Overture Services, Inc. v. Google Inc.

Filing 207

MOTION to Seal Document (Declaration of Christine P. Sun in Support of Google's Reply Re Motion to Compel Production of Documents and Testimony Re Prosecution of '361 Patent ); [Proposed] Order filed by Google Inc.. (Grewal, Ravind) (Filed on 7/30/2004)

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Overture Services, Inc. v. Google Inc. Doc. 207 Case 3:02-cv-01991-JSW Document 207 Filed 07/30/2004 Page 1 of 3 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 KEKER & VAN NEST, LLP JOHN W. KEKER - #49092 DARALYN J. DURIE - #169825 CHRISTINE P. SUN - #218701 RAVIND S. GREWAL - #220543 710 Sansome Street San Francisco, CA 94111-1704 Telephone: (415) 391-5400 Facsimile: (415) 397-7188 Attorneys for Defendant and Counterclaimant GOOGLE INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION OVERTURE SERVICES, INC., Plaintiff and Counterdefendant, v. GOOGLE INC., Defendant and Counterclaimant. Case No. C 02-01991 JSW (EDL) REQUEST TO FILE DOCUMENT UNDER SEAL; [PROPOSED] ORDER Date: Time: Courtroom: Judge: August 24, 2004 9:00 a.m. E, 15th Floor Hon. Elizabeth D. Laporte 335987.01 REQUEST TO FILE DOCUMENT UNDER SEAL; [PROPOSED] ORDER CASE NO. C 02-01991 JSW (EDL) Dockets.Justia.com Case 3:02-cv-01991-JSW Document 207 Filed 07/30/2004 Page 2 of 3 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 Google Inc. ("Google") hereby submits this Request to File Documents Under Seal in connection with its Reply in Support of Its Motion to Compel Production of Documents and Testimony Re Prosecution of the '361 Patent ("Reply"). Google requests that the Court allow Google to file under seal the Declaration of Christine P. Sun in Support of Google's Reply ("Sun Reply Declaration). The Declaration of Christien P. Sun and Exhibit thereto The exhibits to the Sun Reply Declaration contain material that has been designated as confidential by Plaintiff Overture Services, Inc. ("Overture"). Under the terms of the protective order entered in this case on December 16, 2002, Google cannot file this material publicly. See Protective Order 6. In light of the foregoing, Google respectfully submits that this Request to File Documents Under Seal is narrowly tailored within the meaning of Civil Local Rule 79-5. Google therefore requests that the Court permit the sealing of the documents set forth above, and order that the Clerk of the Court maintain them in accordance with the provisions of Local Civil Rule 79-5(e). RESPECTFULLY SUBMITTED, Dated: July 30, 2004 KEKER & VAN NEST, LLP By: /s/ Ravind S. Grewal RAVIND S. GREWAL Attorneys for Defendant and Counterclaimant GOOGLE INC. 1 335987.01 REQUEST TO FILE DOCUMENT UNDER SEAL; [PROPOSED] ORDER CASE NO. C 02-01991 JSW (EDL) Case 3:02-cv-01991-JSW Document 207 Filed 07/30/2004 Page 3 of 3 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 Dated: [PROPOSED] ORDER Pursuant to Civil Local Rules 7-10 and 79-5, Google has applied to this Court for an order permitting it to file under seal the Declaration of Christine P. Sun in connection with its Reply in Support of Its Motion to Compel Production and Testimony Re Prosecution of the '361 Patent. GOOD CAUSE APPEARING, Google's request is granted. The Clerk is directed to maintain the following document, submitted by Google on or about July 30, 2004, in accordance with the provisions of Civil Local Rule 79-5(e): (1) The Declaration of Christine P. Sun in Support of Google's Reply. IT IS SO ORDERED. HON. ELIZABETH D. LAPORTE United States Magistrate Judge 2 335987.01 REQUEST TO FILE DOCUMENT UNDER SEAL; [PROPOSED] ORDER CASE NO. C 02-01991 JSW (EDL)

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