Apple Inc. v. Samsung Electronics Co., Ltd. et al
Filing
145
EXHIBITS re #144 Declaration in Support, Exhibits 15-25 to Declaration of Heather H. Martin filed byGoogle Inc.. (Attachments: #1 Exhibit 16, #2 Exhibit 17, #3 Exhibit 18, #4 Exhibit 19, #5 Exhibit 20, #6 Exhibit 21, #7 Exhibit 22, #8 Exhibit 23, #9 Exhibit 24, #10 Exhibit 25)(Related document(s) #144 ) (Candido, Amy) (Filed on 4/28/2012)
EXHIBIT 15
quinn emanuel
trial lawyers | washington, dc
1299 Pennsylvania Avenue NW, Suite 825, Washington, District of Columbia 20004-2400 | TEL: (202) 538-8000 FAX: (202) 538-8100
WRITER'S DIRECT DIAL NO.
(202) 538-8126
WRITER'S EMAIL ADDRESS
heathermartin@quinnemanuel.com
April 23, 2012
VIA ELECTRONIC MAIL
Jason Lo
Gibson Dunn & Crutcher LLP
333 South Grand Avenue
Los Angeles, California 90071-3197
jlo@gibsondunn.com
Re:
Apple Inc. v. Samsung Electronics Co., Ltd.. et al., No 12-630 (N.D. Cal.)
Dear Mr. Lo:
I write to finalize plans regarding the deposition of Ken Wakasa. As we discussed today, Mr.
Wakasa lives and works in Tokyo, Japan, as does the team responsible for Android Keyboard,
which Apple has accused of infringing the '172 patent. For unrelated reasons, however, Mr.
Wakasa is in Mountain View for the rest of this week. Next week is Golden Week in Japan
when, as I'm sure you know, the country essentially shuts down. For the two weeks after that,
business and family commitments prevent Mr. Wakasa from leaving Japan; again, as you know,
it would be illegal to depose him there.
For all these reasons, we offered Mr. Wakasa on Thursday, April 26. In response, you said
Apple could not be ready in time for this deposition, because it fell too soon after Samsung's
opposition brief. In light of your statements, Mr. Wakasa has rearranged his schedule so he can
be deposed a day later, Friday, April 27, 2012. The deposition will commence at 8:00 a.m. PDT,
and will have a hard stop at 4:00 p.m. PDT, so that Mr. Wakasa can make his flight back to
Japan in time for Golden Week.
quinn emanuel urquhart & sullivan, llp
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TOKYO | NBF Hibiya Building, 25F, 1-1-7, Uchisaiwai-cho, Chiyoda-ku, Tokyo 100-0011, Japan | TEL +81 3 5510 1711 FAX +81 3 5510 1712
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NEW YORK |
Jason Lo
April 23, 2012
Page 2
We expect Apple to depose Mr. Wakasa on Friday. As you know, Apple's notice of deposition
sought testimony that day on all four preliminary injunction patents. If you cannot actually take
a deposition on only one of those patents, then we question the urgency of your case.
Very truly yours,
/s/
Heather H. Martin
01980.51871/4719710.1
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