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

Filing 87

Declaration of Patrick Zhang in Support of #86 MOTION for Preliminary Injunction filed byApple Inc.. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8, #9 Exhibit 9, #10 Exhibit 10, #11 Exhibit 11, #12 Exhibit 12, #13 Exhibit 13, #14 Exhibit 14, #15 Exhibit 15, #16 Exhibit 16, #17 Exhibit 17, #18 Exhibit 18, #19 Exhibit 19, #20 Exhibit 20, #21 Exhibit 21, #22 Exhibit 22, #23 Exhibit 23, #24 Exhibit 24, #25 Exhibit 25, #26 Exhibit 26, #27 Exhibit 27, #28 Exhibit 28, #29 Exhibit 29, #30 Exhibit 30, #31 Exhibit 31, #32 Exhibit 32, #33 Exhibit 33, #34 Exhibit 34, #35 Exhibit 35, #36 Exhibit 36, #37 Exhibit 37, #38 Exhibit 38, #39 Exhibit 39, #40 Exhibit 40, #41 Exhibit 41, #42 Exhibit 42, #43 Exhibit 43, #44 Exhibit 44, #45 Exhibit 45, #46 Exhibit 46, #47 Exhibit 47, #48 Exhibit 48, #49 Exhibit 49, #50 Exhibit 50, #51 Exhibit 51, #52 Exhibit 52)(Related document(s) #86 ) (Bartlett, Jason) (Filed on 7/1/2011)

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HAROLD J. MCELHINNY (CA SBN 66781)
[e-mail]
MICHAEL A. JACOBS (CA SBN 111664)
[e-mail]
JENNIFER LEE TAYLOR (CA SBN 161368)
[e-mail]
JASON R. BARTLETT (CA SBN 214530)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: 415.268.7522

KENNETH H. BRIDGES (CA SBN 243541)
[e-mail]
MICHAEL T. PIEJA (CA SBN 250351)
[e-mail]
BRIDGES & MAVRAKAKIS LLP
3000 El Camino Real
One Palo Alto Square, 2nd Floor
Palo Alto, CA 94306
Telephone: [phone]
Facsimile: [phone]

Attorneys for Plaintiff
APPLE INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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APPLE INC., a California corporation,
Plaintiff,

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v.
SAMSUNG ELECTRONICS CO., LTD., a
Korean business entity; SAMSUNG
ELECTRONICS AMERICA, INC., a New York
corporation; SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC, a
Delaware limited liability company,

Case No.

11-cv-01846-LHK

DECLARATION OF PATRICK J.
ZHANG IN SUPPORT OF
APPLE’S MOTION FOR A
PRELIMINARY INJUNCTION
Date:
Time:
Place:
Judge:

August 5, 2011
1:30 p.m.
Courtroom 4, 5th Floor
Hon. Lucy H. Koh

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Defendants.
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DECLARATION OF PATRICK J. ZHANG IN SUPPORT OF APPLE’S MOTION FOR A PRELIMINARY INJUNCTION
CASE NO. 4:11-CV-01846-LHK
sf-3010759

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I, PATRICK J. ZHANG, do hereby declare as follows:

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1.

I am an attorney at the law firm of Morrison & Foerster LLP, which is counsel for

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Plaintiff Apple Inc. I am admitted to practice law in the State of California and before this Court.

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I submit this declaration in support of Apple’s Motion for Preliminary Injunction. I have personal

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knowledge of the facts stated in this declaration, and I could and would competently testify to

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them if called as a witness.

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A.

Samsung’s Serial Copying

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2.

Attached as Exhibit 1 is a true and correct copy of a Wired.com Internet article

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10
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dated July 15, 2010,1 entitled “First Look: Samsung Vibrant Rips Off iPhone 3G Design,” which
reports that “Samsung’s latest phone, the Vibrant, has the body of an iPhone.”
3.

