DECL. OF E. TAKASHIMA IN SUPPORT OF PLAINTIFF FEDERAL TRADE 

COMMISSION’S MOTION TO FILE UNDER SEAL (ECF 789) 

CASE NO. 5:17-CV-00220-LHK-NMC 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

BOIES SCHILLER FLEXNER LLP 

William A. Isaacson (Pro Hac Vice App. to be filed) 

DC Bar No. 414788, wisaacson@bsfllp.com 

Karen L. Dunn (Pro Hac Vice App. to be filed) 

DC Bar No. 1002520, kdunn@bsfllp.com 

Amy J. Mauser (Pro Hac Vice App. to be filed) 

DC Bar No. 424065, amauser@bsfllp.com 

1401 New York Avenue, N.W. 

Washington, DC 20005 

Telephone: (202) 237-2727 

Facsimile: (202) 237-6131 

BOIES SCHILLER FLEXNER LLP 

Edward H. Takashima, SBN 270945 

etakashima@bsfllp.com 

401 Wilshire Blvd, Suite 850 

Santa Monica, CA 90401 

Telephone: (310) 752-2408 

Facsimile: (310) 752-2490 

Attorneys for Non-Party APPLE INC. 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN JOSE DIVISION 

FEDERAL TRADE COMMISSION, 

Plaintiff, 

v. 

QUALCOMM INCORPORATED, 

a Delaware Corporation, 

Defendant. 

Case No. 5:17-CV-00220-LHK-NMC

DECLARATION OF EDWARD H. 

TAKASHIMA ON BEHALF OF NONPARTY APPLE INC. IN SUPPORT OF 

PLAINTIFF FEDERAL TRADE 

COMMISSION’S ADMINISTRATIVE 

MOTION TO FILE UNDER SEAL 

PORTIONS OF ITS MOTION TO 

EXCLUDE EXPERT TESTIMONY OF 

DR. EDWARD A. SNYDER AND 

ACCOMPANYING EXHIBITS (ECF 789) 

Courtroom: 8, 4th Floor 

Judge: Hon. Lucy H. Koh 

Case 5:17-cv-00220-LHK Document 845 Filed 09/12/18 Page 1 of 11
1 

DECL. OF E. TAKASHIMA IN SUPPORT OF PLAINTIFF FEDERAL TRADE 

COMMISSION’S MOTION TO FILE UNDER SEAL (ECF 789) 

CASE NO. 5:17-CV-00220-LHK-NMC 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

I, Edward H. Takashima, declare as follows: 

1. I am a partner at the law firm of Boies Schiller Flexner LLP, representing NonParty Apple Inc. (“Apple”). I am an active member in good standing with the State Bar of 

California. I have personal knowledge of the matters set forth in this declaration, or am informed 

and believe them to be true, and if called upon as a witness could and would testify competently 

to the matters herein. 

2. I respectfully submit this declaration in support of Plaintiff Federal Trade 

Commission’s (“FTC”) Administrative Motion to File Under Seal Portions of Its Motion to 

Exclude Expert Testimony of Dr. Edward A. Snyder and Accompanying Exhibits (ECF 789), 

pursuant to Civil Local Rules 7-11 and 79-5. I have reviewed the portions of the FTC’s Motion 

to File Under Seal (ECF 789) that the FTC has indicated contain material designated confidential 

by Apple under a Protective Order. 

3. Exhibit 1 to the Declaration of Jennifer Milici in Support of the FTC’s Motion to 

Exclude Expert Testimony of Dr. Edward A. Snyder is the Expert Report of Edward A. Snyder 

(“Snyder Report”). Portions of the Snyder Report contain confidential information, as described 

below. I am providing Qualcomm’s and the FTC’s counsel with a copy of the report that 

highlights those specific portions of the report that Apple deems confidential. Apple treats this 

information as confidential, and has designated it as at least Confidential. If this information 

were to be released to the public, Apple’s competitors and potential business partners would gain 

insight into Apple’s internal business operations, potentially compromising Apple’s competitive 

standing. 

Paragraph / Footnote Basis to Seal 

¶ 37a Contains confidential information pertaining to internal Apple 

analysis and strategy regarding suppliers, and confidential information 

regarding Apple’s relationships and communications with potential 

suppliers. 

