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

Filing 991

Administrative Motion to File Under Seal Documents Re Apples Opposition To Samsungs Motion To Exclude Opinions Of Certain Of Apple Experts filed by Apple Inc.. (Attachments: #1 Declaration Of Cyndi Wheeler In Support Of Apples Administrative Motion To File Under Seal Documents Re Apples Opposition to Exclude Apple Experts Opinions, #2 [Proposed] Order Granting Apples Administrative Motion To File Under Seal, #3 Apples Opposition To Samsungs Motion To Exclude Opinions Of Certain Of Apples Experts, #4 Declaration Of Mia Mazza In Support Of Apples Opposition To Samsungs Motion To Exclude Opinions Of Certain Of Apples Experts, #5 Exhibit Mazza Decl. Ex. D, #6 Exhibit Mazza Decl. Ex. F, #7 Exhibit Mazza Decl. Ex. G, #8 Exhibit Mazza Decl. Ex. J, #9 Exhibit Mazza Decl. Ex. K, #10 Exhibit Mazza Decl. Ex. L, #11 Exhibit Mazza Decl. Ex. R, #12 Exhibit Mazza Decl. Ex. S, #13 Exhibit Mazza Decl. Ex. T, #14 Exhibit Mazza Decl. Ex. U, #15 Exhibit Mazza Decl. Ex. V, #16 Exhibit Hauser Decl. Ex. B, #17 Exhibit Hauser Decl. Ex. C, #18 Exhibit Hauser Decl. Ex. D, #19 Exhibit Hauser Decl. Ex. E, #20 Exhibit Musika Decl. Ex. S, #21 Exhibit Musika Decl. Ex. T, #22 Exhibit Musika Decl. Ex. U, #23 [Proposed] Order Denying Samsungs Motion To Exclude Opinions Of Apples Experts)(Jacobs, Michael) (Filed on 5/31/2012) Modified on 6/3/2012 attachment #1 Sealed pursuant to General Order No. 62 (dhm, COURT STAFF).

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HAROLD J. MCELHINNY (CA SBN 66781)
[e-mail]
MICHAEL A. JACOBS (CA SBN 111664)
[e-mail]
JENNIFER LEE TAYLOR (CA SBN 161368)
[e-mail]
ALISON M. TUCHER (CA SBN 171363)
[e-mail]
RICHARD S.J. HUNG (CA SBN 197425)
[e-mail]
JASON R. BARTLETT (CA SBN 214530)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: [phone]

WILLIAM F. LEE
[e-mail]
WILMER CUTLER PICKERING
HALE AND DORR LLP
60 State Street
Boston, MA 02109
Telephone: [phone]
Facsimile: [phone]
MARK D. SELWYN (SBN 244180)
[e-mail]
WILMER CUTLER PICKERING
HALE AND DORR LLP
950 Page Mill Road
Palo Alto, California 94304
Telephone: [phone]
Facsimile: [phone]

Attorneys for Plaintiff and
Counterclaim-Defendant APPLE INC

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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APPLE INC., a California corporation,

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Plaintiff,
v.
SAMSUNG ELECTRONICS CO., LTD., a
Korean business entity; SAMSUNG
ELECTRONICS AMERICA, INC., a New York
corporation; SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC, a
Delaware limited liability company,

Case No. 11-cv-01846-LHK (PSG)
DECLARATION OF MIA MAZZA IN
SUPPORT OF APPLE’S OPPOSITION
TO SAMSUNG’S MOTION TO
EXCLUDE OPINIONS OF CERTAIN
OF APPLE’S EXPERTS

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Defendants.
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MAZZA DECL. ISO OPP. TO SAMSUNG’S MOTION TO EXCLUDE OPINIONS OF CERTAIN OF APPLE’S EXPERTS
CASE NO. 11-cv-01846-LHK (PSG)
sf-3150824

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I, MIA MAZZA, declare as follows:

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I am a partner in the law firm of Morrison & Foerster LLP, counsel for Apple Inc.

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(“Apple”) in this action. I am licensed to practice law in the State of California and admitted to

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practice before this Court. I submit this declaration in support of Apple’s Opposition to

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Samsung’s Motion To Exclude Opinions of Certain of Apple’s Expert Witnesses. Unless

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otherwise indicated, I have personal knowledge of the matters stated herein or understand them to

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be true from members of my litigation team. If called as a witness, I would testify to the facts set

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forth below.

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Terry Musika
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Attached hereto as Exhibit A is a true and correct copy of excerpts of the

transcript of the May 14, 2012 deposition of Terry Musika.
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Attached hereto as Exhibit B is a true and correct copy of excerpts of the

transcript of the May 12, 2012 deposition of Michael J. Wagner.
3.