Attached as Exhibit 2 is a true and correct copy of a PCWorld.com Internet article

dated June 29, 2010,2,which reports that the Samsung Galaxy S design is “very iPhone 3GS-like.”
4.

Attached as Exhibit 3 is a true and correct copy of a Washington Post Internet

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article dated July 21, 2010,3 which reports that “[l]ike the European Galaxy S, the Vibrant

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resembles an iPhone 3GS.”

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5.

Attached as Exhibit 4 is a true and correct copy of a Fastcompany.com Internet

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article dated March 22, 2011,4 entitled “Samsung’s Anti-iPad 2 Policy: Clone the Heck Out of

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It,” which concludes that “Samsung has thrown in the towel on innovative tablet design.”

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6.

Attached hereto as Exhibit 5 is a true and correct copy of a BusinessInsider.com

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Internet article dated April 19, 20115, entitled “Samsung Has Been Copying Everyone Forever,

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Not Just Apple.”

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1

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http://www.wired.com/gadgetlab/2010/07/first-look-samsung-vibrant-rips-off-iphone3g-design/ printed on June 28, 2011.
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25
26

http://www.pcworld.com/article/200142/samsung_galaxy_s_how_does_it_measure_up_to_the_c
ompetition.html printed on June 28, 2011.
3

http://www.washingtonpost.com/wpdyn/content/article/2010/07/15/AR2010071506963.html printed on June 28, 2011.
4

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http://www.fastcompany.com/1741859/samsungs-anti-ipad-2-policy-clone-the-heck-outof-it printed on June 28, 2011.

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DECLARATION OF PATRICK J. ZHANG IN SUPPORT OF APPLE’S MOTION FOR A PRELIMINARY INJUNCTION
CASE NO. 4:11-CV-01846-LHK
sf-3010759

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7.

Attached as Exhibit 6 is a true and correct copy of a Fastcompany.com Internet

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article dated September 2, 2010,6 entitled “Samsung’s B+ Mentality: Find a Successful Product,

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Copy It Adequately.”

4

B.

May 12 Hearing Transcript

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8.

Attached as Exhibit 7 is a true and correct copy of an excerpt from the transcript of

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the May 12, 2011 hearing on Apple’s motion for expedited discovery.

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C.

May 12 Samsung Handout

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9.

Attached as Exhibit 8 is a true and correct copy of a hand out provided by

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Samsung’s counsel at the May 12, 2011 hearing on Apple’s motion for expedited discovery.

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D.

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Acer Stream

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10.

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Samsung-Identified Phones Were Released After the iPhone

Attached as Exhibit 9 is a true and correct copy of a SlashGear.com Internet article

dated May 27, 2010,7 reporting Acer’s official announcement of the Acer Stream.

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HTC Touch Pro2

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11.

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Attached as Exhibit 10 is a true and correct copy of a Sprint press release dated

August 31, 2009,8 announcing the release of the HTC Touch Pro2 on September 8, 2009.

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LG Axis LGAS740

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12.

Attached as Exhibit 11 is a true and correct copy of a Phonearena.com article dated

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January 13, 2011,9 reporting that the LG Axis is now available through Alltel.

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(Footnote continued from previous page.)

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5

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25
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http://www.businessinsider.com/samsung-designs-2011-4#ixzz1OUafB400 printed on
June 28, 2011.
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http://www.fastcompany.com/1686739/the-samsung-mo-find-a-successful-productcopy-it-adequately printed on June 29, 2011.
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http://www.slashgear.com/acer-stream-launches-with-android-2-1-snapdragon-hdmi2787249 printed on June 28, 2011.
8

http://newsroom.sprint.com/article_display.cfm?article_id=1205 printed on June 28,

2011.
9

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http://www.phonearena.com/news/Android-2.1-powered-LG-Axis-is-now-available-for90-through-Alltel_id15957 printed on June 28, 2011.

