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

Filing 89

Declaration of Sissie Twiggs 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)(Related document(s) #86 ) (Bartlett, Jason) (Filed on 7/1/2011)

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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,

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Plaintiff,
v.

Case No. 11-cv-01846-LHK
DECLARATION OF SISSIE TWIGGS
IN SUPPORT OF APPLE INC.’S
MOTION FOR A PRELIMINARY
INJUNCTION

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

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DECLARATION OF SISSIE TWIGGS IN SUPPORT OF APPLE’S MOTION FOR A PRELIMINARY INJUNCTION
CASE NO. 11-CV-01846-LHK
sf-3013006

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I, Sissie Twiggs, declare as follows:

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1.

My title is Director, Worldwide Advertising at Apple Inc. I submit this

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declaration in support of Apple’s Motion for a 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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2.

Apple has invested heavily in promoting its iPhone and iPad products. Apple has

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reported total advertising expenditures of $691 million, $501 million, and $486 million for

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2010, 2009, and 2008, respectively.

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Apple’s iPhone Advertising
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Apple promotes its iPhone products extensively in print media. Attached as

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Exhibit 1 is a true and correct copy of a print advertisement from 2007 featuring the original

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iPhone. Attached as Exhibit 2 is a true and correct copy of a print advertisement from 2008

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featuring the iPhone 3G. Attached as Exhibit 3 is a true and correct copy of a print

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advertisement from 2009 featuring the iPhone 3GS. Attached as Exhibits 4-5 are true and

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correct copies of print advertisements from 2010 featuring the iPhone 4. The print

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advertisements shown in Exhibits 1-5 have appeared in nationally circulated newspapers and

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magazines.

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4.

Apple promotes its iPhone products extensively through television commercials.

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Enclosed on a CD as Exhibits 6-10 are true and correct copies of television commercials from

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2007 through 2011 featuring the iPhone products. The television commercials in Exhibits 6-10

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have appeared during primetime national television broadcasts.

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Apple’s iPad Advertising

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5.

Apple promotes its iPad products extensively in print media. Attached as

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Exhibits 11-13 are true and correct copies of print advertisements from 2010 featuring the first-

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generation iPad. Attached as Exhibit 14 is a true and correct copy of a print advertisement from

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2011 featuring the iPad 2. The print advertisements shown in Exhibits 11-14 have appeared in

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nationally circulated newspapers and magazines.

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DECLARATION OF SISSIE TWIGGS IN SUPPORT OF APPLE’S MOTION FOR A PRELIMINARY INJUNCTION
CASE NO. 11-CV-01846-LHK
sf-3013006