¶ 37b Contains confidential information pertaining to internal Apple 

analysis and strategy regarding suppliers, and confidential information 

regarding Apple’s relationships with potential suppliers. 

Case 5:17-cv-00220-LHK Document 845 Filed 09/12/18 Page 2 of 11
2 

DECL. OF E. TAKASHIMA IN SUPPORT OF PLAINTIFF FEDERAL TRADE 

COMMISSION’S MOTION TO FILE UNDER SEAL (ECF 789) 

CASE NO. 5:17-CV-00220-LHK-NMC 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

¶ 89 Contains confidential information pertaining to internal Apple 

strategy and potential future business plans. 

FN 173 Contains confidential information pertaining to internal Apple 

strategy and potential future business plans. 

FN 174 Contains confidential information pertaining to internal Apple 

strategy and potential future business plans. 

FN 177 Contains confidential information pertaining to internal Apple 

strategy and analysis regarding potential future business plans. 

¶ 96 Contains confidential information pertaining to internal Apple 

strategy concerning product development and procurement decisions. 

FN 188 Contains confidential information regarding Apple product 

development and strategy. 

FN 189 Contains confidential information regarding Apple product 

development and strategy. 

FN 190 Contains confidential information regarding Apple product 

development. 

FN 191 Contains confidential information regarding Apple product 

development. 

FN 192 Contains confidential information concerning Apple procurement 

decision making. 

FN 194 Contains confidential information regarding Apple internal strategy 

and analysis, product development, and procurement decision making. 

¶ 97 Contains confidential information regarding Apple internal strategy 

regarding procurement decision making. 

¶ 102 Contains confidential information regarding Apple product 

development. 

FN 214 Contains confidential information regarding Apple product 

development. 

¶ 103 Contains confidential information regarding Apple product 

development. 

FN 217 Contains confidential information regarding Apple product 

development and procurement decision making. 

FN 218 Contains confidential information regarding Apple product 

development.

FN 219 Contains confidential information regarding Apple product 

development.

¶ 106 Contains confidential information about Apple procurement and 

supplier relationships. 

FN 222 Contains confidential information about Apple product development 

and procurement decision making. 

¶ 108 Contains confidential information about Apple product development 

and procurement decision making. 

FN 226 Contains confidential information about Apple product development 

and procurement decision making. 

¶ 112 Contains confidential information about Apple procurement strategy. 

FN 234 Contains confidential information about Apple procurement strategy. 

FN 235 Contains confidential information about Apple procurement strategy. 

Case 5:17-cv-00220-LHK Document 845 Filed 09/12/18 Page 3 of 11
3 

DECL. OF E. TAKASHIMA IN SUPPORT OF PLAINTIFF FEDERAL TRADE 

COMMISSION’S MOTION TO FILE UNDER SEAL (ECF 789) 

CASE NO. 5:17-CV-00220-LHK-NMC 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

FN 242 Contains confidential information about Apple procurement strategy. 

FN 245 Contains confidential information about Apple procurement strategy. 

FN 246 Contains confidential information about Apple procurement strategy. 

FN 247 Contains confidential information about Apple product development 

and procurement decision making. 

FN 252 Contains confidential information about Apple product development 

strategy. 

FN 257 Contains confidential information about Apple product development. 

¶ 133 Contains confidential information reflecting Apple procurement 

decision making and supplier relationships. 

FN 274 Contains confidential information reflecting Apple product 

development. 

¶ 134 Contains confidential information reflecting Apple procurement 

decision making. 

¶ 135 Contains confidential information regarding Apple procurement 

decision making. 

FN 280 Contains confidential information regarding Apple’s procurement 

strategy. 

FN 281 Contains confidential information regarding Apple’s procurement 

decision making. 

¶ 137 Contains confidential information regarding Apple product 

development strategy. 

FN 292 Contains confidential information regarding Apple procurement 

strategy. 

¶ 142 Contains confidential information regarding Apple procurement 

strategy. 

¶ 171 Contains confidential information regarding Apple communications 

with Qualcomm concerning product development. 

