Elan Microelectronics Corporation v. Apple, Inc.

Filing 235

Declaration of Nathan Greenblatt in Support of 234 Administrative Motion to File Under Seal [APPLE INC.'S OPPOSITION TO ELAN'S MOTION FOR PARTIAL SUMMARY JUDGMENT OF INFRINGEMENT OF US PATENT NO. 5,825,352 AND SUPPORTING DOCUMENTS] Administrative Motion to File Under Seal [APPLE INC.'S OPPOSITION TO ELAN'S MOTION FOR PARTIAL SUMMARY JUDGMENT OF INFRINGEMENT OF US PATENT NO. 5,825,352 AND SUPPORTING DOCUMENTS] filed byApple, Inc.. (Related document(s) 234 ) (Greenblatt, Nathan) (Filed on 6/2/2011)

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MATTHEW D. POWERS (Bar No. 104795)
[e-mail]
JARED BOBROW (Bar No. 133712)
[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]

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Attorneys for Defendant and Counterclaim Plaintiff
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.
APPLE INC.,

Case No. C-09-01531 RS (PSG)
DECLARATION OF NATHAN
GREENBLATT IN SUPPORT OF
ADMINISTRATIVE MOTION TO
FILE APPLE INC.’S OPPOSITION TO
ELAN MICROELECTRONICS
CORP.’S MOTION FOR PARTIAL
SUMMARY JUDGMENT UNDER
SEAL

Defendant and Counterclaim
Plaintiff.

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JUDGE: Hon. Richard Seeborg
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DECLARATION OF NATHAN GREENBLATT IN SUPPORT
OF ADMINISTRATIVE MOTION TO FILE UNDER SEAL

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

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I, Nathan Greenblatt, declare:

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I am an attorney with the law firm of Weil, Gotshal & Manges LLP, counsel of

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record for Defendant and Counter-Claimant Apple Inc. (“Apple”) in the above-captioned matter.

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I submit this declaration based on personal knowledge and following a reasonable investigation.

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If called upon as a witness, I could competently testify to the truth of each statement herein.

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1.

I prepared the redacted version of Apple Inc.’s Opposition to Elan

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

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No. 5,825,352 (“Apple’s Opposition”). Based on my review, the redacted portions contain

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confidential technical information regarding the operation of Apple’s products, as well as internal

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codenames, which could harm Apple if publicly disclosed.
2.

I prepared the redacted version of the Declaration of Ravin Balakrishnan in

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Support of Apple’s Opposition. Based on my review, the redacted portions contain confidential

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technical information regarding the operation of Apple’s products, as well as internal codenames,

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which could harm Apple if publicly disclosed.

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3.

I have reviewed Exhibit A [May 24, 2011 Dezmelyk Dep.] to the Walter

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Declaration. Based on my review, the exhibit consists predominantly of technical information

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related to the operation of Apple products, which could harm Apple if publicly disclosed.

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4.

I prepared the redacted version of Exhibit D [May 24, 2011 Dezmelyk Dep., Exh.

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13] to the Walter Declaration. Based on my review, the redacted portions consists of technical

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information related to the operation of Apple products, which could harm Apple if publicly

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disclosed.

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5.

I have reviewed Exhibit G [Aug. 27, 2006 letter from Elantech Devices Corp. to

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Apple Inc.] to the Walter Declaration. Based on my review, exhibit consists of confidential

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correspondence between Apple and Elan that could have an adverse impact on Apple if publicly

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disclosed.

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6.

I have reviewed Exhibit H [Aug. 22, 2007 letter from J. Whitt to S. DeBruine] to

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the Walter Declaration. Based on my review, exhibit consists of confidential correspondence

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between Apple and Elan that could have an adverse impact on Apple if publicly disclosed.
DECLARATION OF NATHAN GREENBLATT IN SUPPORT
OF ADMINISTRATIVE MOTION TO FILE UNDER SEAL

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

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7.

I have reviewed Exhibit L [Nov. 11, 2010 Westerman Dep.] to the Walter

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Declaration. Based on my review, the exhibit consists predominantly of technical information

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related to the operation of Apple products, which could harm Apple if publicly disclosed.

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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 June 2, 2011, at Redwood Shores, California.

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/s/ Nathan Greenblatt
Nathan Greenblatt

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DECLARATION OF NATHAN GREENBLATT IN SUPPORT
OF ADMINISTRATIVE MOTION TO FILE UNDER SEAL

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