Oracle America, Inc. v. Google Inc.

Filing 1224

Administrative Motion to File Under Seal Certain Discovery Pricing Information filed by Oracle America, Inc.. (Attachments: #1 Declaration Declaration of Benjamin Beck in support of Oracle's Administrative Motion to File Under Seal Certain Discovery Pricing Information, #2 Proposed Order [Proposed] Order Granting Oracle's Administrative Motion to File Under Seal)(Muino, Daniel) (Filed on 7/23/2012)

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN FRANCISCO DIVISION
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ORACLE AMERICA, INC.
Plaintiff,

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v.
GOOGLE INC.

Case No. CV 10-03561 WHA
DECLARATION OF BENJAMIN
BECK IN SUPPORT OF ORACLE’S
ADMINISTRATIVE MOTION TO
FILE UNDER SEAL CERTAIN
DISCOVERY PRICING
INFORMATION

Defendant.
Dept.: Courtroom 8, 19th Floor
Judge: Honorable William H. Alsup

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BECK DECLARATION IN SUPPORT OF ORACLE MOTION TO FILE UNDER SEAL
CASE NO. CV 10-03561 WHA
pa-1542911

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I, Benjamin Beck, declare

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1.

as

follows:

I submit this declaration in support of Oracle's Administrative Motion to File

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Under Seal Ce¡tain Discovery Pricing Information. I have personal knowledge of the matters set

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forth herein and, if called to testify, could and would testify competently to the following.

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SFL Data ("SFL") provides electronic discovery and project management services

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to corpomte legal departments and law firms. I have been working at SFL since 2007, and my

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present title is Chief Client

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negotiating pricing with SFL's clients.

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3.

Officer. My job responsibilities include, among other things,

I unde¡stand that an SFL pricing estimate is being submitted in support of Oracle's

Objections to Google's Bill of Costs. SFL requests that this information remain under seal.

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SFL considers its pricing information confidential and does not ordinarily

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distribute it without an obligation from the recipient not to disclose it to third parties. Disclosing

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SFL's pricing information would put SFL at a disadvantage to its competitors.

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5.

The task descriptions in the pricing estimate being submitted in this case, as well

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as the document's structure, reveal

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proprietary. Disclosing this information would further disadvantage SFL competitively.

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6.

SFL's business methods and processes, which SFL considers

SFL thus respectfully requests that its pricing estimate, and the information

contained within it, be filed under seal.

I declare under penalty of perjury under the laws of the United States that to the best of

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my knowledge the foregoing is true and correct.

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California.

2012, in San Francisco,

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BECK DECI-ARATIONIN SUPPORT OF ORACLE MOTIONTO FILE UNDERSEAL
CASE NO.

CV 10-03561 WHA

pa-I5429t1.

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ATTESTATION OF FILER

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I, Daniel P. Muino, have obtained Mr. Beck’s concurrence to file this document on his

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behalf.

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Dated: July 23, 2012

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MORRISON & FOERSTER LLP
By: /s/ Daniel P. Muino
Daniel P. Muino
Attorneys for Plaintiff
ORACLE AMERICA, INC.

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BECK DECLARATION IN SUPPORT OF ORACLE MOTION TO FILE UNDER SEAL
CASE NO. CV 10-03561 WHA
pa-1542911

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