Elan Microelectronics Corporation v. Apple, Inc.

Filing 257

Administrative Motion to File Under Seal APPLE INC.'S RESPONSE TO ELAN MICROELECTRONIC CORPORATION'S MOTION TO COMPEL APPLE TO SUPPLEMENT ITS RESPONSE TO ELAN'S INTERROGATORY NO. 13 AND EXHIBITS 1 AND 2 TO THE DECLARATION OF DEREK WALTER IN SUPPORT THEREOF filed by Apple, Inc.. (Attachments: # 1 Proposed Order)(Greenblatt, Nathan) (Filed on 6/7/2011)

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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.,
Defendant and Counterclaim
Plaintiff.

Case No. C-09-01531 RS (PSG)
APPLE INC.’S ADMINISTRATIVE
MOTION TO FILE UNDER SEAL
APPLE INC.’S RESPONSE TO ELAN
MICROELECTRONICS CORP.’S
MOTION TO COMPEL APPLE INC.
TO SUPPLEMENT ITS RESPONSE TO
ELAN'S INTERROGATORY NO. 13
JUDGE: Hon. Paul Singh Grewal

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ADMINISTRATIVE MOTION TO FILE UNDER SEAL

CASE NO. C-09-01531 RS (PSG)

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Apple Inc. submits this Administrative Motion for a sealing order pursuant to Civil

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Local Rule 79-5.

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accompanying Declaration of Nathan Greenblatt in Support of Apple Inc.’s Administrative

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Motion to File Under Seal Apple Inc.’s Response to Elan Microelectronics Corp.’s Motion to

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Compel Apple Inc. to Supplement Its Response to Elan's Interrogatory No. 13 (“Greenblatt

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Declaration”). Apple respectfully requests that the Court issue an order permitting the following

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documents, or portions thereof, to be filed under seal:

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1.

This motion is based on the points and authorities herein, and on the

Apple Inc.’s Response to Elan Microelectronics Corp.’s Motion to Compel Apple

Inc. to Supplement Its Response to Elan's Interrogatory No. 13 (a partially redacted public version
is being lodged with the Court).
2.

Exhibits 1 and 2 to the Declaration of Derek Walter in Support of Apple Inc.’s

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Response to Elan Microelectronics Corp.’s Motion to Compel Apple Inc. to Supplement Its

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Response to Elan's Interrogatory No. 13 (partially redacted public versions are being lodged with

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the Court).

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The partially redacted versions of the above documents contain the minimal redactions

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necessary to protect highly confidential technical information regarding the operation of the

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accused Apple products, as well as internal codenames for the products. See Greenblatt Decl. ¶¶

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1-3; see also Civil L.R. 79-5 (Commentary). Each of the documents listed above has been given

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particularized consideration, with attention to the Court’s policy of providing public access to the

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court proceedings. See generally Greenblatt Decl. Therefore, Apple respectfully requests that the

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Court grant this motion.

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Dated: June 7, 2011

WEIL, GOTSHAL & MANGES LLP

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By:

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/s/ Nathan Greenblatt
Nathan Greenblatt
Attorneys for Defendant and
Counterclaim Plaintiff Apple Inc.

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ADMINISTRATIVE MOTION TO FILE UNDER SEAL

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CASE NO. C-09-01531 RS (PSG)