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 22

quinn emanuel

trial lawyers | washington, dc

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WRITER'S DIRECT DIAL NO.
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April 24, 2012
VIA ELECTRONIC MAIL
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 in response to your emails of earlier today, as well as our brief telephone conference.
During the latter, you again declined to narrow Apple's discovery requests in any way.
In one of your emails, you stated that I failed to quote portions of Judge Koh’s Order Setting
Briefing and Hearing Schedule for Preliminary Injunction Motion dated February 22, 2012, and
that those unquoted portions somehow limited the Order’s applicability to disputes between
parties. As we discussed during our call, I see no language in the Order suggesting such a
limitation; please direct me to it. Separately, you stated on the phone that Judge Koh did not
wish to burden third-parties with the in-person meet-and-confer requirement. Speaking for nonparty Google, I can state with assurance that we believe we do benefit from this requirement, and
that Apple's unauthorized motion will be a far greater burden on us than any in-person meet-andconfer discussion, which would likely narrow or eliminate the issues between us. In any event, I
again see no language in the Order to that effect. I would appreciate it if you could point me to
the basis for your belief.
quinn emanuel urquhart & sullivan, llp
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Jason Lo
April 24, 2012
Page 2

Finally, in another of your emails you indicated that our schedule for briefing cannot suffice
because it would inconvenience “our folks working in the East Coast on this issue.” This is not
an acceptable argument considering Apple chose to bring suit in the Northern District of
California. Our proposal is reasonable for lawyers in the Northern District of California – indeed,
you do not argue otherwise. If you do not accept our final compromise, we have no agreement.
If you move independently for shortened briefing, we expect you will provide our proposal as
well as yours to the Court.
Very truly yours,
/s
Heather H. Martin

01980.51871/4721502.1

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