Elan Microelectronics Corporation v. Apple, Inc.

Filing 198

Administrative Motion to File Under Seal ELAN MICROELECTRONICS CORPORATION'S MOTION FOR PARTIAL SUMMARY JUDGMENT OF INFRINGEMENTS AND SUPPORTING DOCUMENTS filed by Elan Microelectronics Corporation. (Attachments: # 1 Declaration, # 2 Proposed Order)(Liu, Jennifer) (Filed on 5/5/2011)

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YITAI HU (SBN 248085)
[e-mail]
SEAN P. DEBRUINE (SBN 168071)
[e-mail]
ELIZABETH H. RADER (SBN 184963)
[e-mail]
JANE HAN BU (SBN 240081)
[e-mail]
JENNIFER LIU (SBN 268990)
[e-mail]
PALANI P. RATHINASAMY (SBN 269852)
[e-mail]
ALSTON & BIRD LLP
275 Middlefield Road, Suite 150
Menlo Park, CA 94025-4008
Telephone:
650-838-2000
Facsimile:
650-838-2001
Attorneys for Plaintiff and Counterdefendant
ELAN MICROELECTRONICS
CORPORATION

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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PLAINTIFF ELAN
MICROELECTRONICS
CORPORATION’S ADMINISTRATIVE
MOTION TO FILE PAPERS IN
SUPPORT OF ITS MOTION FOR
PARTIAL SUMMARY JUDGMENT OF
INFRINGEMENT UNDER SEAL;
DECLARATION OF JENNIFER LIU

Plaintiff,

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Case No. 09-cv-01531 RS (PSG)

ELAN MICROELECTRONICS
CORPORATION,

v.
APPLE, INC.,
Defendant.

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AND RELATED COUNTERCLAIMS

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ELAN’S ADMIN. MOT. TO FILE PAPERS ISO OF ITS MOT FOR
PARTIAL SUMMARY JUDGMENT OF INFRINGEMENT UNDER
SEAL; DECL. OF JENNIFER LIU

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Case No. 09-cv-01531 RS (PSG)

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Pursuant to Civil Local Rules 7-11 and 79-5, Plaintiff Elan Microelectronics Corporation

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(“Elan”) hereby requests leave of Court to file under seal the following documents which have

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been lodged with the Clerk:

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1.

Elan’s Motion for Partial Summary Judgment of Infringement of U.S. Patent

5,875,352;
2.

Declaration of Robert Dezmelyk in Support of Elan’s Motion for Partial Summary

Judgment of Infringement;
3.

Declaration of Jennifer Liu in Support of Elan’s Motion for Partial Summary

Judgment of Infringement;
4.

Exhibit 3 to the Declaration of Jennifer Liu in Support of Elan’s Motion for Partial

Summary Judgment of Infringement;
5.

Exhibit 4 to the Declaration of Jennifer Liu in Support of Elan’s Motion for Partial

Summary Judgment of Infringement;
6.

Exhibit 5 to the Declaration of Jennifer Liu in Support of Elan’s Motion for Partial

Summary Judgment of Infringement;
7.

Exhibit 6 to the Declaration of Jennifer Liu in Support of Elan’s Motion for Partial

Summary Judgment of Infringement;
8.

Exhibit 23 to the Declaration of Jennifer Liu in Support of Elan’s Motion for Partial

Summary Judgment of Infringement;
9.

Exhibit 24 to the Declaration of Jennifer Liu in Support of Elan’s Motion for Partial

Summary Judgment of Infringement;
10.

Exhibit 25 to the Declaration of Jennifer Liu in Support of Elan’s Motion for Partial

Summary Judgment of Infringement;
11.

Exhibit 27 to the Declaration of Jennifer Liu in Support of Elan’s Motion for Partial

Summary Judgment of Infringement;
12.

Exhibit 28 to the Declaration of Jennifer Liu in Support of Elan’s Motion for Partial

Summary Judgment of Infringement;

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ELAN’S ADMIN. MOT. TO FILE PAPERS ISO OF ITS MOT FOR
PARTIAL SUMMARY JUDGMENT OF INFRINGEMENT UNDER
SEAL; DECL. OF JENNIFER LIU

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Case No. 09-cv-01531 RS (PSG)

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13.

