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

Filing 401

MOTION to Seal Opposition TO 393 MOTION and the declaration of T. Sutton in support thereof filed by Mark Zuckerberg, The Facebook, Inc.. (Attachments: # 1 Proposed Order)(Sutton, Theresa) (Filed on 5/29/2008) Modified on 5/29/2008 (cv, COURT STAFF).

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

Doc. 40

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 [e-mail] I. NEEL CHATTERJEE (State Bar No. 173985) [e-mail] MONTE COOPER (State Bar No. 196746) [e-mail] m THERESA A. SUTTON (State Bar No. 211857) [e-mail] YVONNE P. GREER (State Bar No. 214072) [e-mail] m ORRICK, HERRINGTON & SUTCLIFFE LLP 1000 Marsh Road Menlo Park, CA 94025 Telephone: [phone] 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) PLAINTIFFS' OPPOSITION TO CONNECTU'S [MAY 23, 2008] ADMINISTRATIVE REQUEST PURSUANT TO CIVIL L.R. 7-11 (2) [PROPOSED] ORDER DENYING CONNECTU'S [MAY 23, 2008] ADMINISTRATIVE REQUEST PURSUANT TO CIVIL L.R. 7-11 (3) DECLARATION OF THERESA SUTTON IN SUPPORT OF PLAINTIFFS' OPPOSITION TO CONNECTU'S [MAY 23, 2008] 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 (1) Plaintiffs' Opposition To ConnectU's [May 23, 2008] Administrative Request Pursuant To Civil L.R. 7-11; (2) [Proposed] Order Denying ConnectU's [May 23, 2008] Administrative Request Pursuant To Civil L.R. 7-11; and (3) Declaration Of Theresa Sutton In Support Of Plaintiffs' Opposition To ConnectU's [May 23, 2008] 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 Confident ial" pursuant to the Protective Order. Plaint iffs' Opposition To ConnectU's [May 23, 2008] Administrative Request Pursuant To Civil L.R. 7-11, and all documents filed in support thereof, contains 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 these documents private, Plaintiffs request that their Administrative Request and its supporting papers remain sealed. The subject matter discussed in these papers includes co mmercially sensitive and confidential information that, if released to the general public, will adversely affect the parties to this litigation.

Dated: May 29, 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:260447236.1

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 29, 2008. Dated: May 29, 2008. Respect fully submitted, /s/ Theresa A. Sutton /s/ Theresa A. Sutton

-2-

PLAINTIFFS ' MOTION TO SEAL CASE NO. 5:07-CV-01389-JW