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)

EXHIBIT 13

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May 10, 2012

Writer’s Direct Contact
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By Email ([e-mail])
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