Digital Envoy Inc., v. Google Inc.,

Filing 148

4 Case 5:04-cv-01497-RS Document 148

C Filed 05/02/2005 Page 1 of 2

P . CRAIG CARDON, Cal . Bar No. 168646 BRIAN R . BLACKMAN, Cal . Bar No . 196996 KENDALL M . BURTON, Cal . Bar No . 228720 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP Four Embarcadero Center, 17th Floo r San Francisco, California 94111-4106 Telephone : [phone]-394 7 Facsimile : TIMOTHY H . KRATZ (Admitted Pro Hac Vice) LUKE ANDERSON (Admitted Pro Hac Vice) MCGUIRE WOODS, L .L . P 1170 Peachtree Street, N .E ., Suite 2100 Atlanta, Georgia 3030 9 Telephone : [phone] Facsimile : 404.443.575 1 Attorneys for DIGITAL ENVOY, INC . UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION DIGITAL ENVOY, INC ., Plaintiff/Counter defendant,
v. GOOGLE, INC . ,

ase No . C 04 01497 RS DIGITAL ENVOY'S ADMINISTRATIVE MOTION FOR AN ORDER FOR LEAVE TO FILE DOCUMENTS UNDER SEAL SEAL IN CONNECTION WITH ITS OPPOSITION TO GOOGLE, INC .'S TWO MOTIONS FOR SUMMARY JUDGMENT AND IN SUPPORT OF ITS RULE 56(F) MOTION

Defendant/ Counterclaimant .

Pursuant to Local Rule 79-5(d), plaintiff Digital Envoy, Inc . ("Digital Envoy") files this request for an order for leave to file under seal Digital Envoy's Rule 56(f) Motion and Exhibits 1, 9, 10, 12, 13, 14, and 15, attached to the Supplemental Declaration of Timothy H . Kratz In Support Of Digital Envoy's Opposition to Google, Inc .'s Two Motions for Summary Judgment and In Support of Its Rule 56(f) Motion. Digital Envoy respectfully requests that Digital Envoy's Rule 56(f) Motion and Exhibits 1, 9, 10, 12, 13, 14, and 15, attached to the Declaration of Timothy H . Kratz In Support Of Digita l
-1W02-SF :5BA 1 \61452379 .1

PLAINTIFF'S ADMIN . REQUEST FOR ORDER FOR LEAVE TO FILE UNDER SEAL IN CONNECTIO N WITH OPPOSITION TO GOOGLE'S MS J

1 Case 5:04-cv-01497-RS Document 148 Filed 05/02/2005 Page 2 of 2

Envoy's Opposition to Google, Inc .'s Two Motions for Summary Judgment and In Suppo rt of Its Rule 56(f) Motion be filed under seal . These Exhibits have been designated Confidential by Defendant Google, Inc . ("Google") pursuant to the Stipulation and Protective Order Regarding Confidentiality filed August 23, 2004 in this matter. For the foregoing reasons, Digital Envoy respectfully requests that the Cou rt grant this request and order DIGITAL ENVOY'S RULE 56(F) MOTION AND EXHIBITS 1, 9, 10, 12, 13, 14, AND 15, ATTACHED TO THE DECLARATION OF TIMOTHY H . KRATZ IN SUPPORT OF DIGITAL ENVOY'S OPPOSITION TO GOOGLE, INC .'S TWO MOTIONS FOR SUMMARY JUDGMENT AND IN SUPPORT OF ITS RULE 56(F) MOTION BE FILED UNDER SEAL TO PROTECT INFORMATION GOOGLE HAS DESIGNATED AS CONFIDENTIAL .

DATED : May 2, 2005 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP

By

Is/ Brian Blackman P . CRAIG CARDON BRIAN R. BLACKMAN TIMOTHY H . KRATZ (Pro Hac Vice To Be Applied For) LUKE ANDERSON (Pro Hac Vice To Be Applied For) MCGUIRE WOODS, L .L . P 170 Peachtree Street, N .E ., Suite 2100 Atlanta, Georgia 3030 9 Telephone : [phone] Facsimile : 404.443 .575 1 Attorneys for DIGITAL ENVOY, INC .

2W02-SF :5BA 1161452379 .1

PLAINTIFF'S ADMIN . REQUEST FOR ORDER FOR LEAVE TO FILE UNDER SEAL IN CONNECTION WITH OPPOSITION TO GOOGLE'S MS J