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

Filing 26

Declaration of Paul M. Fakler in Support of 25 Stipulated Administrative Motion for Leave to File Certification of Interested Entities Under Seal filed byVeoh Networks, Inc.. (Related document(s) 25 ) (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 26

Filed 09/25/2006

Page 1 of 2

Dean A. Morehous (CA Bar No. 111841)

dam~thelenreid. com

THELEN REID & PRIEST LLP 101 Second Street Suite 1800 San Francisco , CA 94105
Telephone: [phone] Facsimile: (415) 371- 1211

melkin~thelenreid. com pfakler~thelenreid. com THELEN REID & PRIEST LLP 875 Third Avenue New York, New York 10022
Michael S. Elkin (pro hac vice) Paul M. Fakler (pro hac vice)

Telephone: [phone]

Facsimile: [phone]
Attorneys for Defendant

10 YEaH 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,

19

18 YEaH NETWORKS , Inc. , a California
Corporation
Defendant.

DECLARATION OF PAUL M. FAKLER IN SUPPORT OF STIPULATED ADMINISTRA TIVE MOTION FOR LEA VE TO FILE CERTIFICATION OF INTERESTED ENTITIES OR PERSONS UNDER SEAL

, PAUL M. FAKLER, declare:
I am an associate of the law firm of Thelen Reid & Priest LLP, attorneys of record

for Defendant YEaH Networks, Inc. ("Defendant"), in the above-entitled action. I am admitted to
practice in the State of New York and have been admitted pro hac vice

in this action. The

following matters are true of my own personal knowledge and if called upon to do so, I could and
would competently testify thereto.

DECLARATION OF P. F AKLER IN SUPPORT OF STIPULATED
THELEN REID
& PRIEST LLP
ATIORNEYS AT LAW

ADMINISTRATIVE MOTION TO FILE CERTIFICATION UNDER SEAL
C 06-3926 (HRL)

Dockets.Justia.co

Case 5:06-cv-03926-HRL

Document 26

Filed 09/25/2006

Page 2 of 2

The required filing of Veoh' s Certification of Interested Entities and Persons

pursuant to Civil Local Rule 3- 16 will necessarily include a list identifying the various shareholders
of Veoh.

The identity of Veoh' s shareholders is not publicly known or available information

and is considered sensitive and confidential by Veoh. This confidential information is the only
information that will be contained in the Certification. Consequently, Veoh respectfully requests
the Court' s leave to file the entire Certification under seal.

On September 25 , 2006, Counsel for Plaintiff stipulated to this motion.

I declare under penalty of perjury under the laws of the United States of America that the

foregoing is true and correct. Executed in New York, New York on the 25th of September, 2006.

Isl Paul M. Fakler Paul M. Fakler (pro hac vice)

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

Facsimile: [phone]

Attorneys for Defendant YEaH NETWORKS , INC.

DECLARATION OF P. F AKLER IN SUPPORT OF STIPULATED
THELEN REID
& PRIEST LLP
ATIORNEYS AT LAW

ADMINISTRATIVE MOTION TO FILE CERTIFICATION UNDER SEAL
C 06-3926 (HRL)