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 C

From:
To:
Cc:
Subject:
Date:
Attachments:

Mazza, Mia
Rachel Herrick Kassabian
AppleMoFo; Samsung v. Apple; WH Apple Samsung NDCal Service
Apple v. Samsung: Continued URGENT Need to Finalize Korea Depo Scheduling
Sunday, February 05, 2012 11:52:54 AM
mg_info.txt

Rachel:
As reflected below, I was informed by Victoria on February 1 that you would get back
to me the next morning regarding finalizing the schedule for depositions in Korea.
You never contacted me to discuss that topic. As you know, Apple's team is currently
in Korea to take the noticed depositions of Samsung witnesses. It is important that the
schedule be finalized immediately to avoid wasting the resources Apple has put forth to
depose Samsung's witnesses in the place where they are located.
1. Apple has determined that it will not at this time pursue the depositions of Woncheol
Chae, Chang Hwan Hwang, Eun Go, Paul Golden, David La, and Hankil Yoon, but Apple
reserves its rights to seek their depositions at a later time.
2. In scheduling Korean travel and other arrangements, Apple has relied and is relying on
the following schedule based on the parties' communications, including the discussion thread
below:
YoungSoon Lee (February 7)
Sun-Young Yi (February 8)
Hangil Song (February 7/8)
ByongChol Hwang (February 8)
Minhkyung Kim (February 10)
Kiyung Nam (February 10)
Jong-Kyun Shin (February 13, as noticed)*
Giyoung Lee (February 16/17)
Youngseok Bang (February 17)
Don Joo Lee (February 17)
Junwon Lee (February 22)
Yun-Jung Lee (February 23/24)
Seoggeun Kim (February 29)
Minhyouk Lee (February 28/29)
Seung Hun-Yoo (March 2)
3. Apple would like to depose the following five witnesses during the week of February 13,
on the dates set forth below. Please let us know immediately if a different date that week
works better for any of these witnesses. The dates previously provided for the first four
witnesses are unacceptably late. No date has been provided for the fifth witness.
Dong Jin Koh (February 14) [Originally noticed for December 5]*
Joon-Il Choi (February 14) [Originally noticed for December 5]
Dong Hoon Chang (February 15) [Originally noticed for January 9]*
Won Pyo Hong (February 15) [Originally noticed for January 12]*

Suk Geun Kim (February 16) [Originally noticed for January 12]
4. Please let us know which of the following are alternate spellings of the same person's
Soggeun
name and which are different Samsung employees (current or former):
Kim, Seog Guen Kim, Seok Gun Kim, Suk Keun Kim, and Suk Geun Kim.
5. Please offer dates for the following noticed witnesses. Apple has provided Samsung with
dates for all of the witnesses Samsung has noticed, regardless of objection. Please extend us
the same courtesy.
SangEun Lee (noticed for February 1, deposition to take place on or before March 2)
SeongWon Yoon (noticed for February 1, deposition to take place on or before March
2)
Seung-Yun Lee (noticed for February 1, deposition to take place on or before March 2)
In-Ho Kim (noticed for February 2, deposition to take place on or before March 2)
Jon-Sik Seong (noticed for February 3, deposition to take place on or before March 2)
Byeong-Wook Kim (noticed for February 6, deposition to take place on or before
March 2)
Kun Ro (noticed for February 6, deposition to take place on or before March 2)
Hyoung-Shin Park (noticed for February 6, deposition to take place on or before March
2)
Heonbae Kim (noticed for February 6, deposition to take place on or before March 2)
Seunghwan Cho (noticed for February 6, deposition to take place on or before March 2)
Dae-Woon Myeong (noticed for February 7, deposition to take place on or before
March 2)
YoungHoon Eom (noticed for February 8, deposition to take place on or before March
2)*
Min-Cheol Shin (noticed for February 8, deposition to take place on or before March
2)*
Gee Sung Choi (noticed for February 8, deposition to take place on or before March 2)
Sungsik Lee (noticed for February 9, deposition to take place on or before March 2)
Younghee Lee (noticed for February 10, deposition to take place on or before March
2)*
Sang Hung (noticed for February 10, deposition to take place on or before March 2)
DongSeok Ryu (noticed for February 13, deposition to take place on or before March
2)
Hoosoo Seo (noticed for February 14, deposition to take place on or before March 2)
6. Please provide witnesses and dates for the topics set forth in Apple's 8 outstanding
30(b)(6) notices. To date, Samsung has not yet provided a single witness or date for any of
the notices Apple has served beginning in October 2011.
7. Apple's acknowledges Samsung's February 3 letter stating its objections to Apple
deposing the eight witnesses designated with an asterisk (*) above. We will address that
issue, and Samsung's proposed limitation to the scope of Mr. Don Joo Lee's February
17 deposition, in separate correspondence. Apple does not agree to any such limitation of the
scope of its deposition of Mr. Lee.

