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

Filing 974

Declaration of Cyndi Wheeler in Support of #934 Administrative Motion to File Under Seal Re Samsungs Motion To Strike Expert Testimony 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 Declaration Of Mark D. Selwyn In Support Of Samsungs Administrative Motion To File Documents Under Seal Re Samsungs Motion To Strike Expert Testimony, #14 Selwyn Decl. Ex. 1, #15 Selwyn Decl. Ex. 2, #16 Proposed Order [Proposed] Order Granting Samsungs Administrative Motion To File Documents Under Seal Re Samsungs Motion To Strike Expert Testimony)(Related document(s) #934 ) (Bartlett, Jason) (Filed on 5/24/2012)

Exhibit 9

EXHIBIT H
FILED UNDER SEAL

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 ,
LO S AN G E LE S , P ALO ALTO ,
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 , BRU SSE L S ,
BE I JI N G , SH AN G H AI , H O N G K O N G

WWW.MOFO.COM

March 15, 2012

Writer’s Direct Contact
415.268.6024
[e-mail]

Via E-Mail ([e-mail])
Sara Jenkins
Quinn Emanuel
555 Twin Dolphin Drive, Fifth Floor
Redwood Shores, CA 94065
Re:

Apple v. Samsung, et al., Case No. 11-cv-1846-LHK (N.D. Cal.)
ATTORNEYS’ EYES ONLY—Contains information subject to protective order

Dear Sara:
I write regarding the replacement documents for APLNDC-Y0000051350-56,
APLNDC0001772330-40, and APLNDC-Y0000232396-430, about which I wrote you late
on March 13, 2012. As background, the first two documents identified above were identical
to one another and were both an earlier version of the third document, which covers a longer
period of time. This last document was produced on Thursday, March 8, 2012.

sf-3120392

Rachel Herrick Kassabian
March 15, 2012
Page Two

As noted previously, certain of the lines reflected third party information that is subject to
confidentiality provisions and notice requirements. We are in the process of contacting those
parties who have not received notice but we have not withheld information based on these
circumstances in this new document. If any party objects to disclosure, we will raise the
issue with you to discuss how to resolve it.
Finally, we are in the process of determining whether the information that we have gained
should result in an expansion in the production previously made of Apple’s license
agreements. We will write again when that review is complete.
Sincerely,
/s/ Mia Mazza
Mia Mazza
cc:

Peter Kolovos
S. Calvin Walden

sf-3120392