Digital Envoy Inc., v. Google Inc.,

Filing 100

Digital Envoy Inc., v. Google Inc.,

Doc. 100

Case 5:04-cv-01497-RS

Document 100

Filed 02/23/2005

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DAVID H. KRAMER, State Bar No. 168452 STEPHEN C. HOLMES, State Bar No. 200727 WILSON SONSINI GOODRICH & ROSATI Professional Corporation 650 Page Mill Road Palo Alto, CA 94304-1050 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant/Counterclaimant Google Inc. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION

DIGITAL ENVOY, INC., Plaintiff/Counterdefendant, v. GOOGLE INC., Defendant/Counterclaimant.

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CASE NO.: C 04 01497 RS DEFENDANT AND COUNTERCLAIMANT GOOGLE INC.'S MISCELLANEOUS ADMINISTRATIVE REQUEST TO FILE DOCUMENTS UNDER SEAL PURSUANT TO LOCAL RULE 79-5 Judge: Hon. Richard Seeborg Courtroom: 4, 5th Floor Date: March 30, 2005 Time: 9:30 a.m

MISCELLANEOUS ADMINISTRATIVE REQUEST TO FILE DOCUMENTS UNDER SEAL CASE NO.: C04-01497 RS

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Dockets.Justia.com

Case 5:04-cv-01497-RS

Document 100

Filed 02/23/2005

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Defendant and counterclaimant Google Inc. ("Google") hereby requests that the Court permit it to file under seal the confidential unredacted version of Google Inc.'s Motion for Summary Judgment, and Exhibit D and Exhibit M to the Declaration of David H. Kramer in Support of Google Inc.'s Motion for Summary Judgment ("Kramer Declaration"). Plaintiff and counterdefendant Digital Envoy, Inc. ("Digital Envoy") has identified the documents attached as Exhibit D and Exhibit M to the Kramer Declaration as "Highly Confidential ­ Attorneys' Eyes Only" pursuant to the Protective Order entered in this matter on August 23, 2004. Exhibit D contains excerpts from the deposition testimony of Rob Friedman, taken on November 17, 2004. Exhibit M is a document produced in this litigation by Digital Envoy and is quoted in Google's memorandum. A public memorandum with the designated material redacted is also being filed. Without concurring in Digital Envoy's view, in light of its designations, Google requests an order permitting it to file Exhibit D, Exhibit M and an unredacted copy of its brief under seal.

Dated: February 23, 2005

WILSON SONSINI GOODRICH & ROSATI Professional Corporation

By:

/s/ David H. Kramer David H. Kramer

Attorneys for Defendant / Counterclaimant GOOGLE INC.

-1MISCELLANEOUS ADMINISTRATIVE REQUEST TO FILE DOCUMENTS UNDER SEAL CASE NO.: C04-01497 RS
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