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 F

quinn emanuel

trial lawyers | silicon valley

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WRITER'S INTERNET ADDRESS
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March 3, 2012
VIA ELECTRONIC MAIL
Mia Mazza
Morrison & Foerster
425 Market Street
San Francisco, CA 94105-2482
Re:

Apple Inc. v. Samsung Elecs. Co. et al., Case No. 11-cv-1846

Dear Mia:
I write in response to your letter regarding Apple’s notice of deposition for Giho Ro, which we
received after the close of business on Friday night. As an initial matter, Apple’s notice is
untimely, as it was served with just four business days before the close of discovery. On this
basis alone, Samsung is not obliged to make him available.
Moreover, Apple’s only articulated basis for noticing Mr. Ro’s deposition was his alleged
participation in preparing the documents referenced in Apple’s Tenth Rule 30(b)(6) Notice.
Subject to its objections, Samsung hereby designates Jae-Hwang Sim, Vice President of
Samsung’s Business Operations Group, as a 30(b)(6) witness for at least the topics in Apple’s
Tenth Notice. We trust that Samsung’s designation of Vice President Sim for those topics
obviates Apple’s perceived need for Mr. Ro’s testimony, and that Apple with withdraw the
notice of deposition served last night. But in any event, to be clear, Samsung will not be offering
Mr. Ro for deposition.
Please confirm that Apple will depose Vice President Sim on March 8, 2012 in Korea.
quinn emanuel urquhart & sullivan, llp
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Very truly yours,

/s/ Rachel Herrick Kassabian
Rachel Herrick Kassabian
02198.51855/4634699.1

02198.51855/4634699.1

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