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

Filing 854

NOTICE by Samsung Electronics America, Inc., Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC 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 Notice of In Camera Submission (Maroulis, Victoria) (Filed on 4/6/2012)

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP
Charles K. Verhoeven (Bar No. 170151)
[e-mail]
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50 California Street, 22nd Floor
3 San Francisco, California 94111
Telephone: [phone]
4 Facsimile: [phone]
Kevin P.B. Johnson (Bar No. 177129
[e-mail]
Victoria F. Maroulis (Bar No. 202603)
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[e-mail]
555 Twin Dolphin Drive, 5th Floor
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Redwood Shores, California 94065-2139
[phone]
8 Telephone:
Facsimile:
[phone]
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5

Michael T. Zeller (Bar No. 196417)
[e-mail]
865 S. Figueroa St., 10th Floor
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Los Angeles, California 90017
12 Telephone: [phone]
Facsimile: [phone]
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14 Attorneys for SAMSUNG ELECTRONICS CO.,
LTD., SAMSUNG ELECTRONICS AMERICA,
15 INC. and SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

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20 APPLE INC., a California corporation,
Plaintiff,

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vs.

23 SAMSUNG ELECTRONICS CO., LTD., a
Korean business entity; SAMSUNG
24 ELECTRONICS AMERICA, INC., a New
York corporation; SAMSUNG
25 TELECOMMUNICATIONS AMERICA,
LLC, a Delaware limited liability company,
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Defendant.
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CASE NO. 11-cv-01846-LHK
SAMSUNG'S NOTICE OF IN CAMERA
LODGING OF MATERIALS IN
SUPPORT OF SAMSUNG'S MOTION TO
COMPEL PRODUCTION OF
MATERIALS FROM RELATED
PROCEEDINGS AND TO ENFORCE THE
DECEMBER 22, 2011 COURT
ORDER; AND REQUEST FOR ORDER
PLACING MATERIALS IN THE
RECORD

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Case No. 11-cv-01846-LHK
SAMSUNG'S NOTICE OF IN CAMERA LODGING OF MATERIALS IN SUPPORT OF SAMSUNG'S MOTION
TO COMPEL PRODUCTION AND TO ENFORCE THE DECEMBER 22, 2011 COURT
ORDER; AND REQUEST FOR ORDER PLACING MATERIALS IN RECORD

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TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

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PLEASE TAKE NOTICE that Samsung Electronics Co., Ltd., Samsung Electronics

3 America, Inc. and Samsung Telecommunications America, LLC (collectively, "Samsung") is
4 hereby lodging an in camera submission with the Court consisting of the February 15, 2012
5 deposition of Christopher Stringer and the February 9, 2012 deposition of Douglas Satzger,
6 conducted in a related proceeding involving Samsung and Apple, Inc. ("Apple") before the
7 International Trade Commission captioned In re Certain Electronic Digital Media Devices And
8 Components Thereof, Inv. No. 337-TA-796 (the "796 Investigation"). Samsung also lodges the
9 exhibits to these depositions. Apple has previously consented to in camera submission of
10 deposition transcripts from the 796 Investigation. See Dkt. 839-5.
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Samsung maintains its objection to the adjudication of its motion without including any

12 portion of the relevant 796 Investigation deposition transcripts in the record, because it believes an
13 understanding of the content and significance of the relevant testimony will likely assist the Court
14 in its consideration of Samsung's motion. Further, as stated in Samsung's Reply Memorandum In
15 Support of Samsung's Motion to Compel Production of Materials From Related Proceedings and
16 to Enforce the December 22, 2011 Court Order, Dkt. 839, in camera submission of these
17 deposition transcripts is insufficient for a number of reasons, not the least of which is that it fails
18 to establish a proper record so that these documents may be reviewed by the District or Circuit
19 Courts as part of their consideration of this or related motions, or of an appeal. However, because
20 the only use that Apple will permit Samsung with respect to submission of the content of these
21 transcripts to this Court is a direct in camera submission, Samsung offers a narrowly tailored in
22 camera submission of certain transcripts and exhibits, and requests that the Court enter an order
23 placing these transcripts in the Court record.
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Case No. 11-cv-01846-LHK
SAMSUNG'S NOTICE OF IN CAMERA LODGING OF MATERIALS IN SUPPORT OF SAMSUNG'S MOTION
TO COMPEL PRODUCTION AND TO ENFORCE THE DECEMBER 22, 2011 COURT
ORDER; AND REQUEST FOR ORDER PLACING MATERIALS IN RECORD

1 DATED: April 6, 2011

Respectfully submitted,

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QUINN EMANUEL URQUHART &
SULLIVAN, LLP

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By/s/ Victoria Maroulis
Charles K. Verhoeven
Kevin P.B. Johnson
Victoria F. Maroulis
Michael T. Zeller
Attorneys for SAMSUNG ELECTRONICS CO.,
LTD., SAMSUNG ELECTRONICS AMERICA,
INC. and SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC

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Case No. 11-cv-01846-LHK
-2SAMSUNG'S NOTICE OF IN CAMERA LODGING OF MATERIALS IN SUPPORT OF SAMSUNG'S MOTION
TO COMPEL PRODUCTION AND TO ENFORCE THE DECEMBER 22, 2011 COURT
ORDER; AND REQUEST FOR ORDER PLACING MATERIALS IN RECORD