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 2

quinn emanuel

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January 9, 2012
VIA HAND DELIVERY
Mia Mazza
Morrison & Foerster
425 Market Street
San Francisco, CA 94105-2462
Re:

Apple v. Samsung, Case No. 11-cv-01846-LHK (PSG) (N.D. Cal)

Dear Mia:
Enclosed, please find Samsung’s production of SAMNDCA-C000000613-764, SAMNDCAC000000836-928, and SAMNDCA-C000001144-1221, which were printed out last Friday,
January 6.
Samsung objects to the production of two printouts, SAMNDCA-C000000765-835 and
SAMNDCA-C000000929-1143, because they are excessively long. The former printout consists
of 71 consecutive pages and the latter printout contains 215 consecutive pages. Under Section
11(i) of the proposed protective order being negotiated between Apple and Samsung, printed
portions which exceed 50 continuous pages shall be presumed excessive and not done for a
permitted purpose. Similarly, Section 9(d) of the interim protective order provides that Samsung
may challenge the amount of source code requested in hard copy. Given the excessive volume
of source code that was printed and lack of any explanation why Apple needs to print such a
large number of pages, Samsung will not be producing the additional pages at this time. Apple
remains free to review and print sections of source code that are more narrowly tailored and

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reasonably necessary for Apple to facilitate its case.
Very truly yours,
/s/ Bill Trac
Bill Trac
Enclosures
02198.51855/4540901.1

02198.51855/4540901.1

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