Elan Microelectronics Corporation v. Apple, Inc.

Filing 352

Administrative Motion to File Under Seal / Plaintiff Elan Microelectronics Corporation's Administrative Motion to File Under Seal Exhibits D-G of the Declaration of Palani P. Rathinasamy in Support of Elan Microelectronics Corporation's Unopposed Motion to Amend Infringement Contentions Pursuant to Pat. L.R. 3-6 filed by Elan Microelectronics Corporation. (Attachments: # 1 Declaration, # 2 Proposed Order)(DeBruine, Sean) (Filed on 7/22/2011)

1
2
3
4
5
6
7
8
9
10
11

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

12
13

UNITED STATES DISTRICT COURT

14

NORTHERN DISTRICT OF CALIFORNIA

15

SAN JOSE DIVISION

16
17
18

ELAN MICROELECTRONICS
CORPORATION,
Plaintiff and Counterdefendant,

19
20
21
22

v.
APPLE, INC.,

Case No. 09-cv-01531 RS (PSG)
DECLARATION OF PALANI P.
RATHINASAMY IN SUPPORT OF
PLAINTIFF ELAN
MICROELECTRONICS
CORPORATION’S ADMINISTRATIVE
MOTION TO FILE UNDER SEAL

Defendant and Counterplaintiff.

23
24

AND RELATED COUNTERCLAIMS

25
26
27
28
DECL. OF PALANI P. RATHINASAMY ISO OF ELAN’S ADMIN.
MOT. TO FILE UNDER SEAL

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

1

I, Palani P. Rathinasamy, declare as follows:

2

1.

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

3

Microelectronics Corporation (“Elan”) in this action. I have personal knowledge of the following

4

facts and, if called to testify, I could and would testify competently to the matters stated herein.

5

2.

In accordance with Civil Local Rule 79-5, Elan seeks to file under seal Exhibits D-

6

G to the Rathinasamy Declaration. Exhibits D-G are claim charts showing infringement of the

7

Apple products and discuss confidential internal operation of Apple’s products. These Exhibits

8

contain information that was obtained from documents that Apple has marked as “Confidential –

9

Attorney’s Eyes’ Only”. Furthermore, Apple’s counsel has requested that these Exhibits be filed

10

under seal. These exhibits predominately consists of sealable information such that it may be

11

appropriate to seal the entire document rather than requiring submission of a heavily redacted

12

document that would not substantially further the policy of providing public access to, and

13

understanding of, court proceedings.

14

Executed this 22nd day of July, 2011 at Menlo Park, California.

15
16
17
/s/ Palani P. Rathinasamy/
Palani P. Rathinasamy

18
19

LEGAL02/32757786v1

20
21
22
23
24
25
26
27
28
DECL. OF PALANI P. RATHINASAMY ISO OF ELAN’S ADMIN.
MOT. TO FILE UNDER SEAL

1

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