Digital Envoy Inc., v. Google Inc.,

Filing 85

Declaration of David H. Kramer in Support of Google Inc.'s Miscellaneous Administrative Request to File Under Seal, Pursuant Local Rules 7-10(b) and 79-5 filed byGoogle Inc.,, Google Inc.,. (Kramer, David) (Filed on 2/7/2005)

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Digital Envoy Inc., v. Google Inc., Doc. 85 Case 5:04-cv-01497-RS Document 85 Filed 02/07/2005 Page 1 of 2 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 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: (650) 493-9300 Facsimile: (650) 565-5100 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. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CASE NO.: C 04 01497 RS DECLARATION OF DAVID H. KRAMER IN SUPPORT OF GOOGLE INC.'S MISCELLANEOUS ADMINISTRATIVE REQUEST TO FILE DOCUMENTS UNDER SEAL, PURSUANT LOCAL RULES 7-10(b) and 79-5 Date: Time: Courtroom: Judge: March 16, 2005 9:30 a.m. 4, 5th Floor Hon. Richard Seeborg DECL. ISO GOOGLE'S MISC. ADMIN. REQUEST TO FILE UNDER SEAL - CASE NO. 04-0197 RS 2601743_1.DOC Dockets.Justia.com Case 5:04-cv-01497-RS Document 85 Filed 02/07/2005 Page 2 of 2 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 I, David H. Kramer, declare as follows: 1. I am an attorney at law duly licensed to practice in the State of California and before this Court. I am a member of Wilson Sonsini Goodrich & Rosati, counsel for defendant and counterclaimant Google Inc. ("Google"). I have personal knowledge of the facts set forth herein and, if called as a witness, could and would testify competently thereto. 2. I submit this declaration in support of Google's Miscellaneous Administrative Request to File Under Seal, Pursuant to Local Rules 7-10(b) and 79-5, Exhibit D to the Declaration of Stephen C. Holmes in Support of Google's Motion For Partial Summary Judgment on Counts II, III, IV and V of the Amended Complaint ("Holmes Declaration"). 3. Exhibit D to the Holmes Declaration ("Exhibit D") contains information designated by plaintiff and counterdefendant Digital Envoy, Inc. as "Highly Confidential Attorneys' Eyes Only" under the terms of the Court's August 23, 2004 Stipulation and Protective Order Regarding Confidentiality ("Protective Order"). The documents attached as Exhibit D are excerpts from the deposition testimony of Rob Friedman, dated November 17, 2004. The excerpts attached as Exhibit D are quoted in Google's accompanying memorandum. Without concurring in Digital Envoy's view, in light of its designations, Google requests an order permitting it to file the deposition testimony and an unredacted copy of its brief under seal. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on February 7, 2005, at Palo Alto, California. /s/ David H. Kramer David H. Kramer DECL. ISO GOOGLE'S MISC. ADMIN. REQUEST TO FILE UNDER SEAL - CASE NO. 04-0197 RS -1-

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