One of the more notable documents filed with Judge Lucy Koh's court in the Apple versus Samsung post-trial motions is a letter from Apple intellectual property licensing director Boris Teskler to his equivalent at Samsung, Seongwoo Kim. The letter outlines a reciprocal patent agreement more in line with actual fair, reasonable, and non-discriminatory (FRAND) terms, rather than Samsung's proposed 2.4 percent rate of the entire device's purchase price.