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 19

quinn emanuel

trial lawyers | washington, dc

1299 Pennsylvania Avenue NW, Suite 825, Washington, District of Columbia 20004-2400 | TEL: [phone] FAX: [phone]

WRITER'S DIRECT DIAL NO.
[phone]
WRITER'S INTERNET ADDRESS
[e-mail]

April 26, 2012

Jason Lo
Gibson Dunn & Crutcher LLP
333 South Grand Avenue
Los Angeles, California 90071-3197
[e-mail]
Re:

Apple Inc. v. Samsung Electronics Co., Ltd., et al., No. 12-630 (N.D. Cal.)

Dear Jason:
I write to follow up on your conversation with Matt Warren last week regarding Google’s
designation of witnesses in response to Apple’s subpoena. From that conversation, Mr. Warren
understood that you would be getting back to us with a proposal regarding the topics that Apple
wanted Google to provide a witness on during preliminary injunction discovery, but you never
did so. Instead, Apple filed a motion to compel, asserting that Google is refusing to provide
witnesses on Apple’s Rule 30(b)(6) topics. But, as you know, that is not correct. As Mr. Warren
explained to you during your prior conversation, each of the Google declarants being offered for
deposition would also be Rule 30(b)(6) designees on related topics.
Accordingly, consistent with that prior conversation, Google designates the following witnesses
for Topics 2, 7 and 8, subject to Google’s objections: Ken Wakasa, Jim Miller, Cary Clark,
Dianne Hackborn and Björn Bringert. Each witness will testify regarding the functionalities
discussed in his or her recently filed declaration. We believe these designations exhaust all
realms of testimony sought under Topics 2, 7 and 8. Please let me know as soon as possible if
you disagree.

quinn emanuel urquhart & sullivan, llp
LOS ANGELES |

865 South Figueroa Street, 10th Floor, Los Angeles, California 90017-2543 | TEL [phone] FAX [phone]
51 Madison Avenue, 22nd Floor, New York, New York 10010-1601 | TEL [phone] FAX [phone]
SAN FRANCISCO | 50 California Street, 22nd Floor, San Francisco, California 94111-4788 | TEL [phone] FAX [phone]
SILICON VALLEY | 555 Twin Dolphin Drive, 5th Floor, Redwood Shores, California 94065-2139 | TEL [phone] FAX [phone]
CHICAGO | 500 W. Madison Street, Suite 2450, Chicago, Illinois 60661-2510 | TEL [phone] FAX [phone]
LONDON | 16 Old Bailey, London EC4M 7EG, United Kingdom | TEL [phone] FAX [phone]
TOKYO | NBF Hibiya Building, 25F, 1-1-7, Uchisaiwai-cho, Chiyoda-ku, Tokyo 100-0011, Japan | TEL [phone] FAX [phone]
MANNHEIM | Mollstraße 42, 68165 Mannheim, Germany | TEL [phone] FAX [phone]
MOSCOW | Voentorg Building, 3rd Floor, 10 Vozdvizhenka Street, Moscow 125009, Russia | TEL [phone] FAX [phone]
NEW YORK |

Jason Lo
April 26, 2012
Page 2

We remind you again that Mr. Wakasa’s deposition will proceed tomorrow at 8:00 a.m. PDT, the
date on which you noticed a much broader deposition involving many more topics. Please
confirm that Apple will attend.
Very truly yours,
/s
Heather H. Martin