Elan Microelectronics Corporation v. Apple, Inc.

Filing 144

Declaration of Nathan Greenblatt in Support of 137 Administrative Motion to File Under Seal / Elan Microelectronics Corporation's Administrative Motion to File Papers in Support of its Opposition to Apple Inc.'s Motion to Dismiss Under Seal filed byApple, Inc.. (Related document(s) 137 ) (Greenblatt, Nathan) (Filed on 7/22/2010)

Elan Microelectronics Corporation v. Apple, Inc.

Doc. 144

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MATTHEW D. POWERS (Bar No. 104795) [e-mail] JARED BOBROW (Bar No. 133712) [e-mail] DOUGLAS E. LUMISH (Bar No. 183863) [e-mail] SONAL N. MEHTA (Bar No. 222086) [e-mail] DEREK C. WALTER (Bar. No. 246322) [e-mail] NATHAN GREENBLATT (Bar No. 262279) [e-mail] WEIL, GOTSHAL & MANGES LLP Silicon Valley Office 201 Redwood Shores Parkway Redwood Shores, CA 94065 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant and Counterclaim Plaintiff Apple Inc. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION ELAN MICROELECTRONICS CORPORATION, Plaintiff and Counterclaim Defendant, v. APPLE INC., Defendant and Counterclaim Plaintiff. Case No. C-09-01531 RS (PVT) DECLARATION OF NATHAN GREENBLATT IN SUPPORT OF ELAN MICROELECTRONICS CORP.'S ADMINISTRATIVE MOTION TO FILE PAPERS UNDER SEAL [D.I. 137] JURY TRIAL DEMANDED Hon. Richard Seeborg

DECLARATION OF NATHAN GREENBLATT ISO ADMINISTRATIVE MOTION TO FILE PAPERS UNDER SEAL

Case No. C-09-01531 RS (PVT)

Dockets.Justia.com

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I, Nathan Greenblatt, declare: 1. I am an attorney with the law firm of Weil, Gotshal & Manges LLP,

counsel of record for Defendant and Counter-Claimant Apple Inc. ("Apple") in the abovecaptioned matter. I submit this declaration based on personal knowledge and following a

reasonable investigation. If called upon as a witness, I could competently testify to the truth of each statement herein. 2. I have reviewed Exhibits B, D, E, M, R, S, T, and U to the Declaration of

Sean P. DeBruine in Support of Elan's Opposition to Apple Inc.'s Motion to Dismiss ("DeBruine Declaration"). 3. Exhibit B to the DeBruine Declaration contains excerpts from the

deposition of Mark Della Bona, a former Apple employee, that contains information about confidential Apple license agreements and Mr. Della Bona's work at Apple. This information contains sensitive business information which could harm Apple if publicly disclosed. 4. Exhibits D and E to the DeBruine Declaration contain engineering

specifications relating to the GlidePoint® product that are labelled as "Confidential and Proprietary." Apple received permission from outside counsel for Cirque to produce those

documents as confidential pursuant to the terms of the protective order in this case. 5. Exhibits T and U to the DeBruine Declaration contain information

reflecting a confidential business agreement between Apple and third party Proxima, Inc. These exhibits contain sensitive business information that could harm Apple and/or Cirque Corp. (the successor to Proxima, Inc.) if publicly disclosed. 6. Exhibits M, R, and S appear to be newspaper articles with some

annotations. Apple is withdrawing its confidentiality designation for Exhibits M, R, and S. I declare under the penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on July 22, 2010, at Redwood Shores, California. /s/ Nathan Greenblatt Nathan Greenblatt
DECLARATION OF NATHAN GREENBLATT ISO ADMINISTRATIVE MOTION TO FILE PAPERS UNDER SEAL

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Case No. C-09-01531 RS (PVT)