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DECLARATION OF PATRICK J. ZHANG IN SUPPORT OF APPLE’S MOTION FOR A PRELIMINARY INJUNCTION
CASE NO. 4:11-CV-01846-LHK
sf-3010759

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1

LG Cookie

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13.

Attached as Exhibit 12 is a true and correct copy of a Phonearena.com entry,10

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indicating that the LG Cookie was announced on September 30, 2008 and released on November

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26, 2008.

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LG Dare

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14.

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Attached is Exhibit 13 is a true and correct copy of a CNET review of the LG

Dare,11 indicating that the LG Dare was released on June 26, 2008.

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LG Pop

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15.

Attached as Exhibit 14 is a true and correct copy of a Phonearena.com entry,12

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indicating that the LG Pop was announced on September 30, 2009 and released on October 28,

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2009.

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Motorola Atrix 4G

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16.

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Attached as Exhibit 15 is a true and correct copy of a press release published by

Motorola on January 5, 2011,13 announcing the Motorola Atrix 4G.

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Nokia 5800xm

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17.

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Attached as Exhibit 16 is a true and correct copy of a press release published by

Nokia on October 2, 2008,14 announcing the pending release of the Nokia 5800xm.

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Palm Pre

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18.

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Attached as Exhibit 17 is a true and correct copy of a Sprint press release dated

May 19, 2009,15 announcing the release of the Palm Pre on June 6, 2009.

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10

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25
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http://reviews.cnet.com/cell-phones/lg-dare-verizon-wireless/4505-6454_733070218.html#reviewPage1 printed on June 28, 2011
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http://www.phonearena.com/phones/LG-Pop-GD510_id4018 printed on June 28, 2011.

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http://mediacenter.motorola.com/Press-Releases/Motorola-Mobility-and-AT-TAnnounce-ATRIX-4G-the-Future-of-Mobile-Computing-353c.aspx printed on June 28, 2011.
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http://press.nokia.com/2008/10/02/nokia-amps-up-music-offering-with-new-nokia5800-xpressmusic/ printed on June 28, 2011.
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http://www.phonearena.com/phones/LG-Cookie_id3185 printed on June 28, 2011.

http://newsroom.sprint.com/article_display.cfm?article_id=1130 printed on June 28,

2011.

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DECLARATION OF PATRICK J. ZHANG IN SUPPORT OF APPLE’S MOTION FOR A PRELIMINARY INJUNCTION
CASE NO. 4:11-CV-01846-LHK
sf-3010759

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1

RIM Blackberry Storm

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19.

Attached as Exhibit 18 is a true and correct copy of a press release published by

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Research In Motion on November 13, 2008,16 announcing the release of the Blackberry Storm on

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November 21, 2008.

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Samsung F700

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20.

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Attached as Exhibit 19 is a true and correct copy of a press release published by

Samsung on February 8, 2007,17 announcing the pending release of the Samsung F700.

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Samsung Galaxy i9000

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21.

10

Attached as Exhibit 20 is a true and correct copy of an article from Slashgear.com

published on March 23, 2010,18 reporting on the pending release of the Samsung Galaxy i9000.

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Sony Erisson Xperia Play

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22.

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Attached as Exhibit 21 is a true and correct copy of a press release published by

Sony Ericsson on February 13, 2011,19 announcing the Sony Erisson Xperia Play.

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E.

Prior Decree Concerning ’D087 Patent

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23.

Attached as Exhibit 22 is a true and correct copy of a January 5, 2011 order issued

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in Apple Inc. v. Brilliant Store, Inc., 10-cv-2996-SBA (N.D. Cal.).

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F.

18

Original iPhone

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24.

Apple’s Products

Attached as Exhibit 23 is a true and correct copy of a CNN.com article dated June

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30, 2011,20 reporting that the original iPhone went on sale on June 29, 2007 and is “turn[ing] 4

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years old.”

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16

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http://press.rim.com/partner/release.jsp?id=1891 printed on June 28, 2011.

