"The Apple iPod iTunes Anti-Trust Litigation"

Filing 369

Declaration of Michael Scott in Support of 368 Response in Support of Apple's Response to Plaintiffs' Administrative Motion to Seal filed byApple Inc.. (Related document(s) 368 ) (Scott, Michael) (Filed on 5/3/2010)

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 Robert A. Mittelstaedt #60359 ramittelstaedt@jonesday.com Craig E. Stewart #129530 cestewart@jonesday.com David C. Kiernan #215335 dkiernan@jonesday.com Michael T. Scott #255282 michaelscott@jonesday.com JONES DAY 555 California Street, 26th Floor San Francisco, CA 94104 Telephone: (415) 626-3939 Facsimile: (415) 875-5700 Attorneys for Defendant APPLE INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION THE APPLE iPOD iTUNES ANTI-TRUST LITIGATION. Case No. C 05-00037 JW (HRL) C 06-04457 JW (HRL) DECLARATION OF MICHAEL SCOTT IN SUPPORT OF APPLE'S RESPONSE TO PLAINTIFFS' ADMINISTRATIVE MOTION TO SEAL I, Michael Scott, declare as follows: 1. I am an associate in the law firm of Jones Day, located at 555 California Street, 26th Floor, San Francisco, CA 94104. I make this declaration in support of Apple's Response to Plaintiffs' Administrative Motion To File Under Seal. The facts stated in this declaration are true and based upon my own personal knowledge and, if called to testify to them, I would competently do so. 2. The redacted portions of Plaintiffs' Reply In Support Of Their Motion For Additional Discovery Pursuant To Rule 56(f) ("Reply") and the Merrick Declaration in support -1Decl. ISO Apple's Administrative Motion to Seal C 05-00037 JW (HRL), C 06-04457 JW (HRL) 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 thereof contain information relating to updates to Apple's FairPlay digital rights management technology. Apple previously moved to file under seal information relating to updates to FairPlay included in its Motion to Dismiss. Dkt. 327. The Court granted Apple's motion to seal on March 12, 2010. Dkt 340. The Court also granted motions to seal similar information in Plaintiffs' Opposition (Dkt. 353) and Apple's Reply (Dkt. 361). Executed this 3 day of May, 2010 in San Francisco, California. ______/s/ Michael Scott________ Michael Scott SFI-640578v1 -2- Decl. ISO Apple's Administrative Motion to Seal C 05-00037 JW (HRL), C 06-04457 JW (HRL)