"The Apple iPod iTunes Anti-Trust Litigation"

Filing 746

Declaration of Amir Amiri in Support of 745 Response to Administrative Motion to File Under Seal 737 , filed by Apple Inc.. (Attachments: # 1 Exhibit A: Exhibits 1-2 to Amiri Declaration)(Related document(s) 745 ) (Amiri, Amir) (Filed on 12/24/2013) Modified on 12/26/2013 (jlmS, COURT STAFF).

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Robert A. Mittelstaedt (State Bar No. 060359)
[e-mail]
Craig E. Stewart (State Bar No. 129530)
[e-mail]
David C. Kiernan (State Bar No. 215335)
[e-mail]
Amir Q. Amiri (State Bar No. 271224)
[e-mail]
JONES DAY
555 California Street, 26th Floor
San Francisco, CA 94104
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendant
APPLE INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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OAKLAND DIVISION

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THE APPLE IPOD ITUNES ANTITRUST LITIGATION

Lead Case No. C-05-0037-YGR
[CLASS ACTION]

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DECLARATION OF AMIR AMIRI IN
SUPPORT OF PLAINTIFFS’
ADMINISTRATIVE MOTION TO
FILE UNDER SEAL

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I am an associate in the law firm of Jones Day, located at 555 California Street, 26th Floor,

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San Francisco, CA 94104. I submit this declaration in support of Apple’s Response to Plaintiffs’

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Administrative Motion to File Under Seal portions of Plaintiffs’ Daubert Motion to Exclude

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Certain Opinion Testimony of Kevin M. Murphy and Robert H. Topel and Exhibits 1-10 to the

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Sweeney Declaration in support thereof (ECF No. 737, “Administrative Motion”). The facts

Amiri Decl. in Support of Apple’s Response to
Plaintiffs’ Motion Seal
C-05-0037-YGR

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stated in this declaration are true and based upon my own personal knowledge, and if called to

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testify to them, I would competently do so.

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tailored to protect Apple’s confidential business and pricing information. Plaintiffs’ Daubert

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Motion, and the exhibits filed in support thereof, contain highly confidential information

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regarding iPod pricing strategy and information regarding sales of iPods to iPod resellers. As

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demonstrated in the attached declarations, each of which were previously submitted in connection

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with various other motions to seal similar data and documents during the pendency of this

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litigation, the disclosure of this information would harm Apple.

The relief requested in Plaintiffs’ Administrative Motion is necessary and narrowly

Attached as Exhibit 1 is a true and correct copy of the Declaration of Mark Buckley in

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Support of Apple’s Response to Plaintiffs’ Under Seal Portions of Plaintiffs’ Motion Regarding

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Schedule for Class Certification filed January 14, 2011, ECF No. 454.

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Support of Apple’s Response to Plaintiffs’ Motion to File Under Seal Portions of Plaintiffs’

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Renewed Motion for Class Certification filed January 25, 2011, ECF No. 492.

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Attached as Exhibit 2 is a true and correct copy of the Declaration of Mark Buckley in

Executed this 24th day of December, 2013 in San Francisco, California.

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/s/ Amir Q. Amiri
Amir Q. Amiri

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SFI-847699v1

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Amiri Decl. in Support of Apple’s Response to
Plaintiffs’ Motion to Seal
C-05-0037-YGR