Deposition scheduling is already on Apple's agenda for this Monday's lead trial counsel
meeting. I hope that Samsung will, before then, provide the requested dates for these 24
witnesses so that we do not need to take up lead counsel's time on this scheduling matter.
Regards,
Mia Mazza
Morrison & Foerster LLP
San Francisco
[phone] office
[phone] mobile
[phone] fax
From: Mazza, Mia
Sent: Wednesday, February 01, 2012 8:24 AM
To: 'Victoria Maroulis'
Cc: AppleMoFo; Samsung v. Apple; '[e-mail]'; '[e-mail]';
'[e-mail]'; Rachel Herrick Kassabian
Subject: RE: Samsung Deposition Dates - URGENT Need to Finalize Korea Deposition Scheduling

Thanks Victoria.
To be clear, the below first bullet point list does represent Apple's acceptance of the dates
offered by Samsung.
We advised in correspondence last week that the first six dates in the second bullet-point list
(in bold blue) offered by Samsung are not acceptable to Apple, and we have provided
information regarding the ranges in which we request that Samsung search for earlier dates.
Most importantly, for the rest of the dates in the second bullet-point list (24 witnesses),
Samsung has not offered any dates, so we are unable to accept any outstanding dates. If
Samsung would offer dates for those 24 witnesses it would go a long way towards finalizing
the Korea schedule.
Regards,
Mia Mazza
Morrison & Foerster LLP
San Francisco
[phone] office
[phone] mobile
[phone] fax

From: Victoria Maroulis [mailto:[e-mail]]
Sent: Wednesday, February 01, 2012 8:01 AM
To: Mazza, Mia; Rachel Herrick Kassabian
Cc: AppleMoFo; Samsung v. Apple; '[e-mail]'; '[e-mail]';
'[e-mail]'
Subject: RE: Samsung Deposition Dates - URGENT Need to Finalize Korea Deposition Scheduling

Counsel,

Rachel is traveling. She will respond to you tomorrow morning. Please accept the outstanding
dates Samsung previously offered. We are unable to offer any earlier dates than what was offered
so if those dates are not acceptable, please advise as soon as possible, and we will search for other
dates before March 8.
Thank you.

Victoria Maroulis
Partner,

Quinn Emanuel Urquhart & Sullivan, LLP
555 Twin Dolphin Drive, 5th Floor
Redwood Shores, CA 94065
650-801-5022 Direct
650.801.5000 Main Office Number
650.801.5100 FAX
[e-mail]
www.quinnemanuel.com
NOTICE: The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s)
named above. This message may be an attorney-client communication and/or work product and as such is privileged and confidential.
If the reader of this message is not the intended recipient or agent responsible for delivering it to the intended recipient, you are
hereby notified that you have received this document in error and that any review, dissemination, distribution, or copying of this
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original message.

