Sony Computer Entertainment America LLC v. Hotz et al

Filing 106

Administrative Motion to File Under Seal filed by Sony Computer Entertainment America LLC. (Attachments: # 1 Affidavit Gaudreau Declaration ISO Admin Motion, # 2 Proposed Order, # 3 Certificate of Service)(Smith, Mehrnaz) (Filed on 3/19/2011)

Sony Computer Entertainment America LLC v. Hotz et al

Doc. 106

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KILPATRICK TOWNSEND & STOCKTON LLP JAMES G. GILLILAND, JR. (State Bar No. 107988) TIMOTHY R. CAHN (State Bar No. 162136) MEHRNAZ BOROUMAND SMITH (State Bar No. 197271) HOLLY GAUDREAU (State Bar No. 209114) RYAN BRICKER (State Bar No. 269100) Two Embarcadero Center Eighth Floor San Francisco, CA 94111 Telephone: [phone] Facsimile: [phone] Email: [e-mail] [e-mail] [e-mail] [e-mail] [e-mail] Attorneys for Plaintiff SONY COMPUTER ENTERTAINMENT AMERICA LLC UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION SONY COMPUTER ENTERTAINMENT AMERICA LLC, Plaintiff, v. GEORGE HOTZ; HECTOR MARTIN CANTERO; SVEN PETER; and DOES 1 through 100, Defendants. Case No. 11-cv-00167 SI ADMINISTRATIVE MOTION TO FILE UNDER SEAL EXHIBIT A TO DECLARATION OF ANDREW PIERCE; EXHIBITS A AND B TO DECLARATION OF KENNETH LAW; AND EXHIBITS H, L, M, N, P AND T TO DECLARATION OF RYAN BRICKER IN SUPPORT OF PLAINTIFF SONY COMPUTER ENTERTAINMENT AMERICA LLC'S OPPOSITION TO DEFENDANT GEORGE HOTZ'S MOTION TO DISMISS FOR LACK OF PERSONAL JURISDICTION AND IMPROPER VENUE Date: April 8, 2011 Time: 9:00 a.m. Courtroom: 10, 19th Floor Judge: Hon. Susan Illston

ADMINISTRATIVE MOTION TO FILE UNDER SEAL Case No. 11-cv-00167 SI

Dockets.Justia.com

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Pursuant to Local Rules 7-11 and 79-5, Plaintiff Sony Computer Entertainment America LLC ("SCEA") submits this Administrative Motion to file under seal Exhibit A to the Declaration of Andrew Pierce, Exhibits A and B to the Declaration of Kenneth Law and Exhibits H, L, M, N and T to the Declaration of Ryan Bricker In Support of Plaintiff's Opposition to Defendant's Motion to Dismiss for Lack of Personal Jurisdiction and Improper Venue. Pursuant to Local Rule 79-5 (c) (3), SCEA is lodging with the Clerk a copy of these documents for filing under seal. This motion is supported by the Declaration of Holly Gaudreau ("Gaudreau Decl.") filed concurrently herein. Exhibit A to the Andrew Pierce Declaration contains IP addresses that should not be made public record in order to protect the privacy of individuals associated with those IP addresses. Gaudreau Decl., ¶2. Exhibits A and B to the Kenneth Law Declaration are internal SCEA reports that provide identifying information and other confidential details ­ including the IP address and corresponding geographic location ­ that correspond to a particular PlayStation®3 computer entertainment system ("PS3 System") and PlayStation® Network ("PSN") account. The documents should not be made public record in order to protect the privacy of the individual associated with the console and account. Id. at ¶3. Exhibits H, L, M, N, P and T to the Ryan Bricker Declaration reproduce circumvention devices, a part thereof, and/or proprietary information related to devices that circumvent the technological protection measures ("TPMs") in SCEA's PS3 System. SCEA brought this action to put an end to the illegal circumvention of these TPMs in its PS3 System. SCEA, therefore, does not want the means of such circumvention ­ the very practice it is aiming to stop ­ to be a matter of public record, thereby making the information further available and enabling others to engage in this illegal practice. Id. at ¶4. SCEA's request is narrowly tailored to seal only those materials for which good cause to seal has been established. Id. at ¶5. Accordingly, SCEA respectfully requests that the Court grant its Administrative Motion to file Exhibit A to the Declaration of Andrew Pierce, Exhibits A and B to the Declaration of Kenneth Law and Exhibits H, L, M, N, P and T
ADMINISTRATIVE MOTION TO FILE UNDER SEAL Case No. 11-cv-00167 SI

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to the Declaration of Ryan Bricker under seal. Respectfully submitted, KILPATRICK TOWNSEND & STOCKTON LLP

By: /s/ Holly Gaudreau Holly Gaudreau Attorneys for Plaintiff SONY COMPUTER ENTERTAINMENT AMERICA LLC
63216536 v1

ADMINISTRATIVE MOTION TO FILE UNDER SEAL Case No. CV11-0167 SI

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