Exhibit 29 to the Declaration of Jennifer Liu in Support of Elan’s Motion for Partial

Summary Judgment of Infringement;
14.

Exhibit 30 to the Declaration of Jennifer Liu in Support of Elan’s Motion for Partial

Summary Judgment of Infringement;
15.

Exhibit 31 to the Declaration of Jennifer Liu in Support of Elan’s Motion for Partial

Summary Judgment of Infringement;
16.

Exhibit 32 to the Declaration of Jennifer Liu in Support of Elan’s Motion for Partial

Summary Judgment of Infringement;
17.

Exhibit 33 to the Declaration of Jennifer Liu in Support of Elan’s Motion for Partial

Summary Judgment of Infringement;
18.

Exhibit 34 to the Declaration of Jennifer Liu in Support of Elan’s Motion for Partial

Summary Judgment of Infringement;
19.

Exhibit 35 to the Declaration of Jennifer Liu in Support of Elan’s Motion for Partial

Summary Judgment of Infringement;
20.

Exhibit 36 to the Declaration of Jennifer Liu in Support of Elan’s Motion for Partial

Summary Judgment of Infringement;
21.

Exhibit 37 to the Declaration of Jennifer Liu in Support of Elan’s Motion for Partial

Summary Judgment of Infringement;
22.

Exhibit 38 to the Declaration of Jennifer Liu in Support of Elan’s Motion for Partial

Summary Judgment of Infringement;
23.

Exhibit 39 to the Declaration of Jennifer Liu in Support of Elan’s Motion for Partial

Summary Judgment of Infringement;
24.

Exhibit 40 to the Declaration of Jennifer Liu in Support of Elan’s Motion for Partial

Summary Judgment of Infringement;
25.

Exhibit 41 to the Declaration of Jennifer Liu in Support of Elan’s Motion for Partial

Summary Judgment of Infringement;
26.

Exhibit 42 to the Declaration of Jennifer Liu in Support of Elan’s Motion for Partial

Summary Judgment of Infringement;
ELAN’S ADMIN. MOT. TO FILE PAPERS ISO OF ITS MOT FOR
PARTIAL SUMMARY JUDGMENT OF INFRINGEMENT UNDER
SEAL; DECL. OF JENNIFER LIU

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Case No. 09-cv-01531 RS (PSG)

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27.

Exhibit 43 to the Declaration of Jennifer Liu in Support of Elan’s Motion for Partial

Summary Judgment of Infringement;
28.

Exhibit 44 to the Declaration of Jennifer Liu in Support of Elan’s Motion for Partial

Summary Judgment of Infringement;
29.

Exhibit 45 to the Declaration of Jennifer Liu in Support of Elan’s Motion for Partial

Summary Judgment of Infringement;
30.

Exhibit 47 to the Declaration of Jennifer Liu in Support of Elan’s Motion for Partial

Summary Judgment of Infringement.
As grounds for this motion, Elan states that Elan’s Motion for Partial Summary Judgment

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of Infringement, the Dezmelyk Declaration, the Liu Declaration and Exhibits 3-6, 23-25, 27-45,

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47 to the Liu Declaration constitute, or disclose information contained in, documents designated

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by Defendant Apple Inc. (“Apple”) as “Confidential − Attorney Eyes Only” or “Confidential –

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Attorneys Eyes Only – Source Code” pursuant to the Amended Protective Order in this matter.

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See Declaration of Jennifer Liu In Support Of Plaintiff Elan Microelectronics Corporation’s

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Motion To File Papers Under Seal filed concurrently herewith. As such, Elan is obligated to file

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those documents under seal.

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DATED: May 5, 2011

Respectfully submitted,
ALSTON & BIRD LLP

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By:

/s/ Jennifer Liu
Jennifer Liu
Attorneys for Plaintiff
ELAN MICROELECTRONICS CORPORATION

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ELAN’S ADMIN. MOT. TO FILE PAPERS ISO OF ITS MOT FOR
PARTIAL SUMMARY JUDGMENT OF INFRINGEMENT UNDER
SEAL; DECL. OF JENNIFER LIU

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Case No. 09-cv-01531 RS (PSG)