Elan Microelectronics Corporation v. Apple, Inc.

Filing 312

Declaration of Jennifer Liu in Support of 305 Administrative Motion to File Under Seal Apple's Reply in Support of Motion to Compel and Exh B to supporting Walter Declaration filed byElan Microelectronics Corporation. (Related document(s) 305 ) (Liu, Jennifer) (Filed on 6/28/2011)

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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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DECLARATION OF JENNIFER LIU IN
SUPPORT OF DEFENDANT APPLE
INC.’S ADMINISTRATIVE MOTION
TO FILE UNDER SEAL APPLE INC.’S
REPLY IN SUPPORT OF MOTION TO
COMPEL

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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DECL. OF JENNIFER LIU ISO OF APPLE’S ADMIN. MOT. TO
FILE UNDER SEAL APPLE’S REPLY ISO MOT. TO COMPEL

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

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I, Jennifer Liu, declare as follows:

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1.

I am an attorney with the law firm of Alston & Bird LLP, counsel to Plaintiff Elan

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Microelectronics Corporation (“Elan”) in this action. I now submit this declaration pursuant to

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Civil Local Rule 79-5 in support of Defendant Apple Inc.’s Administrative Motion to File Under

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Seal Apple Inc.’s Reply in Support of Motion to Compel (Dkt No. 305).

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2.

I have reviewed the redacted version 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 (“Apple’s Reply in Support of

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Motion to Compel”). Based on my review, the redacted portions contain sensitive business

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information including Elan’s product sales and downstream customer information, as well as

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confidential information relating to Elan employees and Elan’s corporate structure and corporate

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policy, that could harm Elan if publicly disclosed.

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3.

I have reviewed Exhibit B to the Declaration of Derek C. Walter in Support of

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Apple’s Reply Brief in Support of Its Motion to Compel (1) Discovery Relating to U.S. Sales; (2)

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

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on my review, the document contains sensitive business information including downstream

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customer and product information, that could harm Elan if publicly disclosed.

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I declare under penalty of perjury under the laws of the United States that the foregoing is
true and correct.
Executed this 28th day of June, 2011 at Menlo Park, California.

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Jennifer Liu

/s/ Jennifer Liu

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LEGAL02/32713386v1

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DECL. OF JENNIFER LIU ISO OF APPLE’S ADMIN. MOT. TO
FILE UNDER SEAL APPLE’S REPLY ISO MOT. TO COMPEL

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