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

Filing 93

Plaintiff's Miscellaneous Administrative Request to File Portions of Plaintiffs' Opposition to Defendants' Motion to Dismiss and Related Exhibits Under Seal filed by Mark Zuckerberg, The Facebook, Inc. (Attachments: # 1 Proposed Order)(Cooper, Monte) (Filed on 6/25/2007) Text modified on 6/26/2007 to conform to document caption post by counsel (bw, COURT STAFF).

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The Facebook, Inc. v. Connectu, LLC et al Doc. 93 Case 5:07-cv-01389-RS Document 93 Filed 06/25/2007 Page 1 of 4 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 G. HOPKINS GUY, III (State Bar No. 124811) hopguy@orrick.co m I. NEEL CHATTERJEE (State Bar No. 173985) nchatterjee@orrick.com MONTE COOPER (State Bar No. 196746) mcooper@orrick.co m THERESA A. SUTTON (State Bar No. 211857) tsutton@orrick.com YVONNE P. GREER (State Bar No. 214072) ygreer@orrick.com ORRICK, HERRINGTON & SUTCLIFFE LLP 1000 Marsh Road Menlo Park, CA 94025 Telephone: 650-614-7400 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), CAMERON WINKLEVOSS, TYLER WINKLEVOSS, DIVYA NARENDRA, PACIFIC NORTHWEST SOFTWARE, INC., WINSTON WILLIAMS, WAYNE CHANG, and DAVID GUCWA AND DOES 1-25, Defendants. Case No. 5:07-CV-01389-RS PLAINTIFFS' MISCELLANEOUS ADMINISTRATIVE REQUEST TO FILE PORTIONS OF PLAINTIFFS' OPPOSITION TO DEFENDANTS' MOTION TO DISMISS AND RELATED EXHIBITS UNDER SEAL Judge: Honorable Richard Seeborg OHS West:260257700.1 PLAINTIFF 'S MAR TO FILE UNDER SEAL 5:07-CV-01389-RS Dockets.Justia.com Case 5:07-cv-01389-RS Document 93 Filed 06/25/2007 Page 2 of 4 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. 79-5, Plaintiffs Facebook, Inc. and Mark Zuckerberg request the Court order that portions of Plaintiffs' Opposition to Defendants Pacific Northwest Software and Winston William's Motion To Dismiss for Lack of Personal Jurisdiction ("Opposition"), and certain exhibits of the Declaration of Monte M. F. Cooper in Support Thereof ("Cooper Declaration") be filed under seal, based on this Miscellaneous Administrative Request, the supporting Declaration of Michael W. Trinh In Support of Plaintiffs' Miscellaneous Administrative Request To File Plaintiffs' Opposition To Defendants' Motion To Dismiss And Related Exhibits Under Seal ("Trinh MAR Decl."), and a [Proposed] Order, attached herewith. Under Civil Local Rule 79-5, a document may only be filed under seal upon a showing of good cause. Certain portions of the Opposition refer to or contain information that is confidential and proprietary to Plaintiffs, or personally ident ifiable information about third party individuals. See Trinh MAR Decl. 2. Other portions of the Opposition refer to or contain confidential information that has been designated by defendants pursuant to the Stipulated Protective Order in this case. See Trinh MAR Decl. 3. Plaintiffs are lodging herewith a redacted version of the Opposition. Accordingly, good cause exists to seal these portions of the Opposition. Certain exhibits of the Cooper Declaration refer to or contain information that is confidential and proprietary to Plaintiffs, or personally identifiable information about third party individuals. See Trinh MAR Decl. 4. Certain exhibits of the Cooper Declaration refer to or contain confidential information that has been designated by defendants pursuant to the Stipulated Protective Order in this case. See Trinh MAR Decl. 5. Accordingly, good cause exists to seal those exhibits of the Cooper Declaration. Accordingly, Plaintiffs respectfully request the Court order that certain portions of the Opposition and certain exhibits of the Cooper Declaration be filed under seal, as specified in the attached [Proposed] Order. /// /// OHS West:260257700.1 -1- PLAINTIFF 'S MAR TO FILE UNDER SEAL 5:07-CV-01389-RS Case 5:07-cv-01389-RS Document 93 Filed 06/25/2007 Page 3 of 4 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 25, 2007 ORRICK, HERRINGTON & SUTCLIFFE LLP /s/ Monte M.F. Cooper /s/ Monte M.F. Cooper Attorneys for Plaintiffs FACEBOOK, INC. and MARK ZUCKERBERG OHS West:260257700.1 -2- PLAINTIFF 'S MAR TO FILE UNDER SEAL 5:07-CV-01389-RS Case 5:07-cv-01389-RS Document 93 Filed 06/25/2007 Page 4 of 4 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:260257700.1 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 June 25, 2007. Dated: June 25, 2007. Respect fully submitted, /s/ Monte M.F. Cooper /s/ Monte M.F. Cooper -3- PLAINTIFF 'S MAR TO FILE UNDER SEAL 5:07-CV-01389-RS

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