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

Filing 730

MOTION to Seal Exhibit A to Facebook, Inc. and Mark Zuckerberg's Joinder filed by The Facebook, Inc., Mark Zuckerberg. (Attachments: # 1 [Proposed] Order)(Sutton, Theresa) (Filed on 12/23/2009) Modified on 12/23/2009 (cv, COURT STAFF).

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

Doc. 730

Case5:07-cv-01389-JW Document730

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I. NEEL CHATTERJEE (State Bar No. 173985) [e-mail] MONTE COOPER (State Bar No. 196746) [e-mail] THERESA A. SUTTON (State Bar No. 211857) [e-mail] YVONNE P. GREER (State Bar No. 214072) [e-mail] 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, 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 FACEBOOK, INC.'S ADMINISTRATIVE MOTION TO SEAL EXHIBIT A TO FACEBOOK, INC. AND MARK ZUCKERBERG'S JOINDER IN CONNECTU'S RENEWED REQUEST FOR HEARING DATE RELATING TO PRODUCTION OF CONNECTU'S DOCUMENTS

OHS West:260800734.1

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

Dockets.Justia.com

Case5:07-cv-01389-JW Document730

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Pursuant to Fed. R. Civ. P. 26, Civil L.R. 7-11 and 79-5(d), as well as this Court's Order dated July 2, 2008 Setting Conditions with Respect to Access to Materials Previously Filed in this Case [Doc. No. 473], Plaintiffs respectfully submit this administrative motion asking the Court to file under seal Exhibit A to Facebook, Inc. and Mark Zuckerberg's Joinder in ConnectU's Renewed Request for Hearing (Docket No. 727). The materials attached to Facebook's Joinder as Exhibit A were designated as confidential by Quinn Emanuel and, thus, are subject to the Stipulated Protective Order entered into on January 23, 2006, which prohibits any party from filing in the public record documents that have been designated as "Confidential." The parties also entered into a separate "Second Stipulated Protective Order" in ConnectU LLC v. Zuckerberg, Case No. 1:04-cv-11923 (D. Mass.), signed by the Honorable Douglas Woodlock on July 6, 2005, which has governed filings in related actions among the parties in the District of Massachusetts, including Exhibit A. Further, the use and disclosure of some of these materials is governed by the District of Massachusetts' Order for Discovery of Computer Memory Devices. Accordingly, good cause and compelling reasons exist to file these designated materials under seal. Dated: December 23, 2009 Orrick, Herrington & Sutcliffe LLP /s/ Theresa A. Sutton /s/ Theresa A. Sutton Attorneys for Plaintiffs FACEBOOK, INC. MARK ZUCKERBERG

OHS West:260800734.1

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

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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 December 23, 2009. Dated: December 23, 2009. Respectfully submitted, /s/ Theresa A. Sutton /s/ Theresa A. Sutton

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