From: Mazza, Mia [mailto:[e-mail]]
Sent: Wednesday, February 01, 2012 7:55 AM
To: Rachel Herrick Kassabian
Cc: AppleMoFo; Samsung v. Apple; [e-mail]; [e-mail];
[e-mail]
Subject: FW: Samsung Deposition Dates - URGENT Need to Finalize Korea Deposition Scheduling
Importance: High

Rachel -I have not heard from you in response to my below January 29, 2012, email regarding
finalizing the deposition schedule for Korea. As you know, we have multiple attorneys
traveling to Korea to take the noticed depositions of 50 Samsung witnesses in the N.D. Cal.
case. You have provided us with reasonably acceptable dates for only 17 of them, as follows:
Jeeyuen Wang (February 2)
Jung Min Yeo (February 2)
Jin-Soo Kim (February 2/3)
YoungSoon Lee (February 7)
Sun-Young Yi (February 8)
Hangil Song (February 7/8)
Minhkyung Kim (February 10)
Kiyung Nam (February 10)
Giyoung Lee (February 16/17)

Youngseok Bang (February 17)
Woncheol Chae (February 20)
Junwon Lee (February 22)
Yun-Jung Lee (February 23/24)
Seoggeun Kim (February 29)
Minhyouk Lee (February 28/29)
Hankil Yoon (March 2)
Seung Hun-Yoo (March 2)
We are finalizing travel schedules and planning on taking these depositions on these dates.
We would appreciate it if you would do us the courtesy of responding with dates falling
within the requested ranges (identified below) for the following witnesses listed below.
For those marked with an asterisk (*), we will assume the deposition is going forward on the
date noticed unless you advise us by noon on Thursday, February 2 that the witness is
unavailable and provide an alternate date. Those depositions were noticed on or before
January 22 and we need to get them calendared.
Joon-Il Choi (noticed for December 5, deposition to take place on or before
February 7)
Dong Jin Koh (noticed for January 10, deposition to take place on or before
February 7)
Don Joo Lee (noticed for December 9, deposition to take place on or before
February 9)
Chang Hwan Hwang (noticed for January 10, deposition to take place on or
before February 24)
Dong Hoon Chang (noticed for January 9, deposition to take place on or
before February 24)
Won Pyo Hong (noticed for January 12, deposition to take place on or before
February 24)
Suk Geun Kim (noticed for January 12, deposition to take place on or before March 2)
SangEun Lee (noticed for February 1, deposition to take place on or before March 2)
SeongWon Yoon (noticed for February 1, deposition to take place on or before March
2)
Seung-Yun Lee (noticed for February 1, deposition to take place on or before March 2)
In-Ho Kim (noticed for February 2, deposition to take place on or before March 2)
Jon-Sik Seong (noticed for February 3, deposition to take place on or before March 2)
David La (noticed for February 3, deposition to take place on or before March 2)
Byeong-Wook Kim (noticed for February 6, deposition to take place on or before
March 2)*
Kun Ro (noticed for February 6, deposition to take place on or before March 2)*
Hyoung-Shin Park (noticed for February 6, deposition to take place on or before March
2) *
Heonbae Kim (noticed for February 6, deposition to take place on or before March 2)
Seunghwan Cho (noticed for February 6, deposition to take place on or before March 2)
Dae-Woon Myeong (noticed for February 7, deposition to take place on or before
March 2)*

ByongChol Hwang (noticed for February 8, deposition to take place on or before
March 2)*
YoungHoon Eom (noticed for February 8, deposition to take place on or before March
2)*
Min-Cheol Shin (noticed for February 8, deposition to take place on or before March
2)*
Gee Sung Choi (noticed for February 8, deposition to take place on or before March 2)
Sungsik Lee (noticed for February 9, deposition to take place on or before March 2)*
Younghee Lee (noticed for February 10, deposition to take place on or before March
2)*
Sang Hung (noticed for February 10, deposition to take place on or before March 2)
DongSeok Ryu (noticed for February 13, deposition to take place on or before March
2)*
Jong-Kyun Shin (noticed for February 13, deposition to take place on or before March
2)*
Eun Go (noticed for February 14, deposition to take place on or before March 2)*
Hoosoo Seo (noticed for February 14, deposition to take place on or before March 2)*
We hope that these dates can be confirmed and scheduled in advance of the upcoming lead
trial counsel meeting. I understand our co-counsel at WilmerHale will contact you
separately regarding the outstanding deposition notices served in Apple's defensive case.
Regards,
Mia Mazza
Morrison & Foerster LLP
San Francisco
[phone] office
[phone] mobile
[phone] fax
From: Mazza, Mia
Sent: Sunday, January 29, 2012 1:13 PM
To: '[e-mail]'
Cc: AppleMoFo; '[e-mail]'; '[e-mail]';
'[e-mail]'; '[e-mail]'
Subject: RE: Samsung Deposition Dates - Need to Finalize Korea Depo Scheduling