FN 346 Contains confidential information regarding Apple communications 

with Qualcomm concerning product development. 

FN 353 Contains confidential information regarding Apple procurement 

process and decision making. 

FN 354 Contains confidential information regarding Apple procurement 

process and decision making. 

¶ 174 Contains confidential information regarding Apple’s procurement 

process and decision making. 

FN 355 Contains confidential information regarding Apple product 

development and procurement strategy. 

FN 356 Contains confidential information regarding Apple’s procurement 

strategy. 

¶ 181 Contains confidential information regarding Apple procurement 

strategy and product design. 

¶ 207 Contains confidential information regarding Apple product 

development and procurement activities. 

¶ 212 Contains confidential information regarding Apple product 

development and procurement activities. 

Case 5:17-cv-00220-LHK Document 845 Filed 09/12/18 Page 4 of 11
4 

DECL. OF E. TAKASHIMA IN SUPPORT OF PLAINTIFF FEDERAL TRADE 

COMMISSION’S MOTION TO FILE UNDER SEAL (ECF 789) 

CASE NO. 5:17-CV-00220-LHK-NMC 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

¶ 235 Contains confidential information concerning Apple’s product 

development and procurement decision making. 

¶ 244 Contains confidential information regarding Apple’s internal 

assessment of industry issues and procurement decision making. 

FN 504 Contains confidential information regarding Apple’s internal 

assessment of industry issues. 

FN 505 Contains confidential information regarding Apple’s internal 

assessment of industry issues and procurement decision making. 

FN 518 Contains confidential information regarding Apple communications 

with potential suppliers regarding product development. 

FN 527 Contains confidential information about Apple internal strategy on 

product development. 

¶ 262 Contains confidential information regarding Apple’s procurement 

decision making. 

FN 552 Contains confidential information about Apple’s procurement 

decision making. 

FN 553 Contains confidential information about Apple’s procurement 

decision making. 

FN 561 Contains confidential information about Apple employee analysis on 

changes in the wireless technology industry. 

¶ 271(iii) Contains confidential information concerning Apple internal strategy 

on product development and procurement decision making. 

FN 589 Contains confidential information concerning Apple internal strategy 

on product development and procurement decision making. 

¶ 274 Contains confidential information regarding Apple’s business 

dealings with Qualcomm. 

¶ 286 Contains confidential information regarding Apple’s communications 

and business dealings with a supplier. 

FN 629 Contains confidential information regarding Apple’s communications 

and business dealings with a supplier. 

FN 630 Contains confidential information regarding Apple’s procurement 

strategy. 

¶ 290 Contains confidential information regarding Apple’s internal strategy 

and analysis of baseband suppliers. 

FN 646 Contains confidential information regarding Apple’s communications 

with a supplier. 

FN 647 Contains confidential information about Apple procurement decision 

making. 

FN 648 Contains confidential information about Apple procurement decision 

making. 

FN 649 Contains confidential information about Apple procurement decision 

making. 

FN 651 Contains confidential information about Apple procurement decision 

making. 

¶ 291 Contains confidential information concerning Apple consideration of 

a baseband supplier. 

FN 655 Contains confidential information related to Apple confidential 

procurement decision making. 

Case 5:17-cv-00220-LHK Document 845 Filed 09/12/18 Page 5 of 11
5 

DECL. OF E. TAKASHIMA IN SUPPORT OF PLAINTIFF FEDERAL TRADE 

COMMISSION’S MOTION TO FILE UNDER SEAL (ECF 789) 

CASE NO. 5:17-CV-00220-LHK-NMC 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

¶ 292 Contains confidential information concerning Apple procurement 

decision making. 

FN 660 Contains confidential information related to Apple consideration of a 

baseband supplier. 

FN 661 Contains confidential information related to Apple analysis of a 

baseband supplier. 

¶ 296 Contains confidential information concerning Apple product 

development and business dealings with a chipset supplier. 

FN 677 Contains confidential information concerning Apple’s views on a 

particular chipset supplier 

¶ 297 Contains confidential information related to Apple procurement 

decision making. 

FN 680 Contains confidential information related to Apple procurement 

decision making. 

FN 682 Contains confidential information related to Apple procurement 

decision making. 

