Elan Microelectronics Corporation v. Apple, Inc.

Filing 261

Declaration of Jennifer Liu in Support of 224 Administrative Motion to File Under Seal Apple, Inc.'s Motion to Compel and Related Documents filed byElan Microelectronics Corporation. (Attachments: # 1 Proposed Order)(Related document(s) 224 ) (Liu, Jennifer) (Filed on 6/7/2011)

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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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[PROPOSED] ORDER GRANTING
DEFENDANT APPLE INC.’S
ADMINISTRATIVE MOTION TO FILE
UNDER SEAL APPLE INC.’S MOTION
TO COMPEL AND RELATED
DOCUMENTS

Plaintiff and Counterdefendant,

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

ELAN MICROELECTRONICS
CORPORATION,

v.
APPLE, INC.,
Defendant and Counterplaintiff.

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AND RELATED COUNTERCLAIMS

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[PROPOSED] ORDER GRANTING APPLE’S ADMIN. MOT. TO
FILE UNDER SEAL APPLE’S MOT. TO COMPEL AND RELATED
DOCUMENTS

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

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The Court has received (1) Defendant Apple Inc.’s Administrative Motion to File Under

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Seal Apple Inc.’s Motion to Compel and Related Documents, and (2) the Declaration of Jennifer

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Liu in Support of Apple’s Motion to File Under Seal. Good cause appearing, the motion is

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GRANTED.
It is hereby ORDERED that the following documents are to be filed under seal as indicated

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below:
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The redacted portions of Apple Inc.’s Notice of Motion and Motion to Compel (1)

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Discovery Relating to Elan’s U.S. Sales; (2) Documents Improperly Withheld on the Basis of

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Privilege; and (3) Inventor Depositions.

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2.

Exhibit 2 to the Declaration of Derek Walter in Support of Apple Inc.’s Motion to

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Compel (1) Discovery Relating to U.S. Sales; (2) Documents Improperly Withheld on the Basis of

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Privilege; and (3) Inventor Depositions.

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3.

Exhibit 4 to the Declaration of Derek Walter in Support of Apple Inc.’s Motion to

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Compel (1) Discovery Relating to U.S. Sales; (2) Documents Improperly Withheld on the Basis of

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Privilege; and (3) Inventor Depositions.

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4.

The revised Exhibit 8 to the Declaration of Derek Walter in Support of Apple Inc.’s

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Motion to Compel (1) Discovery Relating to U.S. Sales; (2) Documents Improperly Withheld on

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the Basis of Privilege; and (3) Inventor Depositions.

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5.

The revised Exhibit 11 to the Declaration of Derek Walter in Support of Apple

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Inc.’s Motion to Compel (1) Discovery Relating to U.S. Sales; (2) Documents Improperly

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Withheld on the Basis of Privilege; and (3) Inventor Depositions.

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6.

Exhibit 12 to the Declaration of Derek Walter in Support of Apple Inc.’s Motion to

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Compel (1) Discovery Relating to U.S. Sales; (2) Documents Improperly Withheld on the Basis of

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Privilege; and (3) Inventor Depositions.

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7.

Exhibit 13 to the Declaration of Derek Walter in Support of Apple Inc.’s Motion to

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Compel (1) Discovery Relating to U.S. Sales; (2) Documents Improperly Withheld on the Basis of

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Privilege; and (3) Inventor Depositions.

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8.

Exhibit 14 to the Declaration of Derek Walter in Support of Apple Inc.’s Motion to

[PROPOSED] ORDER GRANTING APPLE’S ADMIN. MOT. TO
FILE UNDER SEAL APPLE’S MOT. TO COMPEL AND RELATED
DOCUMENTS

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

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Compel (1) Discovery Relating to U.S. Sales; (2) Documents Improperly Withheld on the Basis of

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Privilege; and (3) Inventor Depositions.

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9.

Exhibit 16 to the Declaration of Derek Walter in Support of Apple Inc.’s Motion to

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Compel (1) Discovery Relating to U.S. Sales; (2) Documents Improperly Withheld on the Basis of

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Privilege; and (3) Inventor Depositions.

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10.

The revised Exhibit 17 to the Declaration of Derek Walter in Support of Apple

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Inc.’s Motion to Compel (1) Discovery Relating to U.S. Sales; (2) Documents Improperly

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Withheld on the Basis of Privilege; and (3) Inventor Depositions.

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11.

Exhibit 18 to the Declaration of Derek Walter in Support of Apple Inc.’s Motion to

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Compel (1) Discovery Relating to U.S. Sales; (2) Documents Improperly Withheld on the Basis of

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Privilege; and (3) Inventor Depositions.

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12.

Exhibit 19 to the Declaration of Derek Walter in Support of Apple Inc.’s Motion to

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Compel (1) Discovery Relating to U.S. Sales; (2) Documents Improperly Withheld on the Basis of

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Privilege; and (3) Inventor Depositions.

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13.

Exhibit 20 to the Declaration of Derek Walter in Support of Apple Inc.’s Motion to

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Compel (1) Discovery Relating to U.S. Sales; (2) Documents Improperly Withheld on the Basis of

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Privilege; and (3) Inventor Depositions.

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14.

Exhibit 21 to the Declaration of Derek Walter in Support of Apple Inc.’s Motion to

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Compel (1) Discovery Relating to U.S. Sales; (2) Documents Improperly Withheld on the Basis of

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Privilege; and (3) Inventor Depositions.

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15.

Exhibit 23 to the Declaration of Derek Walter in Support of Apple Inc.’s Motion to

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Compel (1) Discovery Relating to U.S. Sales; (2) Documents Improperly Withheld on the Basis of

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Privilege; and (3) Inventor Depositions.

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16.

Exhibit 25 to the Declaration of Derek Walter in Support of Apple Inc.’s Motion to

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Compel (1) Discovery Relating to U.S. Sales; (2) Documents Improperly Withheld on the Basis of

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Privilege; and (3) Inventor Depositions.

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17.

Exhibit 26 to the Declaration of Derek Walter in Support of Apple Inc.’s Motion to

Compel (1) Discovery Relating to U.S. Sales; (2) Documents Improperly Withheld on the Basis of
[PROPOSED] ORDER GRANTING APPLE’S ADMIN. MOT. TO
FILE UNDER SEAL APPLE’S MOT. TO COMPEL AND RELATED
DOCUMENTS

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

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Privilege; and (3) Inventor Depositions.
18.

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The revised Exhibit 27 to the Declaration of Derek Walter in Support of Apple

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Inc.’s Motion to Compel (1) Discovery Relating to U.S. Sales; (2) Documents Improperly

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Withheld on the Basis of Privilege; and (3) Inventor Depositions, including pages 1-5, 14-21 and

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118.

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19.

Exhibit 34 to the Declaration of Derek Walter in Support of Apple Inc.’s Motion to

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Compel (1) Discovery Relating to U.S. Sales; (2) Documents Improperly Withheld on the Basis of

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Privilege; and (3) Inventor Depositions.

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20.

Exhibit 35 to the Declaration of Derek Walter in Support of Apple Inc.’s Motion to

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Compel (1) Discovery Relating to U.S. Sales; (2) Documents Improperly Withheld on the Basis of

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Privilege; and (3) Inventor Depositions.

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IT IS SO ORDERED.

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DATED: ________________, 2011

____________________________________
UNITED STATES MAGISTRATE JUDGE

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LEGAL02/32675719v1

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[PROPOSED] ORDER GRANTING APPLE’S ADMIN. MOT. TO
FILE UNDER SEAL APPLE’S MOT. TO COMPEL AND RELATED
DOCUMENTS

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