Attached hereto as Exhibit C is a true and correct copy of Apple’s Responses to

Samsung Interrogatory No. 7.

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Henry A. Urbach

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4.

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Attached hereto as Exhibit D is a true and correct copy of excerpts of the

transcript of the April 19, 2012 deposition of Henry A. Urbach.

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Susan Kare

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5.

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Attached hereto as Exhibit E is a true and correct copy of excerpts of the

transcript of the April 27, 2012 deposition of Susan Kare.
6.

Attached hereto as Exhibit F is a true and correct copy of excerpts of the transcript

of the April 27, 2012 deposition of Russell Winer.

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Michael Walker

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7.

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Attached hereto as Exhibit G is a true and correct copy of the ETSI IPR Policy,

produced by Samsung as Bates No. S-ITC-003356259 through S-ITC-003356266.
8.

Attached hereto as Exhibit H is a true and correct copy of excerpts of the

transcript of the March 6, 2012 testimony of Samsung executive Jun Won Lee.
MAZZA DECL. ISO OPP. TO SAMSUNG’S MOTION TO EXCLUDE OPINIONS OF CERTAIN OF APPLE’S EXPERTS
CASE NO. 11-cv-01846-LHK (PSG)
sf-3150824

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Richard L. Donaldson

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Attached hereto as Exhibit I is a true and correct copy of excerpts of the transcript

of the May 2, 2012 testimony of Apple expert Richard L. Donaldson.
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Attached hereto as Exhibit J is a true and correct copy of excerpts of the Rebuttal

Report of Erik Stasik, dated April 17, 2012.

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John Hauser

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Attached hereto as Exhibit K is a true and correct copy of excerpts of the

transcript of the April 27, 2012 deposition of John Hauser.
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Attached hereto as Exhibit L is a true and correct copy of excerpts of the

transcript of the April 24, 2012 deposition of Ramamirtham Sukumar.
13.

Attached hereto as Exhibit M is a true and correct copy of the Expert Report of

Karan Singh, PhD dated March 22, 2012.
14.

Attached hereto as Exhibit N is a true and correct copy of the Expert Report of

Ravin Balakrishnan, PhD dated March 22, 2012.
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Attached hereto as Exhibit O is a true and correct copy of the Rebuttal Expert

Report of Ravin Balakrishnan, PhD dated April 16, 2012.
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Attached hereto as Exhibit P is a true and correct copy of the Expert Report of

Michel Mahabariz, PhD dated March 22, 2012.
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Attached hereto as Exhibit Q is a true and correct copy of the Expert Report of

Terry Musika, CPA dated March 22, 2012.
18.

Attached hereto as Exhibit R is a true and correct copy of the table titled

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“Summary of Expert Report and Patent Language Supporting Dr. Hauser’s Descriptions of

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Patented Features.”

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19.

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Attached hereto as Exhibit S is a true and correct copy of excerpts of U.S. Patent

No. 7,864,163.
20.

Attached hereto as Exhibit T is a true and correct copy of excerpts of U.S. Patent

No. 7,663,607.

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MAZZA DECL. ISO OPP. TO SAMSUNG’S MOTION TO EXCLUDE OPINIONS OF CERTAIN OF APPLE’S EXPERTS
CASE NO. 11-cv-01846-LHK (PSG)
sf-3150824

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21.

Attached hereto as Exhibit U is a true and correct copy of excerpts of U.S. Patent

No. 7,844,915.
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Attached hereto as Exhibit V is a true and correct copy of excerpts of U.S. Patent

No. 7,469,381.
I declare under penalty of perjury that the foregoing is true and correct. Executed this 31st
day of May, 2012, at San Francisco, California.
/s/ Mia Mazza
Mia Mazza

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MAZZA DECL. ISO OPP. TO SAMSUNG’S MOTION TO EXCLUDE OPINIONS OF CERTAIN OF APPLE’S EXPERTS
CASE NO. 11-cv-01846-LHK (PSG)
sf-3150824

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ATTESTATION OF E-FILED SIGNATURE
I, MICHAEL A. JACOBS, am the ECF User whose ID and password are being used to

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file this Declaration. In compliance with General Order 45, X.B., I hereby attest that Mia Mazza

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has concurred in this filing.

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Dated: May 31, 2012

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ECF ATTESTATION
CASE NO. 11-cv-01846-LHK (PSG)
sf-3150824

/s/ Michael A. Jacobs
Michael A. Jacobs