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

Filing 456

MOTION for leave to file under Seal Document CONNECTU, INC.S ADMINISTRATIVE REQUEST FOR LEAVE TO FILE ADDITIONAL AUTHORITY filed by ConnectU LLC. (Holtzman, Steven) (Filed on 6/24/2008) Modified on 6/25/2008 (cv, COURT STAFF).

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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 STEVEN C. HOLTZMAN (CA BAR NO. 144177) sholtzman@bsfllp.com BOIES SCHILLER & FLEXNER LLP 1999 Harrison Street, Suite 900 Oakland, CA 94612 Telephone: (510) 874-1000 Facsimile: (510) 874-1460 D. MICHAEL UNDERHILL (pro hac vice) munderhill@bsfllp.com BOIES SCHILLER & FLEXNER LLP 5301 Wisconsin Avenue NW Washington, D.C. 20015 Telephone: (202) 237-2727 Facsimile: (202) 237-6131 Attorneys for Defendant CONNECTU, INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION THE FACEBOOK, INC. and MARK ZUCKERBERG, Plaintiffs, 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 CONNECTU'S ADMINISTRATIVE MOTION TO FILE UNDER SEAL CONNECTU, INC.'S ADMINISTRATIVE REQUEST FOR LEAVE TO FILE ADDITIONAL AUTHORITY CONNECTU'S MOTION TO SEAL 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 1 Pursuant to Civil L.R. 7-11 and 79-5(d), ConnectU respectfully submits this administrative motion asking the Court to file under seal ConnectU, Inc.'s Administrative Request for Leave to File Additional Authority. On June 23, 2008, the Court held a closed hearing in this matter due to concerns relating to the confidentiality of the terms of a settlement agreement, which were discussed at the hearing. The Administrative Request to File Additional Authority relates to, and contains information presented at, the closed hearing. 1 Although ConnectU believes the material in the Administrative Request and attached Submission of Additional Authority may not require sealing because it does not disclose terms of the settlement at issue, ConnectU requests that its Administrative Request to File a Additional Authority remain sealed because the hearing remains sealed. Dated: June 24, 2008 /s/ Steven C. Holtzman Steven C. Holtzman STEVEN C. HOLTZMAN (CA BAR NO. 144177) BOIES SCHILLER & FLEXNER LLP 1999 Harrison Street, Suite 900 Oakland, CA 94612 Telephone: (510) 874-1000 Facsimile: (510) 874-1460 Email: sholtzman@bsfllp.com D. MICHAEL UNDERHILL (pro hac vice) munderhill@bsfllp.com BOIES SCHILLER & FLEXNER LLP 5301 Wisconsin Avenue NW Washington, D.C. 20015 Telephone: (202) 237-2727 Facsimile: (202) 237-6131 Attorneys for Defendant CONNECTU, INC. By filing this request to seal, ConnectU does not waive any arguments or rights as to (i) the admissibility or inadmissibility of evidence surrounding the underlying purported agreement, (ii) the confidentiality or non-confidentiality of information relating to the purported agreement, or (iii) the enforceability or unenforceability of the purported agreement. 1 CONNECTU'S MOTION TO SEAL 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 Dated: June 24, 2008 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 24, 2008. /s/ Steven C. Holtzman Steven C. Holtzman 2 CONNECTU'S MOTION TO SEAL 5:07-CV-01389-JW

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