Overture Services, Inc. v. Google Inc.

Filing 84

Proposed Order Re: Request to File Documents Under Seal (Volume 2 of the Declaration of Christine P. Sun) by Google Inc.. (Sun, Christine)

Overture Services, Inc. v. Google Inc.

Doc. 84

Case 3:02-cv-01991-JSW

Document 84

Filed 08/14/2003

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KEKER & VAN NEST, LLP JOHN W. KEKER - #49092 DARALYN J. DURIE - #169825 CHRISTINE P. SUN - #218701 710 Sansome Street San Francisco, CA 94111-1704 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant and Counterclaimant GOOGLE TECHNOLOGY INC., sued under its former name GOOGLE INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

OVERTURE SERVICES, INC., a Delaware corporation, Plaintiff and Counterdefendant, v. GOOGLE INC., a California corporation, Defendant and Counterclaimant.

Case No. C 02-01991 JSW (EDL) GOOGLE'S REQUEST TO FILE DOCUMENTS UNDER SEAL; [PROPOSED] ORDER DISCOVERY MATTER

Google Technology Inc. ("Google") hereby submits this Request to File Documents Under Seal in connection with its Opposition to Overture Services, Inc.'s ("Overture's") Motion for a Protective Order. Google requests that the Court allow Google to file under seal an unredacted version of its Opposition, and Volume 2 of the Declaration of Christine P. Sun in support thereof. The unredacted version of the Opposition contains quotations from and summaries of the deposition transcript excerpts that Overture has designated confidential. A redacted version of the Opposition is being publicly filed. Volume 2 of the Sun Declaration contains excerpts from the transcripts of the depositions of Darren Davis and John Rauch. Those materials have been designated confidential by 1

316920.01

REQUEST TO FILE UNDER SEAL CASE NO. C 02-01991 JSW (EDL)
Dockets.Justia.com

Case 3:02-cv-01991-JSW

Document 84

Filed 08/14/2003

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Overture, and under the terms of the protective order entered in this case on December 18, 2002, Google cannot file these materials 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 and the Honorable Elizabeth D. Laporte's Standing Order on Confidential and Sealed Documents. 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).

Dated: August 11, 2003

KEKER & VAN NEST, LLP

By:

/s/ Christine P. Sun CHRISTINE P. SUN Attorneys for Defendant and Counterclaimant GOOGLE TECHNOLOGY INC., sued under its former name GOOGLE INC.

[PROPOSED] ORDER Pursuant to Civil Local Rules 7-10 and 79-5, Google has applied to this Court for an order permitting them to file under seal certain documents in connection with their opposition to Overture's motion for a protective order. GOOD CAUSE APPEARING, Google's request is granted. The Clerk is directed to maintain the unredacted versions of the following documents, submitted by Google on or about August 11, 2003, in accordance with the provisions of Civil Local Rule 79-5(e): (1) (2) Google's Opposition to Overture's Motion for Protective Order Volume 2 of the Declaration Of Christine P. Sun in Support of Google's

Opposition to Overture's Motion for Protective Order IT IS SO ORDERED.

Dated: HON. ELIZABETH D. LAPORTE United States Magistrate Judge 2
REQUEST TO FILE UNDER SEAL CASE NO. C 02-01991 JSW (EDL)

316920.01