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

Filing 922

Administrative Motion to File Under Seal Samsung's Motion for Clarification Regarding the COurt's May 4, 2012 Order filed by Samsung Electronics America, Inc.(a New York corporation), Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC(a Delaware limited liability company). (Attachments: #1 Declaration of Joby Martin In Support of Samsung's Motion to File Documents Under Seal, #2 Exhibit Samsung's Motion For Clarification Regarding the Court's May 4, 2012 Order (Redacted), #3 Declaration of Mark TUng In Support of Samsung's Motion for Clarification (Redacted), #4 Exhibit 1 to the Tung Declaration, #5 Exhibit 2 to the Tung Declaration, #6 Exhibit 3 to the Tung Declaration, #7 Exhibit 4 to the Tung Declaration, #8 Exhibit 5 to the Tung Declaration, #9 Exhibit 6 to the Tung Declaration, #10 Exhibit 7 to the Tung Declaration, #11 Exhibit 8 to the Tung Declaration, #12 Exhibit 9 to the Tung Declaration, #13 Exhibit 10 to the Tung Declaration, #14 Exhibit 11 to the Tung Declaration, #15 Exhibit 12 to the Tung Declaration, #16 Exhibit 13 to the Tung Declaration, #17 Exhibit 14 to the Tung Declaration, #18 Exhibit 15 to the Tung Declaration, #19 Exhibit 16 to the Tung Declaration, #20 Exhibit 17 to the Tung Declaration, #21 Exhibit 18 to the Tung Declaration, #22 Proposed Order Granting Samsung's Administrative Motion to FIle Documents Under Seal)(Maroulis, Victoria) (Filed on 5/15/2012)

Download PDF
EXHIBIT 13 425 MARKET STREET SAN FRANCISCO CALIFORNIA 94105-2482 U.S.A. MORRISON & FOERSTER LLP TELEPHONE: 415.268.7000 FACSIMILE: 415.268.7522 TOKYO, LONDON, BRUSSELS, BEIJING, SHANGHAI, HONG KONG NEW YORK, SAN FRANCISCO, LOS ANGELES, PALO ALTO, SACRAMENTO, SAN DIEGO, DENVER, NORTHERN VIRGINIA, WASHINGTON, D.C. WWW.MOFO.COM May 10, 2012 Writer’s Direct Contact 415.268.6024 MMazza@mofo.com By Email (ketanpatel@quinnemanuel.com) Ketan Patel Quinn Emanuel 51 Madison Ave, 22nd Floor New York, NY 10010 Re: Apple v. Samsung, Case No. 11-cv-1846-LHK (PSG) (N.D. Cal.) Dear Ketan: I write regarding your letter of May 6, 2012, in which you requested that we make available for inspection the Samsung products discussed by Dr. Balakrishnan in his opening expert report. As you noted in your letter of April 22, Samsung made this request because it was purportedly interested in the “version of the Android code . . . installed on the devices . . . [and the] version of the Gallery, Contacts or ThinkFree Office software . . . installed on the devices.” In my letter of May 2, Apple offered to provide Samsung with the exact information requested. Your suggestion now that that offer is somehow “insufficient” is perplexing. Samsung obviously has access to its own products and its own source code, and can easily confirm the operation of those products. During his deposition, Samsung’s expert Dr. Johnson was even provided an opportunity to inspect a number of the products discussed in Dr. Balakrishnan’s report, including the Galaxy Ace, the Galaxy S 4G, and the Galaxy S Showcase, and went so far as to read into the record the technical specifications and Android version information for those devices. See, e.g., Johnson Dep. Tr. at 195:6-197:1. Please find below a table with the information you requested. Sincerely, /s/ Mia Mazza Mia Mazza Encl. sf-3143532 Ketan Patel May 10, 2012 Page Two cc: S. Calvin Walden Peter Kolovos sf-3143532 Ketan Patel May 10, 2012 Page Three Product Name Android Version ThinkFree Office Version Captivate 2.1-update1 - Continuum 2.1-update1 2.0.0810.01 Droid Charge 2.2.1 2.0.110222 Epic 4G 2.2.1 2.0.1115.01 Exhibit 4G 2.3.3 2.0.110222 Fascinate 2.2.2 2.0.110222 Galaxy Ace 2.2.1 2.0.1115.01 Galaxy Prevail 2.2.2 2.0.110222 Galaxy S (i9000) 2.2.1 2.0.1011.01 Galaxy S II (i9100) 2.3.3 - Galaxy S II (AT&T) 2.3.4 - Galaxy S II Epic 4G Touch 2.3.4 - Galaxy S 4G 2.2.1 2.0.110222 Galaxy S Showcase (i500) 2.1-update1 2.0.0810.01 Galaxy Tab 7.0 2.3.5 2.0.110222 Galaxy Tab 10.1 3.1 - Gem 2.1-update1 - Gravity Smart 2.2.2 - Indulge 2.2.1 2.0.110222 Infuse 4G 2.2.1 - Intercept 2.2.2 2.0.1115.01 sf-3143532 Ketan Patel May 10, 2012 Page Four Mesmerize 2.1-update1 2.0.0810.01 Nexus S 2.3.1 - Nexus S 4G 2.3.4 - Replenish 2.2.2 2.0.110222 Sidekick 2.2.1 2.0.110222 Vibrant 2.1-update1 - sf-3143532

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?