Elan Microelectronics Corporation v. Apple, Inc.

Filing 329

Declaration of NATHAN GREENBLATT in Support of 328 Administrative Motion to File Under Seal [APPLE INC.S ADMINISTRATIVE MOTION TO FILE UNDER SEAL APPLE INC.'S SURREPLY TO ELAN MICROELECTRONICS CORP.'S MOTION FOR PARTIAL SUMMARY JUDGMENT] Administrative Motion to File Under Seal [APPLE INC.S ADMINISTRATIVE MOTION TO FILE UNDER SEAL APPLE INC.'S SURREPLY TO ELAN MICROELECTRONICS CORP.'S MOTION FOR PARTIAL SUMMARY JUDGMENT] filed byApple, Inc.. (Related document(s) 328 ) (Greenblatt, Nathan) (Filed on 7/6/2011)

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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.,

Case No. C-09-01531 RS (PSG)
DECLARATION OF NATHAN
GREENBLATT IN SUPPORT OF
ADMINISTRATIVE MOTION TO
FILE APPLE INC.’S SURREPLY TO
ELAN MICROELECTRONICS
CORP.’S MOTION FOR PARTIAL
SUMMARY JUDGMENT UNDER
SEAL

Defendant and Counterclaim
Plaintiff.

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JUDGE: Hon. Richard Seeborg
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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 Surreply to Elan Microelectronics

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Corp.’s Motion for Partial Summary Judgment of Infringement of U.S. Patent No. 5,825,352

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(“Apple’s Surreply”). Based on my review, the redacted portions contain confidential technical

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information regarding the operation of Apple’s products, as well as internal codenames, which

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could harm Apple if publicly disclosed.
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 July 6, 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)