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24

http://www.samsung.com/us/news/newsRead.do?news_seq=3516 printed on June 28,

2011.
18

http://www.slashgear.com/samsung-galaxy-s-gt-i9000-android-2-1-smartphoneannounced-2378775/ printed on June 28, 2011.
19

http://www.sonyericsson.com/mwcnews/xperia_play/ printed on June 28, 2011.

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DECLARATION OF PATRICK J. ZHANG IN SUPPORT OF APPLE’S MOTION FOR A PRELIMINARY INJUNCTION
CASE NO. 4:11-CV-01846-LHK
sf-3010759

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25.

Photographs of the original iPhone appearing in Apple’s Motion for a Preliminary

2

Injunction and the supporting Declaration of Cooper C. Woodring, filed herewith, are true and

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accurate representations of an iPhone.

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iPhone 3GS

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26.

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Attached as Exhibit 24 is a true and correct copy of CNET.com article dated June

8, 2009,21 reporting that the iPhone 3GS “will hit stores June 19.”

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27.

Photographs of the iPhone 3GS appearing in Apple’s Motion for a Preliminary

8

Injunction and the supporting Declaration of Cooper C. Woodring, filed herewith, are true and

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accurate representations of an iPhone 3GS.

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iPhone 4

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28.

Attached as Exhibit 25 is a true and correct copy of a CBSNews.com article dated

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June 30, 2011,22 reporting that “[t]oday marks the first year anniversary of the iPhone 4, the most

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advanced mobile phone Apple released to date.”

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29.

Photographs of the iPhone 4 appearing in Apple’s Motion for a Preliminary

15

Injunction and the supporting Declaration of Cooper C. Woodring, filed herewith, are true and

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accurate representations of an iPhone 4.

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iPad 2

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30.

Attached as Exhibit 26 is a true and correct copy of a Huffingtonpost.com article

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dated March 10, 2011,23 reporting that “[t]he new iPad 2 officially goes on sale Friday, March

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11.”

21

(Footnote continued from previous page.)

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24

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http://www.cnn.com/2011/TECH/innovation/06/29/original.iphone.four.years/index.html?hpt=te_
bn6 printed on June 30, 2011.
21

25

http://reviews.cnet.com/8301-19512_7-10260079-233.html printed on June 30, 2011.

22

http://www.cbsnews.com/8301-504943_162-20075554-10391715.html printed on June

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30, 2011.
23

27

http://www.huffingtonpost.com/2011/03/10/ipad-2-release-day-2011_n_834017.html
printed on June 30, 2011.

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DECLARATION OF PATRICK J. ZHANG IN SUPPORT OF APPLE’S MOTION FOR A PRELIMINARY INJUNCTION
CASE NO. 4:11-CV-01846-LHK
sf-3010759

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1
2

31.

Photographs of the iPad 2 appearing in Apple’s Motion for a Preliminary

Injunction, filed herewith, are true and accurate representations of an iPad 2.

3

G.

Public Reaction to Apple’s Designs

4

32.

Attached as Exhibit 27 is a true and correct copy of a New York Times review of

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6

the iPhone dated January 11, 2007,24 entitled “Apple Waves Its Wand at the Phone.”
33.

Attached as Exhibit 28 is a true and correct copy of a New York Times article dated

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June 27, 2007,25 reporting that “in the last six months, Apple’s iPhone has been the subject of

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11,000 print articles” and “turns up about 69 million hits on Google.” The article further states

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that “The iPhone is revolutionary,” and describes the iPhone as “a tiny, gorgeous hand-hand

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computer.” “The phone is so sleek and thin, it makes Treos and Blackberrys look obese.”
34.

Attached as Exhibit 29 is a true and correct copy of a Time article dated November

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1, 2007,26 naming the iPhone its “Invention Of the Year,” and listing the iPhone’s design (“The

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iPhone is pretty”) as the first reason that it is “the best thing invented this year.”

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35.

