Electronic Arts Inc. v. Zynga Inc.

Filing 20

Ex Parte Application to file UNDER SEAL PORTIONS OF ITS COUNTERCLAIM FOR BREACH OF CONTRACT AND VIOLATION OF CALIFORNIA BUSINESS AND PROFESSIONS CODE SECTION 17200 re 18 Answer to Complaint, Counterclaim filed by Zynga Inc.. (Attachments: # 1 Declaration, # 2 Proposed Order)(Butler, Timothy) (Filed on 9/14/2012) Modified on 9/17/2012 (ysS, COURT STAFF). Modified on 9/17/2012 (ysS, COURT STAFF). Modified on 9/17/2012 (ewn, COURT STAFF).

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QUINN EMANUEL URQUHART & SULLIVAN, LLP
Claude M. Stern (Bar No. 96737)
[e-mail]
Karin Kramer (Bar No. 87346)
[e-mail]
555 Twin Dolphin Drive, 5th Floor
Redwood Shores, California 94065-2139
Telephone:
[phone]
Facsimile:
[phone]
PAUL HASTINGS LLP
Bradford K. Newman (Bar No. 178902)
[e-mail]
Peter C. Meier (Bar No. 179019)
[e-mail]
1117 S. California Avenue
Palo Alto, CA 94304-1106
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendant/Counter-Claimant
ZYNGA INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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ELECTRONIC ARTS INC.,

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Plaintiff,
vs.
ZYNGA INC.,

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Defendant.

CASE NO. CV 12 4099 SI
[PROPOSED] ORDER GRANTING
ZYNGA INC.’S EX PARTE APPLICATION
TO FILE UNDER SEAL PORTIONS OF
ITS COUNTERCLAIM FOR BREACH OF
CONTRACT AND VIOLATION OF
CALIFORNIA BUSINESS AND
PROFESSIONS CODE SECTION 17200

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ZYNGA INC.,
Counter-Claimant,

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vs.
ELECTRONIC ARTS INC.,
Counter-Defendant.

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Case No. CV 12 4099 SI

[PROPOSED] ORDER GRANTING
ZYNGA’S EX PARTE APP.

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Defendant and Counter-Claimant Zynga Inc. (“Zynga”) has filed Zynga’s Ex Parte

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Application To File Under Seal portions of its Counterclaim For Breach Of Contract And

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Violation Of California Business And Professions Code Section 17200, pursuant to Civil Local

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Rules 7-10, 79-5, and this Court’s Standing Order in the above-captioned matter.

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The Court, having considered the papers and the respective arguments of counsel, finds as
follows:
1.

Portions of the documents set forth in Zynga’s Ex Parte Application are entitled to

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protection under the law as compelling reasons exist for the sealing thereof;

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2.

The request is narrowly tailored to seek sealing only of sealable material;

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3.

The request conforms with Civil L.R. 79-5(c).

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Good and sufficient cause appearing, IT IS, THEREFORE, ORDERED, that Zynga’s Ex

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Parte Application To File Under Seal be, and hereby is GRANTED. The following portions of

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documents submitted in support of Zynga Inc.’s Counterclaim For Breach Of Contract And

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Violation Of California Business And Professions Code Section 17200 are hereby sealed:

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Document

Page:Line

Zynga Inc.’s Counterclaim For Breach Of Contract And
Violation Of California Business And Professions Code
Section 17200

1:10 (all words
after
“released”)

2.

Zynga Inc.’s Counterclaim For Breach Of Contract And
Violation Of California Business And Professions Code
Section 17200

3.

Zynga Inc.’s Counterclaim For Breach Of Contract And
Violation Of California Business And Professions Code
Section 17200

4.

Zynga Inc.’s Counterclaim For Breach Of Contract And
Violation Of California Business And Professions Code
Section 17200

5.

Zynga Inc.’s Counterclaim For Breach Of Contract And
Violation Of California Business And Professions Code
Section 17200

6.

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Item
No.
1.

Zynga Inc.’s Counterclaim For Breach Of Contract And
Violation Of California Business And Professions Code
Section 17200

8:22 (all words
after “into a”
and before
“settlement
agreement”)
8:23 (all words
after “a
release” and
before “See”)
8:24-25 (all
words after
“release” and
before “See”)
12:10 (all
words after
“agreement
that”)
12:11 (all
words before
“included a”)

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Case No. CV 12 4099 SI

-1-

[PROPOSED] ORDER GRANTING
ZYNGA’S EX PARTE APP.

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7.

Zynga Inc.’s Counterclaim For Breach Of Contract And
Violation Of California Business And Professions Code
Section 17200

8.

Zynga Inc.’s Counterclaim For Breach Of Contract And
Violation Of California Business And Professions Code
Section 17200
Zynga Inc.’s Counterclaim For Breach Of Contract And
Violation Of California Business And Professions Code
Section 17200
Zynga Inc.’s Counterclaim For Breach Of Contract And
Violation Of California Business And Professions Code
Section 17200
Zynga Inc.’s Counterclaim For Breach Of Contract And
Violation Of California Business And Professions Code
Section 17200
Zynga Inc.’s Counterclaim For Breach Of Contract And
Violation Of California Business And Professions Code
Section 17200
Zynga Inc.’s Counterclaim For Breach Of Contract And
Violation Of California Business And Professions Code
Section 17200
Exhibit A to Zynga Inc.’s Counterclaim For Breach Of
Contract And Violation Of California Business And
Professions Code Section 17200
Exhibit B to Zynga Inc.’s Counterclaim For Breach Of
Contract And Violation Of California Business And
Professions Code Section 17200

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9.
10.

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12.

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14.

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12:12 (all
words after
“claims” and
before “See”)
15:27 (all
words after
“released”)
15:28-16:1
(all)
16:5-8 (all)
16:9 (all words
before “and to
the extent”)
16:10-12 (all)
16:13-14 (all
words after
“and waived”)
In its entirety
In its entirety

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IT IS SO ORDERED.

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Dated: September ___, 2012

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THE HONORABLE SUSAN ILLSTON
U.S. DISTRICT COURT JUDGE

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Case No. CV 12 4099 SI

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[PROPOSED] ORDER GRANTING
ZYNGA’S EX PARTE APP.