunications America, LLC (“STA”) (collectively “Samsung”) and with Samsung’s
9 products.
10

3.

Since 2010, Gee-Sung Choi has been the Vice-Chairman and Chief

11 Executive Officer of SEC. During his career at Samsung, Mr. Choi has held the positions of:
12 President of Corporate Management (2010); President of the Digital Media & Communications
13 Division (2009-2010); President of the Telecommunications Division (2007-2009); and President
14 of the Digital Media Division (2004-2007). Mr. Choi has also worked in the Semiconductor
15 Division.
16

4.

I am informed and believe that Alkon is the project code name for a

17 Samsung product that is not sold in the United States.
18

5.

I am informed and believe that Lismore is a project code name for a

19 smartphone that uses Samsung’s proprietary Bada smartphone platform. Lismore is not an
20 Android-based smartphone.
21
22

I declare under penalty of perjury under the laws of the United States of America

23 that the foregoing is true and correct.
24

Executed March 19, 2012, at Suwon, Korea.

25
26
Hankil Kang
27
28
02198.51855/4662841.1

-2DECLARATION OF HANKIL KANG