Apple Inc. v. Samsung Electronics Co. Ltd. et al
OPPOSITION to ( #782 Administrative Motion to File Under Seal re Samsung's Motion Compel Production Materials From Related Proceedings and to Enforce 12/22/11 Court Order ) filed byApple Inc.. (Attachments: #1 Nathan Sabri Declaration, #2 Exhibit 1, #3 Exhibit 2, #4 Exhibit 3, #5 Exhibit 4, #6 Exhibit 5, #7 Exhibit 6, #8 Exhibit 7, #9 Exhibit 8, #10 Proposed Order)(Jacobs, Michael) (Filed on 3/21/2012) Modified text on 3/22/2012 (dhm, COURT STAFF).
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L O S A N G E L E S, P A L O A L T O ,
SAC RAME N T O , SAN D I E G O ,
D E N VE R, N O RT H E RN VI RG I N I A,
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T O K YO , L O N D O N , BR U SSE L S,
BE I JI N G , SH AN G H AI , H O N G K O N G
February 10, 2012
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Los Angeles, CA 90017-2543
Apple v. Samsung, Case No. 11-cv-1846 LHK (N.D. Cal.)
I write in response to your February 3, 2012, and February 8, 2012, letters requesting
documents from proceedings involving the patents-in-suit.
It appears from your letters that Samsung has been aware of all related proceedings involving
the patents-in-suit or related patents. Samsung has listed all such proceedings in both its
Request for Production No. 75 and again in its February 8 letter. Apple is not aware of any
other proceedings that involve the patents-in-suit or related patents.
As for your request that Apple produce “materials” from “any other cases having a
technological nexus to the issues in this case,” Apple declines to do so. Pursuant to the
Court’s January 15, 2012 Order, Apple will only produce the deposition transcripts of Apple
witnesses bearing a “technological nexus” to the patents-in-suit. Your document requests do
not seek all materials from cases with a “technological nexus” with this case. Your sudden
expansion of your request to include all such documents appears to be for the purpose of
Furthermore, Samsung appears to have done nothing for several months despite Judge
Grewal ordering Samsung to take on the tasks of obtaining third party approval. As stated in
the February 6, 2012, meet-and-confer with lead counsel, Samsung needs to obtain this
consent before Apple can produce unredacted confidential documents. Once Samsung
obtains this consent, Apple will promptly produce such documents.
/s/ Jason R. Bartlett
Jason R. Bartlett
Peter Kolovos, S. Calvin Walden
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