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

Filing 415

*** FILED IN ERROR. PLEASE SEE DOCKET # 425 . *** MOTION to Seal Reply Brief in Support of Motion to Quash and for Protective Order, and Corrected Declaration filed by R. Gregory Roussel, Fenwick & West LLP. (Attachments: # 1 Proposed Order)(Lui-Kwan, Kalama) (Filed on 6/9/2008) Modified on 6/10/2008 (ewn, COURT STAFF).

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The Facebook, Inc. v. Connectu, LLC et al Doc. 41 1 2 3 4 5 6 7 8 9 10 11 12 FENWICK & W EST LLP A TTORNEYS AT L AW S AN F RANCISCO TYLER BAKER (CSB NO. 65109) FENWICK & WEST LLP Silico n Valley Center 801 California Street Mountain View, CA 94041 Telephone: (650) 988-8500 Facsimile: (650) 938-5200 tbaker@fenwick.com KALAMA M. LUI-KWAN (CSB NO. 242121) FENWICK & WEST LLP 555 California Street, 12th Floor San Francisco, CA 94104 Telephone: (415) 875-2300 Facsimile: (415) 281-1350 klui-kwan@fenwick.com Attorneys for Non-Parties Fenwick & West LLP and R. Gregory Roussel UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MOTION TO SEAL THE 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 ADMINISTRATIVE MOTION BY NONPARTIES R. GREGORY ROUSSEL AND FENWICK & WEST LLP TO SEAL: (1) REPLY IN SUPPORT OF MOTION TO QUASH AND FOR PROTECTIVE ORDER; (2) CORRECTED DECLARATION OF KALAMA M. LUI-KWAN IN SUPPORT OF MOTION TO QUASH AND FOR PROTECTIVE ORDER CASE NO. 5:07-CV-01389-JW Dockets.Justia.com 1 2 3 4 5 6 7 8 9 10 11 12 FENWICK & W EST LLP A TTORNEYS AT L AW S AN F RANCISCO Pursuant to Civil L.R. 7-11 and 79-5(d), non-parties R. Gregory Roussel and Fenwick & West LLP (together, "Fenwick") respectfully submit this administrative motion asking the Court to file under seal: (1) Reply in Support of Motion to Quash and for Protective Order; and (2) Corrected Declaration of Kalama M. Lui-Kwan in Support of Motion to Quash ("Reply Papers"). The parties in this action entered into, and the California Superior Court issued, a Stipulated Protective Order on January 23, 2006, which prohibits either party fro m filing in the public record any documents that have been designated as "Confidential" or "Highly Confidential" pursuant to the Protective Order. Although Fenwick is not a party to this action, it has represented Facebook, Inc. ("Facebook") in connection with certain matters related to Facebook's settlement of this action. The Reply Papers 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 these documents private, Fenwick requests that the Reply Papers remain sealed. The subject matter discussed in these papers includes commercially sensit ive and confidential information that, if released to the general public, will adversely affect the parties to this litigation. Dated: June 9, 2008 FENWICK & WEST LLP By: /s/ Kalama M. Lui-Kwan Kalama M. Lui-Kwan Attorneys for Non-Parties Fenwick & West LLP and R. Gregory Roussel 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 26246/00400/DOCS/1922114.1 MOTION TO SEAL CASE NO. 5:07-CV-01389-JW

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