Elan Microelectronics Corporation v. Apple, Inc.

Filing 211

Administrative Motion to File Under Seal Exhibits to the Declaration of Palani P. Rathinasamy in Support of Plaintiff Elan Microelectronics Corporation's Motion to Compel Apple to Supplement Its Response to Elan's Interrogatory No. 13 filed by Elan Microelectronics Corporation. (Attachments: # 1 Declaration, # 2 Proposed Order)(Rathinasamy, Palani) (Filed on 5/24/2011)

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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 FRANCISCO DIVISION

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PLAINTIFF ELAN
MICROELECTRONICS
CORPORATION’S ADMINISTRATIVE
MOTION TO FILE UNDER SEAL
EXHIBITS TO THE DECLARATION
OF PALANI P. RATHINASAMY IN
SUPPORT OF PLAINTIFF ELAN
MICROELECTRONICS
CORPORATION’S MOTION TO
COMPEL APPLE TO SUPPLEMENT
ITS RESPONSE TO ELAN’S
INTERROGATORY NO. 13

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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PL. ELAN’S ADMIN. MOT. TO FILE UNDER SEAL EXHIBITS
TO THE DECL. OF PALANI P. RATHINASAMY IN SUPPORT
OF PL. ELAN’S MOT. TO COMPEL APPLE TO SUPPL. ITS
RESPONSE TO ELAN’S INTERROG. NO. 13

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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.

Exhibit B to the Declaration of Palani P. Rathinasamy (filed under seal);

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2.

Exhibit E to the Declaration of Palani P. Rathinasamy (filed under seal);

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3.

Exhibit F to the Declaration of Palani P. Rathinasamy (filed under seal);

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4.

Exhibit G to the Declaration of Palani P. Rathinasamy (filed under seal);

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5.

Exhibit H to the Declaration of Palani P. Rathinasamy (filed under seal);

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6.

Exhibit I to the Declaration of Palani P. Rathinasamy (filed under seal);

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7.

Exhibit J to the Declaration of Palani P. Rathinasamy (filed under seal);

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8.

Exhibit L to the Declaration of Palani P. Rathinasamy (filed under seal);

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9.

Exhibit M to the Declaration of Palani P. Rathinasamy (filed under seal).

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As grounds for this motion, Elan states that these Exhibits constitute, or disclose

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information contained in, or derived from, documents designated by the parties as “Confidential −

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Attorneys’ Eyes Only” pursuant to the Amended Protective Order in this matter. As explained in

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the Declaration of Palani P. Rathinasamy In Support of Plaintiff Elan Microelectronics

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Corporation’s Motion To File Under Seal Exhibits to the Declaration of Palani P. Rathinasamy,

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good cause exists to file these exhibits under seal as the exhibits contain confidential information.

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These exhibits predominately consist of sealable information such that it may be appropriate to

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seal the entire document rather than requiring submission of a heavily redacted document that

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would not substantially further the policy of providing public access to, and understanding of,

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court proceedings.

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For the reasons stated above, the Court should grant Elan leave to file the above identified
documents entirely under seal.

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PL. ELAN’S ADMIN. MOT. TO FILE UNDER SEAL EXHIBITS
TO THE DECL. OF PALANI P. RATHINASAMY IN SUPPORT
OF PL. ELAN’S MOT. TO COMPEL APPLE TO SUPPL. ITS
RESPONSE TO ELAN’S INTERROG. NO. 13

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

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DATED: May 24, 2011

Respectfully submitted,
ALSTON & BIRD LLP

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By:

/s/ Palani P. Rathinasamy
Palani P. Rathinasamy
Attorneys for Plaintiff
ELAN MICROELECTRONICS CORPORATION

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PL. ELAN’S ADMIN. MOT. TO FILE UNDER SEAL EXHIBITS
TO THE DECL. OF PALANI P. RATHINASAMY IN SUPPORT
OF PL. ELAN’S MOT. TO COMPEL APPLE TO SUPPL. ITS
RESPONSE TO ELAN’S INTERROG. NO. 13

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