Hovsepian v. Apple, Inc.

Filing 967

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Hovsepian v. Apple, Inc. Doc. 967 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 DECHERT L L P AT T O R N E Y S AT L A W P A L O AL T O Chris Scott Graham (State Bar No. 114498) chris.scott.graham@dechert.com Michael N. Edelman (State Bar No. 180948) michael.edelman@dechert.com DECHERT LLP 1117 California Avenue Palo Alto, CA 94304-1106 Telephone: 650.813.4800 Facsimile: 650.813.4848 Attorneys for Plaintiff and Counter-Defendant, SYNOPSYS, INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION SYNOPSYS, INC., a Delaware corporation, Plaintiff and Counter-Defendant, v. MAGMA DESIGN AUTOMATION, a Delaware corporation, Defendant and Counter-Claimant. AND RELATED CROSS-ACTIONS. Case No. C-04-03923 MMC (JCS) PLAINTIFF SYNOPSYS, INC.'S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL PURSUANT TO CIVIL LOCAL RULES 7-11 AND 79-5 RELATING TO OPENING CLAIM CONSTRUCTION BRIEF /// /// /// /// /// /// /// /// /// SYNOPSYS ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL RELATING TO OPENING CLAIM CONSTRUCTION BRIEF; CASE NO.: C-04-03923 MMC (JCS) 9771248.1.LIT Dockets.Justia.com 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 DECHERT L L P AT T O R N E Y S AT L A W P A L O AL T O Plaintiff Synopsys, Inc. ("Synopsys") hereby requests, pursuant to Civil Local Rules 7-11 and 79-5, an Order sealing the following documents lodged with the Court in connection with Synopsys' Opening Claim Construction Brief: 1. Synopsys' Opening Claim Construction Brief, at 7:25-8:5, 16:8-14, 21:10-18 contains information cited and quoted from documents that have been designated by the parties and are simultaneously being lodged under seal. 2. The Declaration of Michael N. Edelman In Support Of Plaintiff Synopsys' Opening Claim Construction Brief (the "Edelman Declaration"), at Paragraphs 5 and 14 contains information summarized and/or quoted from documents that have been designated by the parties and are simultaneously being lodged under seal. 3. Exhibit D to the Edelman Declaration contains a letter from David A. Jakopin from the Pillsbury law firm to Elizabeth Roemer, Magma's in- house counsel, bearing Bates number MAGMA0068232. Although Synopsys disagrees that this document contains confidential information, Magma has designated the document "Attorneys and Consultants Only." For this reason Synopsys requests that the document be filed under seal. 4. Exhibit E to the Edelman Declaration is an email from David A. Jakopin to Lukas van Ginneken, bearing Bates number MAGMA0067270. Although Synopsys disagrees that this document contains confidential information, Magma has designated the document "Attorneys and Consultants Only." 5. Exhibit N to the Edelman Declaration is an email chain between David A. Jakopin and Lukas van Ginneken, bearing Bates number MAGMA0067271-MAGMA0067271.2. Although Synopsys disagrees this document contains any confidential information, Magma has designated it "Attorneys and Consultants Only." Accordingly, Synopsys respectfully requests that this document be filed under seal. 6. The Declaration of David Harris In Support Of Plaintiff Synopsys' Opening Claim Construction Brief (the "Harris Declaration"), at Paragraphs 86 and 87 contains information summarized and/or quoted from documents that have been designated by the parties and are simultaneously being lodged under seal. SYNOPSYS ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL RELATING TO OPENING CLAIM CONSTRUCTION BRIEF; CASE NO.: C-04-03923 MMC (JCS) 1 9771248.1.LIT 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 DECHERT L L P AT T O R N E Y S AT L A W P A L O AL T O 7. Exhibit S to the Harris Declaration is a document entitled "Physical Design Strategy" bearing Bates number MAGMA0123415-MAGMA0123432. Magma has designated the document "Confidential Attorneys and Consultants Only." For this reason, Synopsys respectfully requests that it be filed under seal. 8. Exhibit T to the Harris Declaration is a document entitled "Methodology Plan" bearing Bates number MAGMA0123222-MAGMA0123251. Magma has designated the document "Confidential Attorneys and Consultants Only." For this reason, Synopsys respectfully requests that it be filed under seal. 9. Exhibit U to the Harris Declaration is a document entitled "Bucket Equalization" bearing Bates number MAGMA0140192-MAGMA0140197. Magma has designated the document "Confidential Attorneys and Consultants Only." For this reason, Synopsys respectfully requests that it be filed under seal. For the foregoing reasons, Synopsys respectfully requests that the Court grant this motion to seal the above referenced document containing information that Synopsys and Magma claim is highly sensitive business confidential and/or proprietary information. Synopsys and Magma have an overriding interest in protecting the disclosure of this allegedly sensitive and confidential information. The sealing of the aforementioned documents is appropriate under Local Rule 79-5. A substantial probability exists that the overriding interest will be prejudiced if the records are not sealed. The proposed sealing is narrowly tailored (Synopsys seeks a narrowly tailored order to have sealed only those documents separately lodged with this Court for which sealing is appropriate). There are no less restrictive means to achieve the overriding interest. A Proposed Order is being filed and served herewith. Dated: July 7, 2005 DECHERT LLP By: /s/ Michael N. Edelman Chris Scott Graham Michael N. Edelman Attorneys for Plaintiff and Counter-Defendant, SYNOPSYS, INC. SYNOPSYS ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL RELATING TO OPENING CLAIM CONSTRUCTION BRIEF; CASE NO.: C-04-03923 MMC (JCS) 2 9771248.1.LIT

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