FN 683 Contains confidential information related to Apple procurement 

decision making 

¶ 304 Contains confidential information concerning Apple’s business 

dealings with a supplier. 

FN 716 Contains confidential information concerning Apple procurement 

decision making. 

FN 717 Contains confidential information related to Apple’s consideration of 

baseband suppliers. 

FN 720 Contains confidential information concerning Apple’s 

communications and business dealings with a supplier. 

FN 721 Contains confidential information related to Apple procurement 

decision making. 

¶ 305 Contains confidential information related to Apple analysis and 

consideration of a baseband supplier. 

FN 724 Contains confidential information related to Apple procurement 

decision making. 

FN 725 Contains confidential information related to Apple product 

development. 

FN 726 Contains confidential information related to Apple product 

development. 

¶ 309 Contains confidential information concerning Apple’s business 

dealings with a supplier. 

FN 738 Contains confidential information about Apple’s procurement 

strategy. 

¶ 310 Contains confidential information concerning Apple potential future 

business plans. 

FN 744 Contains confidential information concerning Apple’s procurement 

decision making. 

FN 745 Contains confidential information concerning Apple procurement 

decision making and strategy. 

FN 788 Contains confidential information concerning Apple communications 

with a supplier. 

Case 5:17-cv-00220-LHK Document 845 Filed 09/12/18 Page 6 of 11
6 

DECL. OF E. TAKASHIMA IN SUPPORT OF PLAINTIFF FEDERAL TRADE 

COMMISSION’S MOTION TO FILE UNDER SEAL (ECF 789) 

CASE NO. 5:17-CV-00220-LHK-NMC 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

FN 789 Contains confidential information concerning Apple communications 

with a supplier. 

¶ 324 Contains confidential information related to Apple’s internal analysis 

regarding industry developments. 

FN 796 Contains confidential Apple internal analysis regarding industry 

developments. 

¶ 328 Contains confidential information regarding Apple communications 

with a cellular carrier. 

FN 811 Contains confidential information concerning Apple communications 

with a cellular carrier. 

FN 817 Contains confidential information concerning Apple’s potential future 

business plans and baseband procurement strategy. 

¶ 330 Contains confidential information relating to Apple’s procurement 

decision making. 

FN 819 Contains confidential information relating to Apple’s procurement 

decision making. 

FN 820 Contains confidential information relating to Apple’s procurement 

decision making. 

FN 822 Contains confidential information regarding Apple procurement 

strategy. 

¶ 333 Contains confidential information concerning Apple product 

development and communications and business dealings with a 

supplier. 

FN 834 Contains confidential information concerning Apple communication 

with a supplier. 

FN 839 Contains confidential information on Apple product development 

strategy.

¶ 334 Contains confidential information related to Apple procurement 

strategy. 

FN 842 Contains confidential information regarding Apple procurement 

strategy. 

FN 890 Contains confidential information concerning Apple evaluation of a 

potential supplier. 

¶ 345 Contains confidential information regarding Apple’s business 

dealings with a supplier. 

FN 892 Contains confidential information about Apple communications and 

business dealings with a supplier. 

¶ 349 Contains confidential information regarding Apple’s consideration of 

a baseband chipset supplier. 

FN 913 Contains confidential information regarding Apple consideration of a 

baseband chipset supplier. 

¶ 353 Contains confidential information regarding Apple consideration of a 

baseband chipset supplier. 

FN 930 Contains confidential information concerning Apple’s sourcing of 

chipsets. 

¶ 354 Contains confidential information concerning Apple communications 

with a baseband chipset supplier. 

Case 5:17-cv-00220-LHK Document 845 Filed 09/12/18 Page 7 of 11
7 

DECL. OF E. TAKASHIMA IN SUPPORT OF PLAINTIFF FEDERAL TRADE 

COMMISSION’S MOTION TO FILE UNDER SEAL (ECF 789) 

CASE NO. 5:17-CV-00220-LHK-NMC 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

FN 934 Contains confidential information regarding Apple dealings with a 

chipset supplier. 

¶ 359 Contains confidential information regarding Apple consideration of a 

chipset supplier. 