Attached as Exhibit 30 is a true and correct copy of a Korea JoongAng Daily

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Internet article dated February 18, 2008,27 entitled “Apple iPhone Tops List of Innovative

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inventions,” reporting the results of a survey of 599 Korean CEO’s by Samsung Economic

17

Research Institute, in which the CEOs indicated that the “iPhone’s sleek design caught their eye.”

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36.

Attached as Exhibit 31 is a true and correct copy of Walt Mossberg’s March 31,

19

2010 review of the iPad for WSJ.com,28 which refers to the iPad as “this beautiful new touch-

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screen device from Apple.”

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24

22
23
24

http://www.nytimes.com/2007/01/11/technology/11pogue.html?sq=pogue printed on
June 28, 2011.
25

http://www.nytimes.com/2007/06/27/technology/circuits/27pogue.html?pagewanted=2&ref=ipho
ne printed on June 28, 2011.
26

25
26
27

http://www.time.com/time/specials/2007/article/0,28804,1677329_1678542_1677891,00.html
printed on June 30, 2011.
27

http://joongangdaily.joins.com/article/view.asp?aid=2886322 printed on June 30, 2011.

28

http://allthingsd.com/20100331/apple-ipad-review/ printed on June 28, 2011.

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DECLARATION OF PATRICK J. ZHANG IN SUPPORT OF APPLE’S MOTION FOR A PRELIMINARY INJUNCTION
CASE NO. 4:11-CV-01846-LHK
sf-3010759

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1
2

37.

Attached as Exhibit 32 is a true and correct copy of a Wired.com review of the

iPad dated April 1, 2010,29 entitled “Why We Are Obsessed With the iPad.”

3

H.

4

Galaxy S 4G

5

38.

Samsung’s Products

Attached as Exhibit 33 is a true and correct copy of a PCMag.com article dated

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February 14, 2011,30 reporting on T-Mobile’s announcement that the Galaxy S 4G “will launch

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on February 23 for $149.99.”

8
9
10

39.

Photographs of the Samsung Galaxy S 4G appearing in Apple’s Motion for a

Preliminary Injunction and the supporting Declaration of Cooper C. Woodring, filed herewith, are
true and accurate representations of a Galaxy S 4G.

11

Droid Charge

12

40.

Attached as Exhibit 34 is a true and correct copy of Channelpartnersonline.com

13

article dated May 13, 2011,31 reporting that the delayed Samsung Droid Charge “is scheduled to

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go on sale Saturday [May 14, 2011].”

15

Infuse 4G

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41.

Attached as Exhibit 35 is a true and correct copy of a CNET article May 5, 2011,32

17

reporting that “[a]t a special event in New York today, AT&T and Samsung announced that the

18

Infuse 4G would be available starting May 15 for $199.99.”

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42.

Photographs of the Samsung Infuse 4G appearing in Apple’s Motion for a

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Preliminary Injunction and the supporting Declaration of Cooper C. Woodring, filed herewith, are

21

true and accurate representations of an Infuse 4G.

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23
24
25
26
27

29

http://www.wired.com/gadgetlab/2010/04/apple-ipad-hands-on/ printed on June 28,

30

http://www.pcmag.com/article2/0,2817,2380330,00.asp printed on June 28, 2011.

2011.
31

http://www.channelpartnersonline.com/news/2011/05/droid-charge-going-on-saletomorrow-report.aspx printed on June 28, 2011.
32

http://reviews.cnet.com/8301-19736_7-20059853-251.html printed on June 28, 2011.

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DECLARATION OF PATRICK J. ZHANG IN SUPPORT OF APPLE’S MOTION FOR A PRELIMINARY INJUNCTION
CASE NO. 4:11-CV-01846-LHK
sf-3010759

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1

Galaxy Tab

2

43.

Attached as Exhibit 36 is a true and correct copy of a Huffingtonpost.com article

3

dated November 11, 2010,33 entitled “Samsung Galaxy Tab REVIEW ROUNDUP: Critics React

4

to iPad’s 7-Inch Android Challenger (PHOTOS),” reporting that the Galaxy Tabs “are now

5

available from T-Mobile and Verizon.”

