IO Group, Inc. v. Veoh Networks, Inc.

Filing 25

STIPULATED Administrative Motion and (Proposed) Order For Leave to File Certification of Interested Entities or Persons Under Seal by Veoh Networks, Inc.. (Fakler, Paul) (Filed on 9/25/2006) Text modified on 9/25/2006 to conform to document post by counsel (bw, COURT STAFF).

Case 5:06-cv-03926-HRL

Document 25

Filed 09/25/2006

Page 1 of 3

Dean A. Morehous (CA Bar No. 111841)

damCfYthelenreid. com

THELEN REID & PRIEST LLP 101 Second Street Suite 1800 San Francisco , CA 94105
Telephone: [phone]

Facsimile: (415) 371- 1211
Michael S. Elkin Paul M. Fakler (pro hac vice pending) (pro hac vice pending)

melkinCfYthelenreid. com pfaklerCfYthelenreid. com

THELEN REID & PRIEST LLP 875 Third Avenue New York, New York 10022
Telephone: [phone]

Facsimile: [phone]

Attorneys for Defendant YEOH NETWORKS, INC.

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION

10 GROUP, INC. , a California Corporation

Case No. : C06-3926 (HRL)

Plaintiff,

YEOH NETWORKS, Inc. , a California Corporation Defendant.

STIPULA TED ADMINISTRATIVE MOTION AND (PROPOSED) ORDER FOR LEA VE TO FILE CERTIFICATION OF INTERESTED ENTITIES OR PERSONS UNDER SEAL

Defendant , Veoh Networks, Inc. , hereby requests, pursuant to Civil Local Rule 79- , an

Order granting leave to file Defendant's Certification ofInterested Entities or Persons pursuant to
Civil Local Rule 3 - 16 under seal.

Defendant will lodge its Certification of Interested Entities or Persons under seal because

27 the Certification identifies various stockholders of Defendant, which information is confidential and
not publicly available. Plaintiff has agreed that th~

Certification may only be viewed by or disclosed
STIPULATED ADMINISTRATIVE MOTION AND (PROPOSED) ORDER TO FILE CERTIFICATION UNDER SEAL O6- 3926 (HRL)

THELEN REID
& PRIEST LLP
ATIORNEYS AT LAW

Dockets.Justia.co

Case 5:06-cv-03926-HRL

Document 25

Filed 09/25/2006

Page 2 of 3

to Plaintiff's counsel , including Plaintiff's General Counsel. Plaintiff retains the right to seek any

information appearing within the Certification, to the extent such information is otherwise
discoverable , subject to further protective orders as appropriate.

This request is narrowly tailored to seal only those materials containing confidential

information. The only information disclosed in the Certification is the confidential identity of
Defendant's stockholders. Consequently

Defendant requests that the entire Certification be filed

under seal. Such sealed filing will not result in the sealing of any information other than the

confidential information Defendant seeks to protect.

SO STIPULATED.
Dated: September 25 ,

2006

THELEN REID & PRIEST LLP

Isl Paul M. Fakler
Paul M. Fakler

(pro hac vice) (pro hac vice)

Michael S. Elkin

Dean A. Morehous
Attorneys for Defendant YEOH NETWORKS, INC.
Dated: September 25 ,

2006

THE LAW FIRM OF GILL SPERLEIN

Isl Gill Sperlein GILL SPERLEIN
Attorneys for Plaintiff
10 GROUP, INC.

, Paul M. Fakler, hereby attest, pursuant to N.D. Cal. General Order No. 45 , that the

concurrence to the filing of this document has been obtained from each signatory hereto.
Isl Paul M. Fakler
Paul M. Fakler

(pro hac vice)

THELEN REID
& PRIEST LLP
ATIORNEYS AT LAW

STIPULATED ADMINISTRATIVE MOTION AND (PROPOSED) ORDER TO FILE CERTIFICATION UNDER SEAL O6- 3926 (HRL)

Case 5:06-cv-03926-HRL

Document 25

Filed 09/25/2006

Page 3 of 3

rPROPOSEDl ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.

Dated:

HONORABLE HOWARD R. LLOYD UNITED STATES MAGISTRATE JUDGE

THELEN REID
& PRIEST LLP
ATIORNEYS AT LAW

STIPULATED ADMINISTRATIVE MOTION AND (PROPOSED) ORDER TO FILE CERTIFICATION UNDER SEAL O6- 3926 (HRL)