Google Inc. v. Netlist, Inc.

Filing 159

Administrative MOTION to File Under Seal Netlist's Reply in Support of its Motion for Summary Judgment of Infringement and in Opposition to Google's Motion for Summary Judgment of Non-Infringement and Related Exhibits filed by Netlist, Inc.. (Attachments: # 1 Declaration, # 2 Proposed Order)(Hansen, Steven) (Filed on 7/6/2010) Modified on 7/7/2010 (jlm, COURT STAFF).

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Google Inc. v. Netlist, Inc. Doc. 159 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PRUETZ LAW GROUP LLP Adrian M. Pruetz (Bar No. CA 118215) E-mail: ampruetz@pruetzlaw.com Erica J. Pruetz (Bar No. CA 227712) E-mail: ejpruetz@pruetzlaw.com 200 N. Sepulveda Blvd. Suite 1525 El Segundo, CA 90245 Telephone: (310) 765-7650 Facsimile: (310) 765-7641 LEE TRAN & LIANG APLC Enoch H. Liang (Bar No. CA 212324) E-mail: ehl@ltlcounsel.com Steven R. Hansen (Bar No. CA 198401) E-mail: srh@ltlcounsel.com Edward S. Quon (Bar No. 214197) E-mail: eq@ltlcounsel.com 601 S. Figueroa St., Suite 4025 Los Angeles, CA 90017 Telephone: (213) 612-3737 Facsimile: (213) 612-3773 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 ITS REPLY IN SUPPORT OF ITS MOTION FOR SUMMARY JUDGMENT OF INFRINGEMENT AND IN OPPOSITION TO GOOGLE'S MOTION FOR SUMMARY JUDGMENT OF NONINFRINGEMENT AND RELATED EXHIBITS UNDER SEAL Date: Time: Place: Judge: July 27, 2010 1:00 p.m. Courtroom 3 Hon. Saundra Brown Armstrong ___________________________________ AND RELATED COUNTERCLAIMS NETLIST'S ADMIN. MOTION TO FILE REPLY AND EXHIBITS UNDER SEAL C-08-04144 SBA Dockets.Justia.com 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ADMINISTRATIVE MOTION TO FILE UNDER SEAL Pursuant to General Order No. 62 and Civil Local Rules 7-11 and 79-5, Defendant and Counterclaimant Netlist, Inc. ("Netlist") hereby requests that the Court file Netlist, Inc.'s Reply in Support of Its Motion for Summary Judgment of Infringement and in Opposition to Google's Motion for Summary Judgment of Non-Infringement ("Netlist's Reply Brief") and Exhibits 1 and 5 of the Declaration of Steven R. Hansen in Support of Netlist's Reply in Support of its Motion for Summary Judgment of Infringement and in Opposition to Google's Motion for Summary Judgment of Non-Infringement ("Hansen Reply Dec.") under seal. This request is based on this administrative motion, 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) and General Order No. 62, the following papers are also being lodged with the Court: (1) a Chamber's copy of Netlist, Inc.'s Reply in Support of Its Motion for Summary Judgment of Infringement and in Opposition to Google's Motion for Summary Judgment of Non-Infringement, and (2) a Chamber's copy of the Declaration of Steven R. Hansen in Support of Netlist's Reply in Support of its Motion for Summary Judgment of Infringement and in Opposition to Google's Motion for Summary Judgment of Non-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 Reply Brief includes information designated by Google and third parties IDT and NEC 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 Netlist's Reply Brief and Exhibits 1 and 5 to the Hansen Reply Dec. 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. 1 NETLIST'S ADMIN. MOTION TO FILE REPLY AND EXHIBITS UNDER SEAL C-08-04144 SBA 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 NETLIST'S ADMIN. MOTION TO FILE REPLY AND EXHIBITS UNDER SEAL C-08-04144 SBA Dated: July 6, 2010 LEE TRAN & LIANG, APLC By: /s/ Steven R. Hansen______________________ Steven R. Hansen Attorneys for Defendant and Counterclaimant NETLIST, INC.

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