6

Galaxy Tab 10.1

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44.

Attached as Exhibit 37 is a true and correct copy of an Engadget article dated June

8

8, 2011,34 reporting that “[a]t noon Eastern Time today, Best Buy’s New York City store at Union

9

Square will start selling Samsung’s [Galaxy Tab 10.1].”

10

45.

Photographs of the Samsung Galaxy Tab 10.1 appearing in Apple’s Motion for a

11

Preliminary Injunction and the supporting Declaration of Cooper C. Woodring, filed herewith, are

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true and accurate representations of a Galaxy Tab 10.1.

13

I.

Nokia Answer and Counterclaim Showing Assertion of ’381 Patent

14

46.

Attached as Exhibit 38 is a true and correct copy of excerpts from Apple’s answer

15

and counterclaim in Nokia Corp. v. Apple Inc., No. 1:09-cv-00791, Dkt. No. 14 (D. Del.).

16

J.

Nokia Action Joint Claim Construction Chart

17

47.

Attached as Exhibit 39 is a true and correct copy of the parties’ February 23, 2011

18

Joint Claim Chart in Nokia Corp. v. Apple Inc., No. 1:09-cv-00791, Dkt. No. 227 (D. Del.).

19

K.

Nokia Requests Ex Parte Re-Examination of ’381 Patent

20

48.

Attached as Exhibit 40 is a true and correct copy of excerpts from Nokia’s opening

21

brief in support of its motion to stay Apple’s patent claims pending reexamination in Nokia Corp.

22

v. Apple Inc., 1:09-cv-00791, Dkt. No. 81(D. Del.), and excerpts from Exhibit 8 of the supporting

23

declaration, Dkt. No. 82-1.

24
25
26

33

http://www.huffingtonpost.com/2010/11/11/samsung-galaxy-tab-reviewroundup_n_782024.html#s180055&title=New_York_Times printed on June 30, 2011.
34

27

http://www.engadget.com/2011/06/08/samsung-galaxy-tab-10-1-on-sale-at-nyc-bestbuy-today-up-for-pr/ printed on June 28, 2011.

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DECLARATION OF PATRICK J. ZHANG IN SUPPORT OF APPLE’S MOTION FOR A PRELIMINARY INJUNCTION
CASE NO. 4:11-CV-01846-LHK
sf-3010759

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1

L.

Nokia’s Invalidity Contentions

2

49.

Attached as Exhibit 41 is a true and correct copy of excerpts from Nokia’s

3

November 15, 2010 supplemental interrogatory responses in Nokia Corp. v. Apple Inc., No. 1:09-

4

cv-00791 (D. Del.).

5

M.

’381 Patent Re-Examination Certificate

6

50.

Attached as Exhibit 42 is a true and correct copy of the certified re-examination

7

certificate for U.S. Patent No. 7,469,381 issued by the U.S. Patent & Trademark Office.

8

N.

Apple’s Complaint in Apple v. HTC Showing Assertion of ’381 Patent

9

51.

Attached as Exhibit 43 is a true and correct copy of excerpts from Apple’s

10

complaint in Apple Inc. v. HTC Corp., No. 1:10-cv-00167 (D. Del.).

11

O.

Samsung’s Newly Released Products Include Significant Upgrades

12

52.

Attached as Exhibit 44 is a true and correct copy of Samsung’s web site page for

13

the Galaxy S 4G,35 which touts the new features of that phone, including its ability to use fourth

14

generation or “4G” communication networks.

15
16
17

53.

The PCMag.com article attached as Exhibit 33 also reports that “The Samsung

Galaxy S 4G is T-Mobile's first high-speed HSPA+ 21 phone.”
54.

