Elan Microelectronics Corporation v. Apple, Inc.

Filing 364

Declaration of Nathan Greenblatt in Support of 359 Administrative Motion to File Under Seal Portions of Papers in Support of Its Motion to Compel Discovery on Various Issues filed byApple, Inc.. (Attachments: # 1 Proposed Order)(Related document(s) 359 ) (Greenblatt, Nathan) (Filed on 8/1/2011)

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MATTHEW D. POWERS (Bar No. 104795)
[e-mail]
201 Redwood Shores Parkway, Suite 401
Redwood Shores, CA 94065
Telephone: [phone]
Facsimile: [phone]

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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]
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.
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APPLE INC.,
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Defendant and Counterclaim
Plaintiff.

Case No. C-09-01531 RS (PSG)
DECLARATION OF NATHAN
GREENBLATT IN SUPPORT OF
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
(DKT. NO. 359)

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DECLARATION OF NATHAN GREENBLATT IN SUPPORT
OF ELAN'S ADMINISTRATIVE MOTION TO FILE UNDER
SEAL PORTIONS OF PAPERS

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

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I, Nathan Greenblatt, declare:

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I am an attorney at Weil, Gotshal & Manges LLP, counsel of record for Defendant

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and Counter-Claimant Apple Inc. (“Apple”) in the above-captioned matter. I now submit this

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declaration pursuant to Civil Local Rule 79-5(d) in support of “Plaintiff Elan Microelectronics

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Corporation’s Administrative Motion To File Under Seal Portions of Papers in Support of Its

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Motion to Compel Discovery on Various Issues.” (Dkt. No. 359).

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1.

I have reviewed Exhibit F 1 to the Declaration of Jane H. Bu (partially

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redacted), which was provided to me via email by Mr. Sissel Browder on Tuesday, July 26, 2011

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at 9:27 p.m. Based on my review, the redacted portions of the document contain confidential

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codenames for Apple products and testing tools which could harm Apple if publicly disclosed.

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2.

I have reviewed Exhibit G to the Declaration of Jane H. Bu (partially

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redacted), which was provided to me via email by Mr. Sissel Browder on Tuesday, July 26, 2011

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at 9:27 p.m.

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codenames for Apple products and testing tools which could harm Apple if publicly disclosed.

Based on my review, the redacted portions of the document contain confidential

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I declare under penalty of perjury of the laws of the United States of America that

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the foregoing is true and correct and that the foregoing is executed on August 1, 2011, at

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Redwood Shores, California.

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DATED: August 1, 2011

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Respectfully submitted,
WEIL, GOTSHAL & MANGES LLP

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/s/ Nathan Greenblatt
Nathan Greenblatt
Attorney for Defendant and Counter-Claimant,
Apple Inc.

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The Exhibits provided to me on July 26, 2011 are labeled as Exhibits F and G. The same
exhibits are cited in Elan’s Motion to Compel (Dkt. No. 357) and the accompanying Bu
Declaration as Exhibits F and G. Thus, I believe that Elan’s Motion for Administrative Relief
(Dkt. No. 359), which refers to Exhibits G and H, contains typographical errors and should
request permission to file under seal Exhibits F and G.
DECLARATION OF NATHAN GREENBLATT IN SUPPORT
OF ELAN'S ADMINISTRATIVE MOTION TO FILE UNDER
SEAL PORTIONS OF PAPERS

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