Elan Microelectronics Corporation v. Apple, Inc.

Filing 195

Administrative Motion to File Under Seal filed by Apple, Inc.. (Attachments: # 1 Declaration, # 2 Proposed Order)(Mehta, Sonal) (Filed on 5/3/2011)

1 MATTHEW D. POWERS (Bar No. 104795)
[e-mail]
2 JARED BOBROW (Bar No. 133712)
jared.bobrowweil.com
3 SONAL N. MEHTA (Bar No. 222086)
[e-mail]
4 DEREK C. WALTER (Bar. No. 246322)
[e-mail]
5
STEFANI SMITH (Bar No. 251305)
[e-mail]
6 NATHAN GREENBLATT (Bar No. 262279)
[e-mail]
7 WElL, GOTSHAL & MANGES LLP
Silicon Valley Office
8 201 Redwood Shores Parkway
Redwood Shores, CA 94065
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Telephone: [phone]
Facsimile: [phone]
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Attorneys for Defendant and Counterclaim Plaintiff
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Apple Inc.
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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ELAN MICROELECTRONICS
CORPORATION,

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Plaintiff and Counterclaim
Defendant,

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V.

19 APPLE INC.,
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Case No. C-09-01531 RS (PSG)
DECLARATION OF SONAL N.
MEHTA IN SUPPORT OF
ADMINISTRATIVE MOTION TO
FILE UNDER SEAL THE ITC'S
INITIAL DETERMINATION
Hon. Richard Seeborg

Defendant and Counterclaim
Plaintiff.

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DECLARATION OF SONAL MEHTA IN SUPPORT OF
ADMINISTRATIVE MOTION TO FILE UNDER SEAL

Case No. C-09-0I53I RS (PSO)

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I, Sonal N. Mehta, declare:

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1.

I am an associate at Weil, Gotshal & Manges LLP, counsel of record for

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Defendant and Counter-Claimant Apple Inc. ("Apple") in the above-captioned matter. I submit

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this declaration pursuant to Civil Local Rules 7-5(a), 7-11, and 79-5 and in support of Apple's

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Administrative Motion To File Under Seal April 29, 2011 Final Initial and Recommended

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Determination of the United States International Trade Commission in Investigation No. 337-TA-

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714, attached as Exhibit A to Apple's May 3, 2011 letter to the Court.

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2.

The April 29, 2011 Final Initial and Recommended Determination of the

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United States International Trade Commission in Investigation No. 337-TA-714 includes

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confidential business information of the parties, including confidential information related to the

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operation of Apple's products and confidential information related to Elan's business practices.

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Such information has been designated by the parties in this case as "Confidential" or

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"Confidential—Attorneys Eyes Only" pursuant to the Protective Order entered in this case.

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3.

The United States International Trade Commission has designated the

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April 29, 2011 Final Initial and Recommended Determination of the United States International

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Trade Commission in Investigation No. 337-TA-714 as including confidential business

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information.

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I declare under penalty of perjury of the laws of the United States of America that

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the foregoing is true and correct and that the foregoing is executed on May 3, 2011, at Redwood

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Shores, California.

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DATED: May3,2011

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Respectfully submitted,
WElL, GOTSHAL & MANGES LLP

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Is! Sonal N. Mehia
Sonal N. Mehta
Attorney for Defendant and Counter-Claimant,
Apple Inc.

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DECLARATION OF SONAL N. MEHTA IN SUPPORT OF
ADMINISTRA I IVL MOTION TO FILE UNDER SEAL

Case No, C-09-01531 RS (PSG)