FN 955 Contains confidential information about Apple internal consideration 

and analysis of a potential chipset supplier. 

FN 1041 Contains confidential information concerning Apple analysis of 

potential chipset supplier. 

¶ 383 Contains confidential information concerning Apple’s evaluation and 

analysis of a potential chipset supplier. 

FN 1059 Contains confidential information concerning Apple’s consideration 

of potential chipset suppliers. 

FN 1060 Contains confidential information regarding Apple’s procurement 

decision making. 

¶ 388 Contains confidential information concerning Apple’s dealings with a 

potential chipset supplier. 

FN 1080 Contains confidential information concerning Apple’s consideration 

of potential chipset suppliers. 

FN 1081 Contains confidential information regarding a potential Apple chipset 

supplier. 

FN 1082 Contains confidential information regarding Apple dealings with, and 

analysis regarding, a potential chipset supplier. 

FN 1083 Contains confidential information regarding Apple dealings with, and 

analysis regarding, a potential chipset supplier. 

¶ 395 Contains confidential information concerning Apple’s procurement 

decision making. 

FN 1105 Contains confidential information concerning Apple’s procurement 

decision making. 

¶ 403 Contains confidential information concerning Apple’s procurement 

decision making. 

FN 1139 Contains confidential information concerning Apple’s consideration 

of potential chipset suppliers. 

¶ 406 Contains confidential information concerning Apple consideration of 

a potential chipset supplier. 

FN 1150 Contains confidential information concerning Apple’s evaluation of a 

potential chipset supplier. 

FN 1151 Contains confidential information concerning Apple’s evaluation of a 

potential chipset supplier. 

FN 1152 Contains confidential information concerning Apple’s evaluation of a 

potential chipset supplier. 

¶ 407 Contains confidential information concerning Apple evaluation of a 

potential chipset supplier. 

FN 1155 Contains confidential information concerning Apple’s evaluation of a 

potential chipset supplier. 

¶ 411 Contains confidential information concerning Apple’s evaluation of a 

potential chipset supplier. 

FN 1169 Contains confidential information concerning Apple’s evaluation of a 

potential chipset supplier. 

Case 5:17-cv-00220-LHK Document 845 Filed 09/12/18 Page 8 of 11
8 

DECL. OF E. TAKASHIMA IN SUPPORT OF PLAINTIFF FEDERAL TRADE 

COMMISSION’S MOTION TO FILE UNDER SEAL (ECF 789) 

CASE NO. 5:17-CV-00220-LHK-NMC 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

¶ 412 Contains confidential information concerning Apple’s procurement 

decision making. 

FN 1176 Contains confidential information concerning Apple’s consideration 

of potential chipset suppliers. 

FN 1177 Contains confidential information concerning Apple’s consideration 

of potential chipset suppliers. 

FN 1178 Contains confidential information concerning Apple’s assessment of a 

potential chipset supplier. 

¶ 444 Contains confidential information concerning Apple’s evaluation of a 

potential chipset supplier. 

¶ 449 Contains confidential information concerning Apple’s procurement 

decision making. 

FN 1345 Contains confidential information concerning Apple’s procurement 

decision making. 

¶ 451 Contains confidential information concerning Apple’s procurement 

decision making. 

FN 1357 Contains confidential information concerning Apple’s consideration 

and evaluation of potential chipset suppliers. 

FN 1538 Contains confidential information concerning Apple’s consideration 

of potential chipset suppliers. 

¶ 471d Contains confidential information concerning Apple’s views on a 

particular chipset supplier. 

¶ 472e Contains confidential information concerning Apple’s views on a 

particular chipset supplier and the two companies’ business dealings. 

FN 1439 Contains confidential information concerning Apple analysis of a 

potential chipset supplier. 

¶ 509 Contains confidential information concerning Apple’s procurement 

decision making. 

FN 1454 Contains confidential information concerning Apple’s consideration 

and evaluation of a potential chipset supplier. 

FN 1455 Contains confidential information concerning Apple’s evaluation of 

potential chipset suppliers. 

FN 1456 Contains confidential information concerning Apple analysis of a 

chipset supplier. 

¶ 511 Contains confidential information concerning Apple’s evaluation of a 

chipset supplier. 

