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 Att. 1

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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 DECLARATION OF HOLLY GAUDREAU IN SUPPORT OF 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 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

I, Holly Gaudreau, declare as follows: 1. I am an attorney in the law firm of Kilpatrick Townsend & Stockton LLP, counsel

of record for plaintiff Sony Computer Entertainment America LLC ("SCEA") in the aboveDECLARATION OF HOLLY GAUDREAU IN SUPPORT OF ADMINISTRATIVE MOTION TO FILE UNDER SEAL CASE NO. 11-cv-00167 SI

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captioned matter. I make this declaration on personal knowledge and if called as a witness could and would testify competently thereto. 2. 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. 3. 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. 4. 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. 5. SCEA's request is narrowly tailored to seal only those materials for which good

cause to seal has been established. I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct to the best of my knowledge and belief. Executed on March 18, 2011, at San Francisco, California.

_______/s/ Holly Gaudreau_________________ Holly Gaudreau
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DECLARATION OF HOLLY GAUDREAU IN SUPPORT OF ADMINISTRATIVE MOTION TO FILE UNDER SEAL CASE NO. 11-cv-00167 SI

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