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

Filing 839

REPLY (re #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 bySamsung Electronics America, Inc., Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC. (Attachments: #1 Declaration, #2 Exhibit A, #3 Exhibit B, #4 Exhibit C, #5 Exhibit D, #6 Exhibit E, #7 Exhibit F)(Maroulis, Victoria) (Filed on 3/28/2012)

EXHIBIT C

Alex Hu
From:
Sent:
To:
Cc:
Subject:

Yohannan, Kristin L. [[e-mail]]
Monday, March 26, 2012 6:21 PM
Diane Hutnyan
Samsung ITC; Apple-Samsung-796-Service; S&[e-mail];
[e-mail]
RE: 796 Investigation: Regarding filing the 796 Deposition Transcripts Under Seal in Northern
California

Counsel Apple has a proposed compromise to try to overcome the current issue the parties have with
showing the 796 Investigation deposition transcripts to Judge Grewal (and possibly Judge Koh).
Samsung stated on today's DCM call that it wanted to prove to Judge Grewal and/or Judge Koh that
the ITC deposition transcripts have not been produced in the NDCal case. And, Samsung stated that
it wanted to show Judge Grewal and/or Judge Koh that there is a technological nexus between the
NDCal case and the 796 Investigation. Apple already offered to allow Samsung to submit the
transcripts in camera. Samsung rejected this proposal on the grounds of "burden." In view of this,
Apple is willing to agree to allow Samsung to show Judge Grewal and/or Judge Koh that the
deposition transcripts are part of the 796 Investigation case and have no Bates numbers from the
NDCal case by producing the first five pages of each of the transcripts you identified in your
previous correspondence. It is unnecessary to show Judge Grewal and/or Judge Koh the entire
deposition transcripts to prove this point. Moreover, Apple will stipulate to the fact that there is a
technological nexus between the NDCal case and the 796 Investigation. If Samsung agrees to this
compromise, Apple will agree to allow Samsung to file five pages from each of the deposition
transcripts that were previously identified with its motion under seal rather than file them for in
camera review.
Please let us know whether you agree to this compromise.
Best regards,
Kristin

From: Diane Hutnyan [mailto:[e-mail]]
Sent: Monday, March 26, 2012 5:20 PM
To: Yohannan, Kristin L.
Cc: Samsung ITC; Apple-Samsung-796-Service; 'S&[e-mail]'; '[e-mail]'
Subject: 796 Inv: Regarding filing the 796 Deposition Transcripts Under Seal in Northern California

Kristin,
Here is our protective order from the Northern District. Who can see HC-AEO items is set forth starting on page 11.
Nothing in any of these transcripts cannot be reasonably protected by HC-AEO treatment.
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