Oracle America, Inc. v. Google Inc.

Filing 1039

Administrative Motion to File Under Seal filed by Google Inc.. (Attachments: #1 Proposed Order)(Van Nest, Robert) (Filed on 5/1/2012)

1
2
3
4
5
6
7
8
9
10
11
12

KEKER & VAN NEST LLP
ROBERT A. VAN NEST - #84065
[e-mail]
CHRISTA M. ANDERSON - #184325
[e-mail]
DANIEL PURCELL - #191424
[e-mail]
710 Sansome Street
San Francisco, CA 94111-1704
Telephone: [phone]
Facsimile: [phone]

KING & SPALDING LLP
SCOTT T. WEINGAERTNER (Pro Hac Vice)
[e-mail]
ROBERT F. PERRY
[e-mail]
BRUCE W. BABER (Pro Hac Vice)
[e-mail]
1185 Avenue of the Americas
New York, NY 10036-4003
Telephone: [phone]
Facsimile: [phone]

KING & SPALDING LLP
DONALD F. ZIMMER, JR. - #112279
[e-mail]
CHERYL A. SABNIS - #224323
[e-mail]
101 Second Street, Suite 2300
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]

GREENBERG TRAURIG, LLP
IAN C. BALLON - #141819
[e-mail]
HEATHER MEEKER - #172148
[e-mail]
1900 University Avenue, Fifth Floor
East Palo Alto, CA 94303
Telephone: [phone]
Facsimile: [phone]

Attorneys for Defendant
GOOGLE INC.

13
14
15

UNITED STATES DISTRICT COURT

16

NORTHERN DISTRICT OF CALIFORNIA

17

SAN FRANCISCO DIVISION

18
19

ORACLE AMERICA, INC.,

20

Case No. 3:10-cv-03561 WHA
Plaintiff,

21

v.

22

GOOGLE INC.’S ADMINISTRATIVE
MOTION TO FILE DOCUMENTS
UNDER SEAL

GOOGLE INC.,
Judge:

23

The Honorable William Alsup

Defendant.

24
25
26
27
28
1
GOOGLE INC.’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL
CASE NO. 3:10-cv-03561 WHA
661315.01

1

Pursuant to the Northern District of California’s Civil Local Rules 7-11 and 79-5,

2

Defendant Google Inc. (“Google”) hereby brings this Administrative Motion to Seal the

3

following material designated by Google as “Confidential” or “Highly Confidential – Attorneys’

4

Eyes Only” pursuant to the Order Approving Stipulated Protective Order Subject to Stated

5

Conditions entered in this case [Dkt. No. 68.]:
•

The redacted portions of Google’s Opposition to Oracle’s Renewed Motion to
Strike Portions of Dr. James Kearl’s Expert Report, including lines 1:1, 2:23-28,
3:1-2, and 3:20-28 of the Opposition;

•

6

The redacted portions of Exhibit A to the Declaration of Daniel Purcell in Support
of Google’s Opposition To Oracle’s Renewed Motion to Exclude Portions of the
Expert Report of Dr. James Kearl, which contains excerpted pages from the April
27, 2012 deposition of Andy Rubin regarding Google’s financial information
related to its Android business unit.

7
8
9
10
11

The redacted portions of Google’s Opposition expressly disclose or would allow others to

12

deduce Google’s sensitive, non-public financial data, such as costs, revenues, and profits, as well

13

as projected costs, revenues, and profits, associated with Android. It also contains sensitive,

14

non-public information about Google’s financial management practices and methodologies.

15

Public release of this information would cause great and undue harm to Google. Exhibit A of the

16

Declaration of Daniel Purcell in Support of Google’s Opposition to Oracle’s Renewed Motion to

17

Strike Portions of Dr. James Kearl’s Expert Report contains sensitive, non-public information

18

about Google’s financial management practices and methodologies. Public release of this

19

information would cause great and undue harm to Google. The Court has previously granted

20

motions to seal based on the identical financial data and practices. See Dkt. No. 935.

21
22

Dated: May 1, 2012

KEKER & VAN NEST LLP
By: /s/ Robert A. Van Nest
ROBERT A. VAN NEST
Attorneys for Defendant
GOOGLE INC.

23
24
25
26
27
28

2
GOOGLE INC.’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL
CASE NO. 3:10-cv-03561 WHA
661315.01

__