Attached as Exhibit 45 is a true and correct copy of Samsung’s web site page for

18

the Infuse 4G,36 which touts the new features of that phone, including its status as “The Nation’s

19

Thinnest 4G Smartphone” and “Samsung’s thinnest smartphone,” and its “Large 4.5” SUPER

20

AMOLED Plus” touch screen.

21
22

55.

The CNET article attached as Exhibit 35 also reports on the improved features of

the Infuse 4G:

23

The main attraction of the Infuse 4G though is the Super AMOLED
Plus display. It offers 50 percent more subpixels than previous
generation of Super AMOLED touch screens, so you get better

24
25

35

26

28, 2011.
36

27

http://www.samsung.com/us/mobile/cell-phones/SGH-T959HABTMB printed on June
http://www.samsung.com/us/mobile/cell-phones/SGH-I997ZKAATT printed on June

28, 2011.

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DECLARATION OF PATRICK J. ZHANG IN SUPPORT OF APPLE’S MOTION FOR A PRELIMINARY INJUNCTION
CASE NO. 4:11-CV-01846-LHK
sf-3010759

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1

contrast and outdoor visibility. The display is noticeably sharp and
vibrant, but even more so, when you put it next to one of the older
[Samsung] Galaxy models. The Samsung Infuse 4G also steps it up
a notch with a 1.2GHz processor and 16GB of internal memory. It
will also be the first HSPA+ Category 14 (21Mbps) 4G phone for
AT&T and it’s HSUPA-enabled at launch.

2
3
4
5
6
7
8
9
10

56.

Attached as Exhibit 46 is a true and correct copy of Samsung’s web site page for

the Droid Charge,37 which touts the new features of that phone, including its “4G Speed,” “Slim
Design,” and 4.3” Super AMOLED Plus Touch Screen Display.”
57.

Attached as Exhibit 47 is a true and correct copy of Samsung’s web site page for

the Galaxy Tab 10.1,38 which touts the new features of that device, including its “brilliant 10.1
[inch] display,” “The power and speed of Android 3.1” operating system, and its “.34 [inch]”
thickness.

11
P.
12
13
14
15
16
17
18

Apple’s Patents At Issue

58.

Attached as Exhibit 48 is a true and correct copy of U.S. Design Patent

No. D618,677.
59.

Attached as Exhibit 49 is a true and correct copy of U.S. Design Patent

No. D593,087.
60.

Attached as Exhibit 50 is a true and correct copy of U.S. Design Patent

No. D504,889.
61.

Attached as Exhibit 51 is a true and correct copy of U.S. Patent No. 7,469,381.

19
20

I declare under penalty of perjury that the foregoing is true and correct.

21
22

Dated: July 1, 2011

23

/s/ Patrick J. Zhang
Patrick J. Zhang

24
25

37

26

28, 2011.

http://www.samsung.com/us/mobile/cell-phones/SCH-I510RAAVZW printed on June

38

27

http://www.samsung.com/us/mobile/galaxy-tab-wifi-only/GT-P7510UWVXAR printed
on June 28, 2011.

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DECLARATION OF PATRICK J. ZHANG IN SUPPORT OF APPLE’S MOTION FOR A PRELIMINARY INJUNCTION
CASE NO. 4:11-CV-01846-LHK
sf-3010759

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I, JASON R. BARTLETT, am the ECF User whose ID and password are being used to

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file the following document: DECLARATION OF PATRICK J. ZHANG IN SUPPORT OF

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APPLE’S MOTION FOR A PRELIMINARY INJUNCTION. In compliance with General Order

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45, X.B., I hereby attest that Patrick J. Zhang has concurred in this filing.

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Dated: July 1, 2011

MORRISON & FOERSTER LLP
By: /s/ Jason R. Bartlett
JASON R. BARTLETT

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DECLARATION OF PATRICK J. ZHANG IN SUPPORT OF APPLE’S MOTION FOR A PRELIMINARY INJUNCTION
CASE NO. 4:11-CV-01846-LHK
sf-3010759

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