FN 1461 Contains confidential information concerning Apple’s evaluation of a 

chipset supplier. 

FN 1463 Contains confidential information concerning Apple’s consideration 

and evaluation of a potential chipset supplier. 

¶ 517 Contains confidential information concerning Apple’s consideration 

of a potential chipset supplier. 

FN 1479 Contains confidential information concerning procurement decision 

making. 

¶ 518 Contains confidential information concerning Apple’s procurement 

decision making. 

FN 1482 Contains confidential information concerning Apple’s procurement 

decision making. 

Case 5:17-cv-00220-LHK Document 845 Filed 09/12/18 Page 9 of 11
9 

DECL. OF E. TAKASHIMA IN SUPPORT OF PLAINTIFF FEDERAL TRADE 

COMMISSION’S MOTION TO FILE UNDER SEAL (ECF 789) 

CASE NO. 5:17-CV-00220-LHK-NMC 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

FN 1483 Contains confidential information regarding analysis of a potential 

chipset supplier. 

¶ 527a Contains confidential information concerning Apple’s dealings with a 

potential chipset supplier. 

¶ 527e Contains confidential information concerning Apple’s dealings with a 

chipset supplier. 

¶ 540 Contains confidential information concerning Apple’s agreements 

with Qualcomm. 

¶ 541 Contains confidential information concerning Apple’s business 

dealings with a supplier and Qualcomm and evaluation of potential 

chipset suppliers. 

FN 1536 Contains confidential information concerning Apple’s consideration 

and evaluation of potential chipset suppliers. 

FN 1537 Contains confidential information concerning Apple’s consideration 

and evaluation of a potential chipset supplier. 

FN 1538 Contains confidential information concerning Apple’s consideration 

and evaluation of potential chipset suppliers. 

¶ 542 Contains confidential information concerning Apple’s evaluation and 

analysis of a potential chipset supplier as well as Apple’s agreements 

with Qualcomm. 

FN 1539 Contains confidential information concerning Apple’s consideration 

and evaluation of potential chipset suppliers. 

FN 1540 Contains confidential information concerning Apple’s consideration 

and evaluation of potential chipset suppliers. 

¶ 547 Contains confidential information concerning Apple’s consideration 

and evaluation of a potential chipset supplier. 

FN 1545 Contains confidential information concerning Apple’s consideration 

and evaluation of a potential chipset supplier. 

¶ 548 Contains confidential information regarding Apple evaluation of 

chipset suppliers. 

¶ 549 Contains confidential information regarding Apple procurement 

decision making. 

FN 1550 Contains confidential Apple procurement decision making. 

¶ 550 Contains confidential information regarding Apple evaluation of a 

chipset supplier. 

FN 1566 Contains confidential information on Apple strategy on product 

development.

4. Exhibit 2 to the Declaration of Jennifer Milici in Support of the FTC’s Motion to 

Exclude Expert Testimony of Dr. Edward A. Snyder consists of excerpts from the Deposition of 

Edward A. Snyder. Apple treats the material at 29:20-30:3 (discussing Apple requirements for 

potential suppliers) and 32:25-33:1 (discussing Apple’s business dealings with a supplier) as 

confidential. If this information were to be released to the public, Apple’s competitors and 

Case 5:17-cv-00220-LHK Document 845 Filed 09/12/18 Page 10 of 11
10 

DECL. OF E. TAKASHIMA IN SUPPORT OF PLAINTIFF FEDERAL TRADE 

COMMISSION’S MOTION TO FILE UNDER SEAL (ECF 789) 

CASE NO. 5:17-CV-00220-LHK-NMC 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

potential business partners would gain insight into Apple’s internal business operations, 

potentially compromising Apple’s competitive standing. 

5. Apple requests that the Court grant Plaintiff’s Motion to File Under Seal as to the 

documents above. 

I declare under penalty of perjury that the foregoing is true and correct. Executed this 

12th day of September, 2018 in Santa Monica, California. 

By: /s/ Edward H. Takashima 

 Edward H. Takashima 

Case 5:17-cv-00220-LHK Document 845 Filed 09/12/18 Page 11 of 11