Apple Inc. v. Samsung Electronics Co., Ltd. et al
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)
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WRITER'S DIRECT DIAL NO.
WRITER'S EMAIL ADDRESS
April 23, 2012
VIA ELECTRONIC MAIL
Gibson Dunn & Crutcher LLP
333 South Grand Avenue
Los Angeles, California 90071-3197
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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April 23, 2012
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,
Heather H. Martin
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