Google Inc. v. American Blind & Wallpaper Factory, Inc.

Filing 320

Google Inc. v. American Blind & Wallpaper Factory, Inc.

Doc. 320

Case 5:03-cv-05340-JF

Document 320

Filed 05/25/2007

Page 1 of 2

1 KEKER & V AN NEST, LLP

MICHAEL H. PAGE - #154913 2 MARK A. LEMLEY - #155830 KLAUS H. HAMM - #224905 3 AJAY S. KRSHNAN - #222476 710 Sansome Street
4 San Francisco, CA 94111-1704

Telephone: [phone]
5 Facsimile: [phone]

6

Attorneys. for Plaintiff and Counter Defendant 7 GOOGLE INC.
8

UNITED STATES DISTRICT COURT
9

NORTHERN DISTRICT OF CALIFORNIA
10
11

GOOGLE INC., a Delaware corporation,
12

Case No. C 03-5340-JF (RS)

Plaintiff,
13

v. 14
15 FACTORY,

AMERICAN BLIND & W ALLP APER INC., a Delaware corporation
d/b/a decoratetoday.com, Inc., and DOES 1-

16 100, inclusive,

17 Defendants.
18

NOTICE OF MOTION AND MOTION FOR ADMINISTRATIVE RELIEF SEEKING AN ORDER SEALING DOCUMENTS FOR FILING IN RELATION TO GOOGLE'S RESPONSE TO ABWF'S FOUR DECLARATIONS REGARDING ABWF'S ALLEGED PRESERVATION, COLLECTION, AND PRODUCTION OF MATERIALS IN RESPONSE TO APRIL 27, 2007 COURT ORDER

AMERICAN BLIND & W ALLP APER 19 FACTORY, INC., a Delaware corporation
d/b/a decoratetoday.com, Inc.,
Hon. Richard Seeborg

20

Counter-Plaintiff,
21

v.

22 GOOGLE INC.,
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Counter-Defendant.
24
25

26

27
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SEEKING AN ORDER SEALING FILING IN RELATION TO GOOGLE'S RESPONSE TO ABWF'S FOUR DECLARA TIONS REGARDING ABWF'S ALLEGED PRESERVATION, COLLECTION, AND PRODUCTION OF MATERILS IN RESPONSE TO APRIL 27,2007 COURT ORDER
NOTICE OF MOTION AND MOTION FOR ADMINISTRATIVE RELIEF DOCUMENTS FOR

396106.01

CASE NO. C 03-5340-JF (RS)

Dockets.Justia.com

Case 5:03-cv-05340-JF

Document 320

Filed 05/25/2007

Page 2 of 2

1

NOTICE OF MOTION AND MOTION FOR ADMINISTRATIVE RELIEF SEALING DOCUMENTS

2

3 TO ALL PARTIES AND THEIR COUNSEL OF RECORD:
4 Pursuant to Civil Local Rules 79-5(d) and 7-11 (a), Plaintiff and Counter-Defendant
5 Google Inc. ("Go

ogle") hereby gives notice to all counsel of record of its Motion for

6 Administrative Relief Seeking an Order Sealing Documents For Filing in Relation to Google' s
7 Response to ABWF's Four Declarations RegardingABWF's Alleged Preservation, Collection,
8 and Production of Materials in Response to April

27, 2007 Court Order ("Administrative
Motion, Google requests an order sealing Exhibit A to

9 Motion"). By way of this Administrative

10 the Declaration of Ajay Krishnan ("Krishnan Declaration") that was designated "Attorneys'

11 Eyes Only" by American Blind & Wallpaper Factory, Inc. ("ABWF") pursuant to the Stipulated
12 Protective Order signed by all parties to this litigation and approved by the Cour on September

13 19,2005 ("Protective Order") (Docket Item No. 60). Exhibit A is a document produced by

14 ABWF in the course of discovery, and Bates labeled ABWF 047376-047377.
15 Pursuant to Local Rules 79-5( d), Google moves to file under seal Exhibit A to the
16 Krishnan Declaration. Pursuant to Civil Local Rule 79-5(d), Exhibit A is lodged with the Clerk

17 concurently with this Administrative Motion.

18 Local Rule 79-5(d) outlines the procedure that ABWF must follow within five days ofthe
19 filing of this Administrative Motion if it wishes to maintain the confidential designation of

20 Exhibit A.
21 Dated: May 25,2007

KEKER & V AN NEST, LLP

22
23

24
25

By: /s/ Ajay S. Krishnan AJA Y S. KRSHNAN Attorneys for Plaintiff and Counter Defendant
GOOGLE INC.

26 27

28 1

NOTICE OF MOTION AND MOTION FOR ADMINISTRATIVE RELIEF SEEKING AN ORDER SEALING FILING IN RELATION TO GOOGLE'S RESPONSE TO ABWF'S FOUR DOCUMENTS FOR DECLARATIONS REGARDING ABWF' S ALLEGED PRESERVATION, COLLECTION, AND PRODUCTION
CASE NO. C 03-5340-JF (RS)

396106.01 OF MATERIALS IN RESPONSE TO APRIL 27, 2007 COURT ORDER