Hi Rachel,
As you know, we have attorneys traveling to Korea beginning this week. The schedule for
depositions to be taken in Korea over the next month needs to be finalized immediately.
For the following deponents, Samsung has not offered any dates. Samsung needs to provide
these dates immediately. Dates in parentheses are those originally noticed.
Suk Geun Kim (January 12)
SangEun Lee (February 1)
SeongWon Yoon (February 1)
Seung-Yun Lee (February 1)

In-Ho Kim (February 2)
Jon-Sik Seong (February 3)
David La (February 3)
Byeong-Wook Kim (February 6)
Kun Ro (February 6)
Hyoung-Shin Park (February 6)
Heonbae Kim (February 6)
Seunghwan Cho (February 6)
Dae-Woon Myeong (February 7)
ByongChol Hwang (February 8)
YoungHoon Eom (February 8)
Min-Cheol Shin (February 8)
Gee Sung Choi (February 8)
Sungsik Lee (February 9)
Younghee Lee (February 10)
DongSeok Ryu (February 13)
Jong-Kyun Shin (February 13)
Eun Go (February 14)
Hoosoo Seo (February 14)
For the following deponents, Apple has accepted Samsung's offered date(s) and we are
planning to move forward on the dates offered and accepted.
Jeeyuen Wang (February 2)
Jung Min Yeo (February 2)
Jin-Soo Kim (February 2/3)
YoungSoon Lee (February 7)
Sun-Young Yi (February 8)
Hangil Song (February 7/8)
Minhkyung Kim (February 10)
Kiyung Nam (February 10)
Giyoung Lee (February 16/17)
Youngseok Bang (February 17)
Woncheol Chae (February 20)
Junwon Lee (February 22)
Yun-Jung Lee (February 23/24)
Seoggeun Kim (February 29)
Minhyouk Lee (February 28/29)
Hankil Yoon (March 2)
Seung Hun-Soo (March 2)
For the following deponents, Apple has rejected Samsung's offered date and Samsung needs
to provide earlier dates, for the reasons set forth in my attached letter dated January 27, 2012.
Joon-Il Choi (noticed for December 5, March 5 proposed date rejected, need earlier date)
Don Joo Lee (noticed for December 9, February 17 proposed date rejected, need earlier
date)
Dong Jin Koh (noticed for January 10, February 27 proposed date rejected, need earlier

date)
Chang Hwan Hwang (noticed for January 10, March 7 proposed date rejected, need earlier
date)
Dong Hoon Chang (noticed for January 9, March 8 proposed date rejected, need earlier
date
Won Pyo Hong (noticed for January 12, March 7 proposed date rejected, need earlier date)
We also need to finalize scheduling for the depositions to take place in Dallas. Below are the
noticed dates. Please let us know if these dates work for you, or propose new dates
immediately.
Joseph Cheong (February 1)
Todd Pendleton (February 2)
Corey Kerstetter (February 3)
Paul Chapple (February 6)
Tim Benner (February 7)
Justin Lee (February 8)
If we cannot get these dates finalized in advance,
we would like to discuss these and other deposition issues at the upcoming lead trial
counsel meeting.
From: Mazza, Mia
Sent: Wednesday, January 25, 2012 12:27 AM
To: '[e-mail]'
Cc: AppleMoFo; '[e-mail]'; '[e-mail]';
'[e-mail]'; '[e-mail]'
Subject: FW: Samsung Deposition Dates

