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

Filing 78

Declaration of Caroline C. Plater in Support of 71 Notice (Other), Notice (Other), Received Document Declaration of Caroline C. Plater in support of Administrative Motion to File Exhibits E, F, and G to the Hamm Declaration under seal filed byAmerican Blind & Wallpaper Factory, Inc.. (Attachments: # 1 Proposed Order)(Related document(s)71, []) (Andelman, Ethan) (Filed on 1/9/2006)

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KELLEY DRYE & WARREN LLP 333 WEST W Case 5:03-cv-05340-JF Document 78 Filed 01/09/2006 Page 2 of 3 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 KELLEY DRYE & WARREN LLP 333 WEST WACKER DRIVE SUITE 2600 CHICAGO, IL 60606 I, Caroline C. Plater declare as follows: 1. I am an attorney at Kelley Drye & Warren LLP, counsel of record for Defendant/Counter-Plaintiff American Blind & Wallpaper Factory, Inc. ("American Blind") in the above-captioned action. I am a member in good standing of the State Bar of Illinois. I have personal knowledge of the facts set forth in this declaration and, if called as a witness, could and would testify competently to such facts under oath. 2. Google has lodged Exhibits E, F, and G to the Hamm Declaration (the "lodged Hamm Exhibits") with the clerk pursuant to Civil Local Rule 79-5(d). The lodged Hamm Exhibits were produced by American Blind in this litigation, and were designated as Confidential pursuant to the protective order entered in this case. 3. The lodged Hamm Exhibits contain nonpublic American Blind business information. Specifically, the lodged documents discuss the keywords American Blind uses on Google' system. This information is not publicly known and could cause American Blind s competitive harm were it to become publicly known. 4. Thus, American Blind believes that the lodged Hamm Exhibits are properly designated as Confidential under the protective order entered in this case, and requests that the Court order the lodged Hamm Exhibits to be filed under seal. 5. American Blind does not contend that the other document lodged by Google under seal, Google' Opposition Brief, should be filed under seal. s Executed on January 9, 2006, at Chicago, Illinois. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. /s/ Caroline C. Plater Caroline C. Plater Case No. C03-5340 JF Declaration of Caroline C. Plater ISO Motion to File Under Seal DM_US\8297921.v1 -2- Case 5:03-cv-05340-JF Document 78 Filed 01/09/2006 Page 3 of 3 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 KELLEY DRYE & WARREN LLP 333 WEST WACKER DRIVE SUITE 2600 CHICAGO, IL 60606 ATTESTATION OF CONCURRENCE OF FILING I, Ethan B. Andelman, under penalty of perjury of the laws of the United States of America, attest that concurrence in the filing of this document has been obtained from each of the other signatories to this document. /s/ Ethan B. Andelman Ethan B. Andelman Case No. C03-5340 JF Declaration of Caroline C. Plater ISO Motion to File Under Seal DM_US\8297921.v1 -3-

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