The motion claims since Samsung didn't know of the products when it filed the original lawsuit, they should be included since their design and software are so similar to other Apple products.
Here's an excerpt of the filing via AllThingsD:
The iPod Touch 5, iPad 4, and iPad Mini have the same accused functionality as the versions of the iPod Touch and iPad that are already part of this case. As such, the proof of infringement of the patents-in-suit by the iPod Touch 5, iPad 4, and iPad Mini will be substantially the same as for other Apple devices already accused of infringement in this litigation.
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