Hi Rachel,
To continue the discussion regarding scheduling of Samsung depositions, I have updated the
attached deposition scheduling chart sent earlier tonight, to include the additional Samsung
witnesses whose depositions were noticed on January 22. This chart reflects the noticed
deposition date for each such witness. We request that you confirm each date or provide an
alternative date. It is important that these remaining depositions be calendared as soon as
possible. If the parties cannot get all remaining dates finalized by the end of this week
we would like to include this on the agenda for Monday's lead trial counsel meeting.
I've also listed the names of the outstanding deponents below, along with their notice dates,
for ease of reference.
Dallas:
Joseph Cheong (February 1)
Todd Pendleton (February 2)
Corey Kerstetter (February 3)
Paul Chapple (February 6)
Tim Benner (February 7)
Justin Lee (February 8)

Location TBD:
SangEun Lee (February 1)
SeongWon Yoon (February 1)
Seung-Yun Lee (February 1)
In-Ho Kim (February 2)
Jon-Sik Seong (February 3)
David La (February 3)
Byeong-Wook Kim (February 6)
Kun Ro (February 6)
Hyoung-Shin Park (February 6)
Dae-Woon Myeong (February 7)
ByongChol Hwang (February 8)
YoungHoon Eom (February 8)
Min-Cheol Shin (February 8)
Sungsik Lee (February 9)
Younghee Lee (February 10)
DongSeok Ryu (February 13)
Jong-Kyun Shin (February 13)
Eun Go (February 14)
Hoosoo Seo (February 14)
Outstanding items from earlier correspondence:
Seung Hun Yoo (noticed for January 20, no date provided)
Suk Geun Kim (noticed for January 12, no date provided)
Regards,
Mia Mazza
Morrison & Foerster LLP
San Francisco
[phone] office
[phone] mobile
[phone] fax
From: Mazza, Mia
Sent: Tuesday, January 24, 2012 9:09 PM
To: 'Rachel Herrick Kassabian'
Cc: AppleMoFo; Samsung v. Apple; '[e-mail]'; '[e-mail]';
'Walden, S. Calvin'
Subject: FW: Samsung Deposition Dates

Hi Rachel,
The dates in your January 13 email below are acceptable to Apple with the
following exceptions.
1. As mentioned in my Sunday email below, Don Joo Lee, Joon-Il Choi, and Dong Jin Koh
need to go earlier in the schedule. There appears to be room between February 6-9.

2. We also need to depose Chang Hwan Hwang, Won Pyo Hong, and Dong HoonChang earlier in the schedule. We request that all depositions in Korea take place on or
before March 2.
3. Jung-Min Yeo has been cancelled in the ITC, so we would like to take the N.D. Cal.
deposition on February 3.
4. For the witnesses being deposed in both ITC and N.D. Cal., in coordination with Apple's
ITC 796 team we would like to take the ITC deposition first. Therefore, the N.D. Cal. dates
for Jin-Soo Kim, Yun-Jung Lee, Giyoung Lee, and Doo-Ju Byun are February 3, 10, 17, and
20, respectively.
5. You have proposed that Sun-Young Yi be deposed in Korea on February 8 instead of San
Francisco on February 3. This is acceptable to Apple.
6. You have proposed that Yun-Jung Lee be deposed on February 23/24 rather than February
9/10. We would prefer to keep the original dates, which our ITC team already accepted last
Friday.
7 . You have indicated Samsung will be proposing a replacement date for Seung Hun Yoo.
We also still have not received any date from you for Suk Geun Kim (alternative spelling
could be Seok Geun Kim, spelled
in Korean). Please provide dates for both of these
witnesses -- they should fall on or before March 2 as mentioned above.
Please see the attached proposed overall schedule. Dates highlighted in yellow were accepted
in previous correspondence.
Regards,
Mia Mazza
Morrison & Foerster LLP
San Francisco
[phone] office
[phone] mobile
[phone] fax

