Elan Microelectronics Corporation v. Apple, Inc.

Filing 305

Administrative Motion to File Under Seal Apple's Reply in Support of Motion to Compel and Exh B to supporting Walter Declaration filed by Apple, Inc.. (Mehta, Sonal) (Filed on 6/21/2011)

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MATTHEW D. POWERS (Bar No. 104795)
E-Mail: [e-mail]
JARED BOBROW (Bar No. 133712)
E-Mail: [e-mail]
SONAL N. MEHTA (Bar No. 222086)
E-Mail: [e-mail]
DEREK C. WALTER (Bar No. 246322)
E-Mail: [e-mail]
NATHAN GREENBLATT (Bar No. 262279)
E-Mail: [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,
Plaintiff and Counterclaim
Defendant,

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Case No. C-09-01531 RS (PSG)
APPLE INC.'S ADMINISTRATIVE
MOTION TO FILE UNDER SEAL
APPLE INC.'S REPLY IN SUPPORT
OF MOTION TO COMPEL

v.
Date:
Time:

APPLE INC.,
Defendant and Counterclaim
Plaintiff.

July 5, 2011
10:00 am

Hon. Paul Singh Grewal

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Apple Inc.'s Administrative Motion to File Under Seal Reply In
Support of Motion to Compel

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(d), to permit the filing under seal of “Apple Inc.’s Reply Brief in Support of Its

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

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Withheld On The Basis Of Privilege And (3) Inventor Depositions” (hereinafter “Apple’s Reply

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In Support of Motion to Compel”) and related paper. In particular:

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Apple is lodging with the Court Apple’s Reply in Support of Motion to Compel

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and a redacted version of Apple’s Reply in Support of Motion to Compel. The redacted portions

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contain information designated by Elan Microelectronics Corp. (“Elan”) as confidential pursuant

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to the protective order in this case.

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Apple is also lodging with the Court certain exhibits that have been designated by

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Elan as confidential. Specifically, the following exhibits to the Declaration of Derek C. Walter in

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Support of Apple’s Reply Brief in Support of Its Motion to Compel (1) Discovery Relating to

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Elan’s U.S. Sales; (2) Documents Improperly Withheld On The Basis Of Privilege; And (3)

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Inventor Depositions” have been designated by Elan as confidential pursuant to the protective

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order in this case: Exhibit B.

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Pursuant to Civil Local Rule 79-5(d), Elan “must file with the Court and serve a

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declaration establishing that the designated information is sealable, and must lodge and serve a

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narrowly tailored proposed sealing order, or must withdraw the designation of confidentiality.”

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Dated: June 21, 2011

WEIL, GOTSHAL & MANGES LLP

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By:

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/s/ Derek C. Walter
Derek C. Walter

Attorneys for Defendant and Counterclaim
Plaintiff APPLE INC.

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Apple Inc.'s Administrative Motion to File Under Seal Reply In
Support of Motion to Compel

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