The Facebook, Inc. v. Connectu, Inc et al

Filing 355

MOTION to file under Seal Plaintiff administrative request to Civil L.R. 7-11; Declaration of I. N. Chatterjee and exhibits in support there of Document filed by Mark Zuckerberg, The Facebook, Inc.. (Attachments: # 1 Proposed Order)(Sutton, Theresa) (Filed on 5/9/2008) Modified on 5/12/2008 (cv, COURT STAFF).

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The Facebook, Inc. v. Connectu, LLC et al Doc. 35 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 SEAN A. LINCOLN (State Bar No. 136387) salinco ln@orrick.com I. NEEL CHATTERJEE (State Bar No. 173985) nchatterjee@orrick.com MONTE COOPER (State Bar No. 196746) mcooper@orrick.co m THERESA A. SUTTON (State Bar No. 211857) tsutton@orrick.com YVONNE P. GREER (State Bar No. 214072) ygreer@orrick.co m ORRICK, HERRINGTON & SUTCLIFFE LLP 1000 Marsh Road Menlo Park, CA 94025 Telephone: 650-614-7400 Facsimile: 650-614-7401 Attorneys for Plaintiffs FACEBOOK, INC. and MARK ZUCKERBERG UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION FACEBOOK, INC. and MARK ZUCKERBERG, Plaint iffs, v. CONNECTU, INC. (formerly known as CONNECTU, LLC), PACIFIC NORTHWEST SOFTWARE, INC., WINSTON WILLIAMS, and WAYNE CHANG, Defendants. Case No. 5:07-CV-01389-JW PLAINTIFFS' ADMINISTRATIVE MOTION TO SEAL: (1) ADMINISTRATIVE REQUEST PURSUANT TO CIVIL L.R. 7-11; (2) DECLARATION OF I. NEEL CHATTERJEE AND EXHIBITS IN SUPPORT THEREOF; (3) PROPOSED ORDER GRANTING ADMINISTRATIVE REQUEST PURSUANT TO CIVIL L.R. 7-11 PLAINTIFFS ' MOTION TO SEAL CASE NO. 5:07-CV-01389-JW Dockets.Justia.com 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 Pursuant to Civil L.R. 7-11 and 79-5(d), Plaint iffs respectfully submit this administrative motion asking the Court to file under seal Plaintiffs' Administrative Request Pursuant to Civil L.R. 7-11; Declarat ion of I. Neel Chatterjee in Support Thereof; and Proposed Order Granting Administrative Request Pursuant To Civil L.R. 7-11. The parties entered into, and the California Superior Court issued, a Stipulated Protective Order on January 23, 2006, which prohibits either party from filing in the public record any documents that have been designated as "Confidential" or "Highly Confidential" pursuant to the Protective Order. Plaint iffs' Administrative Request, and all documents filed in support thereof, contain confidential information that is subject to the protection in the protective order. In light of the high profile nature of this case, and the parties' desire to keep the details of this Administrative Request private, Plaintiffs request that their Administrative Request and its supporting papers remain sealed. The subject matter discussed in these papers includes commercially sensitive and confidential information that, if released to the general public, will adversely affect the parties to this litigation. Dated: May 9, 2008 Orrick, Herrington & Sutcliffe LLP /s/ Theresa A. Sutton /s/ Theresa A. Sutton Attorneys for Plaintiffs FACEBOOK, INC. AND MARK ZUCKERBERG -1- PLAINTIFFS ' MOTION TO SEAL CASE NO. 5:07-CV-01389-JW 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 OHS West:260434215.1 CERTIFICATE OF SERVICE I hereby certify that this document(s) filed through the ECF system will be sent electronically to the registered participants as identified on the Notice of Electronic Filing (NEF) and paper copies will be sent to those indicated as non registered participants on May 9, 2008. Dated: May 9, 2008. Respect fully submitted, /s/ Theresa A. Sutton /s/ Theresa A. Sutton -2- PLAINTIFFS ' MOTION TO SEAL CASE NO. 5:07-CV-01389-JW

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