From: Mazza, Mia
Sent: Sunday, January 22, 2012 10:20 PM
To: 'Rachel Herrick Kassabian'
Cc: AppleMoFo; Samsung v. Apple; Samsung ITC
Subject: RE: Samsung Deposition Dates

Mia Mazza
Morrison & Foerster LLP
San Francisco
[phone] office
[phone] mobile
[phone] fax

From: Rachel Herrick Kassabian [mailto:[e-mail]]
Sent: Friday, January 13, 2012 6:58 PM
To: Mazza, Mia; Bartlett, Jason R.
Cc: AppleMoFo; Samsung v. Apple; Samsung ITC
Subject: Samsung Deposition Dates

Mia and Jason,
Pursuant to the parties’ agreement to exchange all deposition dates today, below please find
proposed deposition dates for the following witnesses:
Witness
Jeeyeun Wang
Jung Min Yeo
Sun-Young Yi
Seung Hun Yoo
YoungSoon Lee
Yunjung Lee
Minhkyung Kim
Kiyung Nam
Giyoung Lee
Youngseok Bang
Don Joo Lee
Jinsoo Kim
Woncheol Chae
Junwon Lee
Hangil Song
Paul Golden
Dong Jin Koh
Seoggeun Kim
Minhyouk Lee
Hankil Yoon

Location
Seoul
Seoul
San Francisco
Seoul
Seoul
Seoul
Seoul
Seoul
Seoul
Seoul
Seoul
Seoul
Seoul
Seoul
Seoul
Texas
Seoul
Seoul
Seoul
Seoul

Date (NDCA)
Feb. 2
Feb. 2
Feb. 3
Feb. 7
Feb. 7
Feb. 9
Feb. 10
Feb. 10
Feb. 16
Feb. 17
Feb. 17
Feb. 2
Feb. 20
Feb. 22
Feb. 22
Feb. 24
Feb. 27
Feb. 29
Feb. 29
Mar. 2

Date (796 ITC)
Feb. 3

Feb. 10

Feb. 17

Feb. 3

Joon-Il Choi
Chang Hwan Hwang
Won Pyo Hong
Dong Hoon Chang

Seoul
Seoul
Seoul
Seoul

Mar. 5
Mar. 7
Mar. 7
Mar. 8

Italicized dates/ names are still awaiting final confirmation and may be subject to change.
Please note that just because a date is offered above, it does not mean that Samsung has waived
its objections to producing these witnesses. To the contrary, Samsung reserves all rights to object
to producing these witnesses, including on relevance, cumulativeness or apex grounds, among
others. We will notify Apple regarding any witnesses Samsung declines to produce in due course.
Further, we have just received a few additional deposition notices yesterday, which arrived after
we agreed to exchange deposition dates today. We have not yet had a chance to consult with our
client on these and will get back to you next week. If you believe our list is missing any other
deponents, please advise.
Finally, please note that Samsung will not be providing a deposition date for Mr. Sohn, as Samsung
has already made a final determination that his deposition is an improper apex deposition, per our
correspondence earlier today.
Please send proposed deposition dates for all noticed Apple witnesses, per the parties agreement,
today.
Regards,
Rachel Herrick Kassabian | Partner
Quinn Emanuel Urquhart & Sullivan LLP
555 Twin Dolphin Drive, Fifth Floor
Redwood Shores, CA 94065
650.801.5005 Direct
650.801.5000 Main
650.801.5100 Fax
[e-mail]
www.quinnemanuel.com
NOTICE: The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s)
named above. This message may be an attorney-client communication and/or work product and as such is privileged and confidential.
If the reader of this message is not the intended recipient or agent responsible for delivering it to the intended recipient, you are
hereby notified that you have received this document in error and that any review, dissemination, distribution, or copying of this
message is strictly prohibited. If you have received this communication in error, please notify us immediately by e-mail, and delete the
original message.