Elan Microelectronics Corporation v. Apple, Inc.

Filing 258

Declaration of Nathan Greenblatt in Support of 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 WA filed byApple, Inc.. (Related document(s) 257 ) (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.

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Case No. C-09-01531 RS (PSG)
DECLARATION OF NATHAN
GREENBLATT IN SUPPORT OF
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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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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I prepared the redacted version of Apple Inc.’s Response to Elan Microelectronics

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Corp.’s Motion to Compel Apple Inc. to Supplement Its Response to Elan's Interrogatory No. 13

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(“Apple’s Response”).

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information regarding Apple internal codenames, which could harm Apple if publicly disclosed.

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2.

Based on my review, the redacted portions contain confidential

I prepared the redacted version of Exhibit 1 to the Declaration of Derek Walter in

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

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to Supplement Its Response to Elan's Interrogatory No. 13 (“Walter Declaration”). Based on my

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review, the redacted portions contain confidential information regarding Apple internal

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codenames, which could harm Apple if publicly disclosed.

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3.

I prepared the redacted version of Exhibit 2 to the Walter Declaration. Based on

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my review, the redacted portions contain confidential information regarding Apple internal

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codenames and supply chain information, 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 7, 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)