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Case 1:13-cv-00919-JLH Document 599 Filed 08/14/23 Page 1 of 4 PagelD #: 60575
`Case 1:13-cv-00919-JLH Document 599 Filed 08/14/23 Page 1 of 4 PageID #: 60575
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`ARENDIS.A.R.L.,
`
`Plaintiff,
`
`;
`
`GOOGLELLC,
`
`Defendant.
`
`
`
`C.A. No. 13-919-JLH
`
`DECLARATION OF CHEOLWOO AHNIN SUPPORT OF NON-PARTIES
`SAMSUNG ELECTRONICS CO., LTD. AND SAMSUNG ELECTRONICS
`AMERICA,INC.’S UNOPPOSED MOTION TO SEAL
`PORTIONS OF THE TRIAL TRANSCRIPTS AND EXHIBITS
`
`I, Cheolwoo Ahn,hereby declare as follows:
`
`L,
`
`De
`
`3:
`
`Mynameis Cheolwoo Ahn.
`
`I am overthe age of 18, of sound mind, and competenttotestify.
`
`I am an employee of Samsung Electronics Co., Ltd. (“Samsung”) in Seoul, South
`
`Korea.
`
`I have worked at Samsung since 2001. My currenttitle is Principal Engineer.
`
`4.
`
`Myresponsibilities include the negotiation and agreementoflicensing agreements
`
`related to patents and otherintellectual property.
`
`I have been involved in several patent licensing
`
`negotiations and continue to be involvedin such activities on behalf of Samsung.
`
`3:
`
`I have reviewed the Settlement and Patent License Agreement(the “Samsung-
`
`Arendi Agreement”) between Samsung and Arendi S.A.R.L. (“Arendi’’).
`
`I understandthatit is
`
`marked as Exhibit PX-77 in the above-captionedcase.
`
`6.
`
`The Samsung-Arendi Agreementcontains highly confidential business
`
`information including financial terms and competitive materials, such that Samsung would be
`
`1
`
`

`

`Case 1:13-cv-00919-JLH Document 599 Filed 08/14/23 Page 2 of 4 PagelD #: 60576
`Case 1:13-cv-00919-JLH Document 599 Filed 08/14/23 Page 2 of 4 PageID #: 60576
`
`competitively disadvantaged from its disclosure. This informationis not available to the public,
`
`and Section 8.2 of the Samsung-Arendi Agreement expressly states that its contents are to
`
`remain confidential.
`
`i
`
`In the ordinary course of business, Samsung expendssignificant resources to
`
`maintain documents such as the Samsung-Arendi Agreementsecurely and confidentially on
`
`secure Computer systemsthat are not accessible to the public or third parties.
`
`8.
`
`Samsunghasaninterest in keeping the information in the Samsung-Arendi
`
`Agreementconfidential, at least because that information relates to the terms on whichitis
`
`willingto settle litigation, and it would be seriously harmedif the information were disclosed to
`
`the public. Disclosure of the information in the Samsung Agreement wouldirreversibly harm
`
`Samsung as it would impair Samsung’s ability to negotiate future favorable settlements and
`
`patent licenses and would makefuture litigants and/or licensors aware of the terms on which
`
`Samsungpreviouslyagreed to settlement and licensing to Samsung’s detriment.
`
`9.
`
`I declare under penalty of perjury underthe laws of the United States of America
`
`that the foregoingis true and correct to the best of my knowledge.
`
`é- LAS
`CHEOLWOO AHN
`Principal Engineer
`Samsung Electronics Co., Ltd.
`
`‘OD, 2023
`
`/ i
`
`Dated: August
`
`

`

`Case 1:13-cv-00919-JLH Document 599 Filed 08/14/23 Page 3 of 4 PageID #: 60577
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that on August 14, 2023, a copy of the foregoing
`
`document was served on the counsel listed below in the manner indicated:
`
`BY EMAIL
`
`SMITH, KATZENSTEIN & JENKINS LLP
`Neal C. Belgam (No. 2721)
`Daniel Taylor (No. 6934)
`1000 West Street, Suite 1501
`Wilmington, DE 19801
`(302) 652-8400
`nbelgam@skjlaw.com
`dtaylor@skjlaw.com
`
`SUSMAN GODFREY LLP
`Seth Ard
`Max Straus
`Beatrice Franklin
`1301 Avenue of the Americas, 32nd Floor
`New York, New York 10019
`Tel: (212) 336-8330
`sard@susmangodfrey.com
`mstraus@susmangodfrey.com
`bfranklin@susmangodfrey.com
`
`John Lahad
`1000 Louisiana Street, Suite 5100
`Houston, TX 77002-5096
`jlahad@susmangodfrey.com
`
`Kalpana Srinivasan
`1900 Avenue of the Stars, Suite 1400
`Los Angeles, CA 90067
`ksrinivasan@susmangodfrey.com
`
`Kemper Diehl
`401 Union Street, Suite 3000
`Seattle, WA 98101-3000
`kdiehl@susmangodfrey.com
`
`Attorneys for Plaintiff Arendi S.A.R.L.
`
`
`
`
`David E. Moore (#3983)
`Bindu A. Palapura (#5370)
`Andrew L. Brown (#6766)
`POTTER ANDERSON & CORROON LLP
`Hercules Plaza, 6th Floor
`1313 N. Market Street
`Wilmington, DE 19801
`Tel: (302) 984-6000
`dmoore@potteranderson.com
`bpalapura@potteranderson.com
`abrown@potteranderson.com
`
`Robert W. Unikel
`John Cotiguala
`PAUL HASTINGS LLP
`71 South Wacker Drive, Suite 4500
`Chicago, IL 60606
`robertunikel@paulhastings.com
`johncotiguala@paulhastings.com
`
`Robert R. Laurenzi
`Chad J. Peterman
`PAUL HASTINGS LLP
`200 Park Avenue
`New York, NY 10166
`robertlaurenzi@paulhastings.com
`chadpeterman@paulhastings.com
`
`Ginger D. Anders
`MUNGER, TOLLES & OLSON LLP
`601 Massachusetts Avenue NW, Suite 500E
`Washington, D.C. 20001
`Ginger.Anders@mto.com
`
`Vincent Y. Ling
`MUNGER, TOLLES & OLSON LLP
`350 S. Grand Avenue, 50th Floor
`Los Angeles, CA 90071
`
`

`

`Case 1:13-cv-00919-JLH Document 599 Filed 08/14/23 Page 4 of 4 PageID #: 60578
`
`
`
`
`
`
`
`
`
`
`
`
`
`vincent.ling@mto.com
`
`Attorneys for Defendant Google LLC
`
`/s/Adam W. Poff
`YOUNG CONAWAY STARGATT &
`TAYLOR, LLP
`Adam W. Poff (No. 3990)
`Samantha G. Wilson (No. 5816)
`1000 North King Street
`Wilmington, DE 19801
`(302) 571-6600
`apoff@ycst.com
`swilson@ycst.com
`
`
`Attorneys for Non-Parties Samsung
`Electronics Co., Ltd. and Samsung Electronics
`America, Inc.
`
`2
`
`
`
`
`
`
`
`
`
`

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