Elan Microelectronics Corporation v. Apple, Inc.
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)
2 JARED BOBROW (Bar No. 133712)
3 SONAL N. MEHTA (Bar No. 222086)
4 DEREK C. WALTER (Bar. No. 246322)
STEFANI SMITH (Bar No. 251305)
6 NATHAN GREENBLATT (Bar No. 262279)
7 WElL, GOTSHAL & MANGES LLP
Silicon Valley Office
8 201 Redwood Shores Parkway
Redwood Shores, CA 94065
Telephone: (650) 802-3000
Facsimile: (650) 802-3100
Attorneys for Defendant and Counterclaim Plaintiff
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
Plaintiff and Counterclaim
19 APPLE INC.,
Case No. C-09-01531 RS (PSG)
DECLARATION OF SONAL N.
MEHTA IN SUPPORT OF
ADMINISTRATIVE MOTION TO
FILE UNDER SEAL THE ITC'S
Hon. Richard Seeborg
Defendant and Counterclaim
DECLARATION OF SONAL MEHTA IN SUPPORT OF
ADMINISTRATIVE MOTION TO FILE UNDER SEAL
Case No. C-09-0I53I RS (PSO)
I, Sonal N. Mehta, declare:
I am an associate at Weil, Gotshal & Manges LLP, counsel of record for
Defendant and Counter-Claimant Apple Inc. ("Apple") in the above-captioned matter. I submit
this declaration pursuant to Civil Local Rules 7-5(a), 7-11, and 79-5 and in support of Apple's
Administrative Motion To File Under Seal April 29, 2011 Final Initial and Recommended
Determination of the United States International Trade Commission in Investigation No. 337-TA-
714, attached as Exhibit A to Apple's May 3, 2011 letter to the Court.
The April 29, 2011 Final Initial and Recommended Determination of the
United States International Trade Commission in Investigation No. 337-TA-714 includes
confidential business information of the parties, including confidential information related to the
operation of Apple's products and confidential information related to Elan's business practices.
Such information has been designated by the parties in this case as "Confidential" or
"Confidential—Attorneys Eyes Only" pursuant to the Protective Order entered in this case.
The United States International Trade Commission has designated the
April 29, 2011 Final Initial and Recommended Determination of the United States International
Trade Commission in Investigation No. 337-TA-714 as including confidential business
I declare under penalty of perjury of the laws of the United States of America that
the foregoing is true and correct and that the foregoing is executed on May 3, 2011, at Redwood
WElL, GOTSHAL & MANGES LLP
Is! Sonal N. Mehia
Sonal N. Mehta
Attorney for Defendant and Counter-Claimant,
DECLARATION OF SONAL N. MEHTA IN SUPPORT OF
ADMINISTRA I IVL MOTION TO FILE UNDER SEAL
Case No, C-09-01531 RS (PSG)
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