Apple Inc. v. Psystar Corporation

Filing 134

MOTION to Seal MOTION TO DISMISS OR ENJOIN, THE DECLARATION OF JACQUES VIDRINE AND EXHIBITS 4-11 AND 14 TO DECLARATION OF MEHRNAZ BOROUMAND SMITH filed by Apple Inc.. (Attachments: # 1 Affidavit, # 2 Proposed Order)(Boroumand Smith, Mehrnaz) (Filed on 9/11/2009)

Apple Inc. v. Psystar Corporation

Doc. 134

Case3:08-cv-03251-WHA Document134

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TOWNSEND AND TOWNSEND AND CREW LLP JAMES G. GILLILAND, JR. (State Bar No. 107988) MEHRNAZ BOROUMAND SMITH (State Bar No. 197271) MEGAN M. CHUNG (State Bar No. 232044) J. JEB B. OBLAK (State Bar No. 241384) Two Embarcadero Center, Eighth Floor San Francisco, CA 94111 Telephone: [phone] Facsimile: [phone] Email: [e-mail] [e-mail] [e-mail] [e-mail] Attorneys for Plaintiff and Counterdefendant APPLE INC. UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

APPLE INC., a California corporation, Plaintiff, v. PSYSTAR CORPORATION, a Florida corporation, and DOES 1-10, inclusive, Defendants. AND RELATED COUNTERCLAIMS

Case No. CV 08-03251 WHA MISCELLANEOUS ADMINISTRATIVE REQUEST TO FILE UNDER SEAL PORTIONS OF APPLE INC.'S MOTION TO DISMISS OR ENJOIN, THE DECLARATION OF JACQUES VIDRINE AND EXHIBITS 4-11 AND 14 TO DECLARATION OF MEHRNAZ BOROUMAND SMITH

Plaintiff and counterdefendant Apple Inc. ("Apple") submits this Administrative Request pursuant to Civil Local Rules 7-11 and 79-5(c), for permission to file under seal portions of the Motion to Enjoin, the Declaration of Jacques Vidrine in Support thereof, and Exhibits 4-11 and 14 to the Declaration of Mehrnaz Boroumand Smith in Support thereof. These documents contain highly confidential testimony and reference highly confidential information from documents regarding confidential trade secret and technical information that has been designated as Confidential or Confidential Attorneys' Eyes Only under the Stipulated Protective Order approved by the Court on
MISC. ADMIN. REQUEST TO FILE UNDER SEAL PORTIONS OF APPLE INC.'S MOT. TO DISMISS OR ENJOIN, DECL. OF JACQUES VIDRINE AND EXHIBITS TO DECL. OF MEHRNAZ BOROUMAND SMITH CASE NO. CV 08-03251 WHA

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Case3:08-cv-03251-WHA Document134

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March 2, 2009. The undersigned declares that the request is narrowly tailored to seal only those materials for which good cause to seal has been established. Pursuant to Civil Local Rule 79-5(c), a sealed copy of the above-described document is being lodged with the clerk. DATED: September 11, 2009 Respectfully submitted, TOWNSEND AND TOWNSEND AND CREW LLP

By: /s/ Megan M. Chung MEGAN M CHUNG Attorneys for Plaintiff and Counterdefendant APPLE INC.
62212059 v1

MISC. ADMIN. REQUEST TO FILE UNDER SEAL PORTIONS OF APPLE INC.'S MOT. TO DISMISS OR ENJOIN, DECL. OF JACQUES VIDRINE AND EXHIBITS TO DECL. OF MEHRNAZ BOROUMAND SMITH CASE NO. CV 08-03251 WHA

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