Google Inc. v. Netlist, Inc.

Filing 139

Administrative MOTION to File Under Seal Motion for Summary Judgment on Google's Affirmative Defenses Based on Netlist's JEDEC Activities and Related Exhibits to the Declaration of Steven R. Hansen, filed by Netlist, Inc.. (Attachments: # 1 Declaration, # 2 Proposed Order)(Hansen, Steven) (Filed on 6/1/2010) Modified on 6/2/2010 (jlm, COURT STAFF).

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PRUETZ LAW GROUP LLP Adrian M. Pruetz (Bar No. CA 118215) E-mail: [e-mail] Erica J. Pruetz (Bar No. CA 227712) E-mail: [e-mail] 200 N. Sepulveda Blvd. Suite 1525 El Segundo, CA 90245 Telephone: [phone] Facsimile: [phone] LEE TRAN & LIANG APLC Enoch H. Liang (Bar No. CA 212324) E-mail: [e-mail] Steven R. Hansen (Bar No. CA 198401) E-mail: [e-mail] Edward S. Quon (Bar No. 214197) E-mail: [e-mail] 601 S. Figueroa St., Suite 4025 Los Angeles, CA 90017 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant and Counterclaimant NETLIST, INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION

GOOGLE, INC., Plaintiff, vs. NETLIST, INC., Defendant.

CASE NO. C-08-04144 SBA [Related to CASE NO. C-09-05718 SBA] DEFENDANT NETLIST, INC.'S ADMINISTRATIVE MOTION TO FILE NOTICE OF MOTION AND MOTION FOR SUMMARY JUDGMENT ON GOOGLE'S AFFIRMATIVE DEFENSES BASED ON NETLIST'S JEDEC ACTIVITIES AND RELATED EXHIBITS TO THE DECLARATION OF STEVEN R. HANSEN IN SUPPORT THEREOF UNDER SEAL Date: Time: Place: Judge: July 27, 2010 1:00 p.m. Courtroom 3 Hon. Saundra Brown Armstrong

___________________________________ AND RELATED COUNTERCLAIMS

NETLIST'S MOTION TO FILE MOTION FOR MSJ ON JEDEC ACTIVITES UNDER SEAL

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APPLICATION TO FILE UNDER SEAL Pursuant to Civil Local Rules 7-11 and 79-5, Defendant and Counterclaimant Netlist, Inc. ("Netlist") hereby requests that the Court file Netlist's "Notice of Motion and Motion for Summary Judgment on Google's Affirmative Defenses Based on Netlist's JEDEC Activities" and Exhibits B, C, D, E, and G of the Declaration of Steven R. Hansen in Support thereof ("Hansen MSJ Dec.") under seal. This request is based on this application, the Declaration of Steven R. Hansen in support thereof, and such oral argument as the Court may entertain. As required by Civil Local Rules 79-5(b)-(d) the following papers are also being lodged with the Court: (1) a Chamber's copy of the Notice of Motion and Motion for Summary Judgment on Google's Affirmative Defenses Based on Netlist's JEDEC Activities, (2) a Chamber's copy of the Declaration of Steven R. Hansen in Support of Netlist's Motion for Patent Infringement and Exhibits Thereto. Paragraph 26 of the Court's Second Amended Protective Order, dated March 5, 2010 requires the parties to file under seal all "transcripts of depositions, exhibits, answers to interrogatories, pleadings, briefs, and other documents submitted to the Court that have been designated as Protected Information or which contain information so designated." Netlist's Motion for Summary Judgment on Google's Affirmative Defenses Based on Netlist's JEDEC Activities includes information designated by Google and the third party JEDEC as Protected Information under the terms of the Second Amended Protective Order. The information includes excerpts of exhibits and deposition transcripts that have been so designated. Accordingly,

Netlist is obligated to file its Notice of Motion and Motion for Summary Judgment on Google's Affirmative Defenses Based on Netlist's JEDEC Activities and Exhibits B, C, D, E, and G to the Declaration of Steven R. Hansen in support thereof under seal. Netlist respectfully requests that the Court grant its application to file the foregoing documents under seal. Pursuant to the Court's Scheduling Order, the parties met and conferred regarding this motion.

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NETLIST'S MOTION TO FILE MOTION FOR MSJ ON JEDEC ACTIVITES UNDER SEAL

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Dated:

June 1, 2010

LEE TRAN & LIANG, APLC By: /s/Steven R. Hansen______________________ Steven R. Hansen Attorneys for Defendant and Counterclaimant NETLIST, INC.

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NETLIST'S MOTION TO FILE MOTION FOR MSJ ON JEDEC ACTIVITES UNDER SEAL