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

Filing 977

*** ATTACHMENTS 2 and 3 FILED IN ERROR WITH CONFIDENTIAL INFORMATION. DOCUMENT LOCKED. *** Administrative Motion to File Under Seal 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 Proposed Order Granting Administrative Motion to File Under Seal, #2 Declaration of Hankil Kang in Support of Administrative Motion to File Under Seal, #3 Samsung's Opposition to Apple's Rule 62(C) Motion, #4 Declaration of Paul Chapple in Support of Samsung's Opposition, #5 Declaration of Travis Merrill in Support of Samsung's Opposition, #6 Declaration of Carl Anderson in Support of Samsung's Opposition, #7 Exhibit 1 to the Declaration of Carl Anderson, #8 Exhibit 2 to the Declaration of Carl Anderson, #9 Exhibit 3 to the Declaration of Carl Anderson, #10 Exhibit 4 to the Declaration of Carl Anderson, #11 Proposed Order Denying Apple's Rule 62(C) Motion)(Maroulis, Victoria) (Filed on 5/25/2012) Modified on 5/29/2012 Attachment #2 Sealed pursuant to General Order No. 62 (dhm, COURT STAFF). Modified on 6/5/2012 (fff, COURT STAFF).

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP
Charles K. Verhoeven (Cal. Bar No. 170151)
2 [e-mail]
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50 California Street, 22nd Floor
3 San Francisco, California 94111
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Telephone: [phone]
4 Facsimile: [phone]
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5 Kevin P.B. Johnson (Cal. Bar No. 177129)
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[e-mail]
6 Victoria F. Maroulis (Cal. Bar No. 202603)
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[e-mail]
7 555 Twin Dolphin Drive 5th Floor
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Redwood Shores, California 94065
8 Telephone: [phone]
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Facsimile: [phone]
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Michael T. Zeller (Cal. Bar No. 196417)
10 [e-mail]
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865 S. Figueroa St., 10th Floor
11 Los Angeles, California 90017
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Telephone: [phone]
12 Facsimile: [phone]
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13 Attorneys for Samsung Electronics Co., Ltd.,
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Samsung Electronics America, Inc., and Samsung
14 Telecommunications America, LLC
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

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APPLE INC., a California corporation,
Plaintiff,

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CASE NO. 11-cv-01846-LHK (PSG)

vs.

SAMSUNG ELECTRONICS CO., LTD., a
21 Korean business entity; SAMSUNG
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ELECTRONICS AMERICA, INC., a
22 New York corporation; SAMSUNG
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TELECOMMUNICATIONS
23 AMERICA, LLC, a Delaware limited liability
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company,
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Defendants.
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DECLARATION OF CARL G.
ANDERSON IN SUPPORT OF
SAMSUNG’S OPPOSITION TO APPLE’S
MOTION PURSUANT TO RULE 62(C)
FOR ENTRY OF PRELIMINARY
INJUNCTION WITHOUT FURTHER
HEARING
Date: June 7, 2012
Time: 1:30 pm
Place: Courtroom 8, 4th Floor
Judge: Hon. Lucy H. Koh

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02198.51855/4776859.1

Case No. 11-cv-01846-LHK (PSG)
ANDERSON DECL. ISO SAMSUNG’S OPPOSITION TO APPLE’S RULE 26(C) MOTION FOR PRELIMINARY INJUNCTION

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I, Carl G. Anderson, declare as follows:

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I am an attorney admitted to practice in the State of California and I am an

3 associate of the law firm of Quinn Emanuel Urquhart & Sullivan, LLP (“Quinn Emanuel”).
4 Except as otherwise stated, I have personal firsthand knowledge of the matters set forth in this
5 Declaration, and if called as a witness I would testify competently to those matters.
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2.

Attached hereto as Exhibit 1 is a true and correct copy of Exhibit 30 of the March

7 22, 2012 Corrected Expert Report of Terry L. Musika.
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3.

Attached hereto as Exhibit 2 is a true and correct copy of the document referred to

9 in Exhibit 30 of the March 22, 2012 Corrected Expert Report of Terry L. Musika, n.1 (a filtered
10 tab from APLNDC-Z0000000003.XLS).
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4.

Attached hereto as Exhibit 3 is a true and correct copy of excerpts from the October

12 13, 2011 Hearing Transcript in this matter.
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5.

Attached hereto as Exhibit 4 is a true and correct copy of excepts from the April 20,

14 2012 Corrected Expert Report of Michael Wagner.
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I declare under penalty of perjury that the foregoing is true and correct.

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Executed this 25th day of May, 2012 in Philadelphia, Pennsylvania.

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/s/ Carl G. Anderson

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Carl G. Anderson

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02198.51855/4776859.1

Case No. 11-cv-01846-LHK (PSG)
-1ANDERSON DECL. ISO SAMSUNG’S OPPOSITION TO APPLE’S RULE 26(C) MOTION FOR PRELIMINARY INJUNCTION

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GENERAL ORDER ATTESTATION
I, Victoria Maroulis, am the ECF user whose ID and password are being used to file the

3 foregoing document. I hereby attest pursuant to General Order 45.X.B. that Carl G. Anderson has
4 concurred in the electronic filing of this document.
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Dated: May 25, 2012

/s/ Victoria Maroulis

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02198.51855/4776859.1

Case No. 11-cv-01846-LHK (PSG)
-2ANDERSON DECL. ISO SAMSUNG’S OPPOSITION TO APPLE’S RULE 26(C) MOTION FOR PRELIMINARY INJUNCTION