Elan Microelectronics Corporation v. Apple, Inc.

Filing 374

Administrative Motion to File Under Seal Apple's Motion for Partial Summary Judgment of Non-Infringement of Elan's '352 Patent by Apple's Current Products and Declaration and Exhibits Thereto filed by Apple, Inc.. (Attachments: # 1 Declaration, # 2 Proposed Order)(Greenblatt, Nathan) (Filed on 8/4/2011)

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MATTHEW D. POWERS (Bar No. 104795)
[e-mail]
TENSEGRITY LAW GROUP LLP
201 Redwood Shores Parkway, Suite 401
Redwood Shores, CA 94065
Telephone: [phone]
Facsimile: [phone]
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,
Plaintiff and Counterclaim
Defendant,

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v.
APPLE INC.,

Case No. C-09-01531 RS (PSG)
APPLE INC.’S ADMINISTRATIVE
MOTION TO FILE UNDER SEAL
APPLE INC.’S MOTION FOR
PARTIAL SUMMARY JUDGMENT OF
NON-INFRINGEMENT OF ELAN’S
‛352 PATENT BY APPLE’S CURRENT
PRODUCTS

Defendant and Counterclaim
Plaintiff.
JUDGE: Hon. Richard Seeborg

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ADMINISTRATIVE MOTION TO FILE UNDER SEAL

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

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Apple Inc. submits this Administrative Motion for a sealing order pursuant to Civil Local

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Rule 79-5. This motion is based on the points and authorities herein, and on the accompanying

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Declaration of Nathan Greenblatt in Support of Apple Inc.’s Administrative Motion to File Under

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Seal Apple Inc.’s Motion for Partial Summary Judgment of Non-Infringement of Elan's ‛352

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Patent by Apple's Current Products (“Greenblatt Decl.”). Apple respectfully requests that the

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Court permit the following documents, or portions thereof, to be filed under seal:

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1.

Apple Inc.’s Motion for Partial Summary Judgment of Non-Infringement of Elan's

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‛352 Patent by Apple's Current Products (“Apple’s Motion”) (a partially redacted public version

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is being lodged with the Court).

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2.

Exhibits 2 and 4-13 to the Declaration of Derek Walter in Support of Apple’s

Motion.
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The Declaration of Ravin Balakrishnan in Support of Apple’s Motion

(“Balakrishnan Declaration”) (a partially redacted public version is being lodged with the Court).

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4.

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As grounds for the motion, Apple states that the documents or portions of documents for

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which sealing is requested contain highly confidential technical information and codenames for

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Apple products, which could harm Apple if publicly disclosed. See Greenblatt Decl. ¶¶ 1-19.

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The documents listed above have been given particularized consideration, with attention to the

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Court’s policy of providing public access to the court proceedings. See id. Therefore, Apple

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respectfully requests that the Court grant this motion.

Exhibits 1 and 10-14 to the Balakrishnan Declaration.

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Dated: August 4, 2011

WEIL, GOTSHAL & MANGES LLP

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By:

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/s/ Nathan Greenblatt
Nathan Greenblatt
Attorneys for Defendant and
Counterclaim Plaintiff Apple Inc.

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ADMINISTRATIVE MOTION TO FILE UNDER SEAL

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