"The Apple iPod iTunes Anti-Trust Litigation"

Filing 756

RESPONSE (re 750 Administrative Motion to File Under Seal Plaintiffs' Motion to Strike Supplemental Expert Report of Kevin M. Murphy and Robert H. Topel, dated December 20, 2013 ) filed byApple Inc.. (Attachments: # 1 Declaration of Amir Q. Amiri in Support of Apple's Response, # 2 Proposed Order Granting Plaintiffs' Admin. Motion to Seal, # 3 Apple's (Proposed) Redactions to Plaintiffs' Motion to Strike Suppl. Report of K. Murphy and R. Topel)(Amiri, Amir) (Filed on 1/21/2014)

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Robert A. Mittelstaedt (State Bar No. 60359)
[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 ANTI-TRUST
LITIGATION.

Case No. C 05-00037 YGR
[CLASS ACTION]

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DECLARATION OF AMIR Q. AMIRI IN
SUPPORT OF APPLE INC.’S
RESPONSE TO PLAINTIFFS’
ADMINISTRATIVE MOTION TO SEAL

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1.

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

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26th Floor, San Francisco, CA 94104. I submit this declaration in support of Apple’s Response

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to Plaintiffs’ Administrative Motion for Leave to File Plaintiffs’ Motion to Strike the

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Supplemental Report of Kevin M. Murphy and Robert H. Topel, Dated December 20, 2013

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Under Seal. (ECF No. 750). The facts stated in this declaration are true and based upon my own

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personal knowledge, and if called to testify to them, I would competently do so.

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2.

The relief requested in Apple’s response in support of Plaintiffs’ Administrative

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Motion and the proposed order provided to the court is necessary and narrowly tailored to protect

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Apple's confidential technological information. A portion of Plaintiffs’ brief in support of the
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Decl. ISO Response to
Administrative Motion to Seal
C 05-00037 YGR

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motion to strike contains sensitive information relating to Apple’s FairPlay digital rights

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management (DRM) technology and updates to that technology. This Court has sealed

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information relating to this subject matter in the past. See, e.g., ECF Nos. 340, 527.

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3.

Attached as Exhibit 1 is a true and correct copy of the Declaration of Jeffrey

Robbin filed January 22, 2010, ECF No. 328.
Executed this 17th day of January, 2014 in San Francisco, California.

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_/s/Amir Q. Amiri________
Amir Q. Amiri

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SFI-849444v1

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Decl. ISO Response to
Administrative Motion to Seal
C 05-00037 YGR

Exhibit 1