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

Filing 892

OPPOSITION to ( #885 ADMINISTRATIVE MOTION For Clarification Of April 12 Order ) filed by Samsung 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, #8 Exhibit G, #9 Exhibit H, #10 Exhibit I, #11 Exhibit J, #12 Exhibit K, #13 Exhibit L, #14 Exhibit M, #15 Exhibit N, #16 Exhibit O, #17 Proposed Order)(Maroulis, Victoria) (Filed on 4/30/2012) Modified text on 5/1/2012 (dhm, COURT STAFF).

EXHIBIT C

425 MARKET STREET
SAN FRANCISCO
CALIFORNIA 94105-2482
TELEPHONE: [phone]
FACSIMILE: 415.268.7522

MO RRI SO N & F O E RST E R L LP
N E W YO RK , SAN F RAN C I SCO ,
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,
WASH I N G T O N , D .C.
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

WWW.MOFO.COM

February 10, 2012
By Email ([e-mail])

Writer’s Direct Contact
415.268.6615
[e-mail]

Diane Hutnyan
Quinn Emanuel
865 South Figueroa St., 10th Floor
Los Angeles, CA 90017-2543
Re:

Apple v. Samsung, Case No. 11-cv-1846 LHK (N.D. Cal.)

Dear Diane:
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
harassment.
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.
Sincerely,
/s/ Jason R. Bartlett
Jason R. Bartlett
cc:

Peter Kolovos, S. Calvin Walden

sf-3105887