Acco Brands, Inc. v. PC Guardian Anti-Theft Products, Inc. et al

Filing 273

SEALING ORDER (264). Signed by Judge Illston on 10/1/08. (ts, COURT STAFF) (Filed on 10/1/2008)

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Case 3:04-cv-03526-SI Document 264 Filed 09/26/2008 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 John M. McCormack (State Bar No. 143194) Peter E. Heuser (State Bar No. 111600) Elizabeth A. Tedesco (State Bar No. 221162) Michael R. Langer (Admitted pro hac vice) Thomas J. Romano (admitted pro hac vice) KOLISCH HARTWELL, P.C. 260 Sheridan Avenue, Suite 200 Palo Alto, California 94306 Telephone: (650) 325-8673 Facsimile: (650) 325-5076 Attorneys for Defendants UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA ACCO BRANDS, INC. d/b/a KENSINGTON TECHNOLOGY GROUP, Plaintiff, v. PC GUARDIAN ANTI-THEFT PRODUCTS, INC. and FELLOWES, INC., Defendants. No. 04-03526 SI STIPULATION TO FILE MATERIALS UNDER SEAL IN CONNECTION WITH DEFENDANTS' OPPOSITION TO PLAINTIFF KENSINGTON TECHNOLOGY GROUP'S MOTION FOR SUMMARY JUDGMENT Plaintiff ACCO Brands, Inc. d/b/a/ Kensington Technology Group ("ACCO") and defendants PC Guardian Anti-Theft Products, Inc. ("PC Guardian") and Fellowes, Inc. hereby stipulate that the following exhibits be filed under seal in connection with the Declaration of Thomas J. Romano in Support of Defendants' Opposition to Plaintiff Kensington Technology Group's Motion for Summary Judgment: Page 1-- STIPULATION AND [PROPOSED] ORDER TO FILE MATERIALS UNDER SEAL; Case No. 04-03526 SI Case 3:04-cv-03526-SI Document 264 Filed 09/26/2008 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 Exhibit H: Copy of Opposition Expert Report of Steven A. Velinsky Regarding Infringement of Claims 1, 4, 5, 7 And 9 of U.S. Patent No. 6,553,794 Exhibit I: Excerpts from the 30(B)(6) deposition of Janet Dulsky, taken May 16, 2008. Exhibit K: Excerpts from the deposition of David A. Dornfeld, Ph.D., taken September 5, 2008. The parties believe that the deposition testimony listed above should be filed under seal because it has been designated "Highly Confidential-Attorneys' Eyes Only" under the Stipulated Protective Order and includes competitively sensitive discussion of activities connected to the prosecution of the patent-in-suit and related patents, as well as product development and confidential internal practices. The parties further believe that the Opposition Expert Report of Steven A. Velinsky Regarding Infringement of Claims 1, 4, 5, 7 and 9 of U.S. Patent No. 6,553,794 should be filed under seal because it has been designated "Highly Confidential--Attorneys' Eyes Onl y" under the Stipulated Protective Order and includes and discusses material from deposition transcripts that are currently designated "Highl y Confidential-Attorneys' Eyes Onl y" under the Stipulated Protective Order. Consistent with the parties' belief that all of the information listed above should be filed under seal, the parties also stipulate to filing Defendants' Memorandum in Opposition to Plaintiff Kensington Technology Group's Motion for Summary Judgment under seal because it discusses the material listed above. Page 2-- STIPULATION AND [PROPOSED] ORDER TO FILE MATERIALS UNDER SEAL; Case No. 04-03526 SI Case 3:04-cv-03526-SI Document 264 Filed 09/26/2008 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: September 26, 2008 /s/ Brian Smith Brian Smith HOWREY LLP 525 Market Street, Suite 3600 San Francisco, CA 94105 Telephone: 415-848-4900 Facsimile: 415-848-4999 Email: smithbrian@howrey.com Attorneys for Plaintiff ACCO BRANDS INC., d/b/a KENSINGTON TECHNOLOGY GROUP DATED: September 26, 2008 /s/ Elizabeth A. Tedesco Elizabeth A. Tedesco KOLISCH HARTWELL, P.C. 520 SW Yamhill Street, Suite 200 Portland, Oregon 97204 Telephone: 503-224-6655 Facsimile: 503-295-6679 Email: tedesco@khpatent.com Attorneys for Defendants, PC GUARDIAN ANTI-THEFT PRODUCTS, INC. and FELLOWES, INC. IT IS SO ORDERED. DATED: Honorable Susan Illston United States District Court Judge Page 3-- STIPULATION AND [PROPOSED] ORDER TO FILE MATERIALS UNDER SEAL; Case No. 04-03526 SI

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