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

Filing 426

MOTION to Seal Document 421 Declaration of I.N.Chatterjee in Support, 424 Objections to motion to strike evidence re: 333 confidential motion , 420 Reply Memorandum in support of 333 Confidential , 422 Declaration of A. Sarin, PH.D in Support, 423 Declaration of T. Wang in Support filed by Mark Zuckerberg, The Facebook, Inc.. (Attachments: # 1 Proposed Order)(Chatterjee, I.) (Filed on 6/9/2008) Modified text on 6/10/2008 (cv, COURT STAFF).

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

Doc. 42

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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' REPLY IN SUPPORT OF CONFIDENTIAL MOTION; (2) DECLARATION OF I. NEEL CHATTERJEE AND EXHIBITS IN SUPPORT THEREOF; (3) DECLARATION OF ATULYA SARIN, PH.D. AND EXHIBITS IN SUPPORT THEREOF; (4) DECLARATION OF TED WANG IN SUPPORT THEREOF; (5) PLAINTIFFS' OBJECTIONS TO AND MOTION TO STRIKE EVIDENCE SUBMITTED IN CONNECTU'S OPPOSITION TO PLAINTIFFS' CONFIDENTIAL MOTION.
PLAINTIFFS ' MOTION TO SEAL CASE NO. 5:07-CV-01389-JW

Dockets.Justia.com

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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' Reply in Support of Confidential Motion; (2) Declaration of I. Neel Chatterjee and Exhibits in Support Thereof; (3) Declaration of Atulya Sarin, PhD. and Exhibits in Support Thereof; and (4) Declaration of Ted Wang in Support Thereof; and (5) Plaintiffs' Object ions to and Motion to Strike Evidence Submitted in ConnectU's Opposition to Plaintiffs' Confident ial Motion. 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' Reply in Support of Confidential Motion, all documents filed in support thereof, and Plaintiffs' Objections to and Motion to Strike Evidence Submitted in ConnectU's Opposition to Plaintiffs' Confidential Motion, 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 Reply in Support of Confidential Motion, all documents filed in support thereof, and Plaintiffs' Objections to and Motion to Strike Evidence Submitted in ConnectU's Opposition to Plaintiffs' Confidential Motion remain sealed. The subject matter discussed in these papers includes commercially sensit ive and confidential informat ion that, if released to the general public, will adversely affect the parties to this litigation.

Dated: June 9, 2008

Orrick, Herrington & Sutcliffe LLP /s/ Theresa A. Sutton /s/ Theresa A. Sutton Attorneys for Plaintiffs FACEBOOK, INC. AND MARK ZUCKERBERG

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

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OHS West:260452463.1 16069-4 A3D/HTT

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 June 9, 2008. Dated: June 9, 2008. Respect fully submitted, /s/ Theresa A. Sutton /s/ Theresa A. Sutton

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