Elan Microelectronics Corporation v. Apple, Inc.

Filing 359

Administrative Motion to File Under Seal Portions of Papers in Support of Its Motion to Compel Discovery on Various Issues filed by Elan Microelectronics Corporation. (Liu, Jennifer) (Filed on 7/26/2011)

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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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ELAN MICROELECTRONICS
CORPORATION,
Plaintiff and Counterdefendant,

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v.
APPLE, INC.,
Defendant and Counterplaintiff.

Case No. 5:09-cv-01531 RS (PSG)
PLAINTIFF ELAN
MICROELECTRONICS
CORPORATION’S ADMINISTRATIVE
MOTION TO FILE UNDER SEAL
PORTIONS OF PAPERS IN SUPPORT
OF ITS MOTION TO COMPEL
DISCOVERY ON VARIOUS ISSUES

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AND RELATED COUNTERCLAIMS

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ELAN’S ADMIN. MOT. TO FILE UNDER SEAL PORTIONS OF
PAPERS ISO ITS MOT TO COMPEL DISCOVERY ON VARIOUS
ISSUES

Case No. 5:09-cv-01531 RS (PSG)

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Pursuant to Civil Local Rules 7-11 and 79-5, Plaintiff Elan Microelectronics Corporation

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(“Elan”) hereby requests leave of Court to file under seal portions of the following documents

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which have been lodged with the Clerk:

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1.

Exhibit G to the Declaration of Jane H. Bu in Support of Elan’s Motion to Compel

Discovery on Various Issues (partially redacted);
2.

Exhibit H to the Declaration of Jane H. Bu in Support of Elan’s Motion to Compel

Discovery on Various Issues (partially redacted).
As grounds for this motion, Elan states that portions of Exhibits G and H to the Bu
Declaration are designated by Apple, Inc. (“Apple”) as “Confidential − Attorney Eyes Only”

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pursuant to the Amended Protective Order in this matter. In accordance with Civil Local Rule 79-

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5, for these partially redacted documents, only the minimum and necessary redactions have been

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made to protect sealable information.

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Pursuant to Civil Local Rule 79-5(d), Apple 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: July 26, 2011

Respectfully submitted,
ALSTON & BIRD LLP

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By:

/s/ Jennifer Liu
Jennifer Liu
Attorneys for Plaintiff
ELAN MICROELECTRONICS CORPORATION

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ELAN’S ADMIN. MOT. TO FILE UNDER SEAL PORTIONS OF
PAPERS ISO ITS MOT TO COMPEL DISCOVERY ON VARIOUS
ISSUES

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Case No. 5:09-cv-01531 RS (PSG)