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

Filing 94

Declaration of Michael W. Trinh in Support of Plaintiffs' Miscellaneous Administrative Request to File Portions of Plaintiffs' Opposition to Defendants' Motion and Related Exhibits Under Seal 93 filed by Mark Zuckerberg, The Facebook, Inc. (Related document(s) 93 ) (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. 94 Case 5:07-cv-01389-RS Document 94 Filed 06/25/2007 Page 1 of 3 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 DECLARATION OF MICHAEL W. TRINH IN SUPPORT OF PLAINTIFFS' MISCELLANEOUS ADMINISTRATIVE REQUEST TO FILE PORTIONS OF PLAINTIFFS' OPPOSITION TO DEFENDANTS' MOTION AND RELATED EXHIBITS UNDER SEAL Judge: Honorable Richard Seeborg OHS West:260257723.1 TRINH DECLARATION ISO PLAINTIFFS ' MAR TO FILE UNDER SEAL 5:07-CV-01389-RS Dockets.Justia.com Case 5:07-cv-01389-RS Document 94 Filed 06/25/2007 Page 2 of 3 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 I, MICHAEL W. TRINH, hereby declare the following: 1. I am an attorney admitted to practice before the Supreme Court of California and this Court. I am an associate with the law firm of Orrick, Herrington & Sutcliffe LLP, counsel for Plaintiffs Facebook, Inc. and Mark Zuckerberg. I make this Declaration in support of Plaintiffs' Miscellaneous Administrative Request To File Portions of Plaintiffs' Opposition To Defendants' Motion To Dismiss For Lack of Personal Jurisdiction And Related Exhibits Under Seal. The matters contained in this declaration are of my own personal knowledge and, if called as a witness, I could and would testify competently to the matters set forth herein. 2. Portions of the Plaintiffs' Opposition To Defendants Pacific Northwest Software and Winston Williams' Motion To Dismiss For Lack Of Personal Jurisdiction ("Opposition") refer to or contain information that is confidential and proprietary to Plaintiffs or third parties, such as confident ial business information regarding Facebook, Inc. and personally identifiable information about third-party individuals. 3. Other redacted portions of the Opposition refer to or contain information that has been designated by Defendants pursuant to the Stipulated Protective Order in this case. 4. Exhibits 1 and 2 of the Declaration of Monte M.F. Cooper In Support of Plaintiff's Opposition to Defendants Pacific Northwest Software and Winston William's Motion To Dismiss for Lack of Personal Jurisdiction ("Cooper Decl.") refer to or contain information that is confidential and proprietary to Plaintiffs or third parties, such as confidential business information regarding Facebook, Inc. and personally identifiable information about third-party individuals. 5. Exhibits 7, 9, 11, 12, 13, 14, 16, 17, 19, 21, and 26 of the Cooper Declaration refer to or contain information that has been designated by Defendants pursuant to the Stipulated Protective Order in this case. /// /// /// /// OHS West:260257723.1 TRINH DECLARATION ISO PLAINTIFFS ' MAR TO FILE UNDER SEAL 5:07-CV-01389-RS Case 5:07-cv-01389-RS Document 94 Filed 06/25/2007 Page 3 of 3 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 I declare under penalty o f perjury under the laws of the United States of America that the foregoing is true and correct. Executed this 25th day of June 2007, in Menlo Park, California. /s/ Michael W. Trinh /s/ Michael W. Trinh OHS West:260257723.1 -2- TRINH DECLARATION ISO PLAINTIFFS ' MAR TO FILE UNDER SEAL 5:07-CV-01389-RS

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