Elan Microelectronics Corporation v. Apple, Inc.

Filing 383

Administrative Motion to File Under Seal Apple's Opposition to Elan Microelectronics Corporation's Motion to Compel Discovery on Various Issues and Exhibits thereto filed by Apple, Inc.. (Attachments: # 1 Declaration, # 2 Proposed Order)(Greenblatt, Nathan) (Filed on 8/9/2011)

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1 2 3 4 5 6 7 8 9 10 11 MATTHEW D. POWERS (Bar No. 104795) matthew.powers@tensegritylawgroup.com TENSEGRITY LAW GROUP LLP 201 Redwood Shores Parkway, Suite 401 Redwood Shores, CA 94065 Telephone: (650) 802-6000 Facsimile: (650) 802-6001 JARED BOBROW (Bar No. 133712) jared.bobrow@weil.com SONAL N. MEHTA (Bar No. 222086) sonal.mehta@weil.com DEREK C. WALTER (Bar. No. 246322) derek.walter@weil.com NATHAN GREENBLATT (Bar No. 262279) nathan.greenblatt@weil.com WEIL, GOTSHAL & MANGES LLP Silicon Valley Office 201 Redwood Shores Parkway Redwood Shores, CA 94065 Telephone: (650) 802-3000 Facsimile: (650) 802-3100 12 13 Attorneys for Defendant and Counterclaim Plaintiff Apple Inc. 14 UNITED STATES DISTRICT COURT 15 NORTHERN DISTRICT OF CALIFORNIA 16 SAN FRANCISCO DIVISION 17 ELAN MICROELECTRONICS CORPORATION, 18 Plaintiff and Counterclaim Defendant, 19 20 21 22 v. APPLE INC., Case No. C-09-01531 RS (PSG) APPLE INC.’S ADMINISTRATIVE MOTION TO FILE UNDER SEAL APPLE INC.’S OPPOSITION TO ELAN MICROELECTRONICS CORPORATION’S MOTION TO COMPEL DISCOVERY ON VARIOUS ISSUES Defendant and Counterclaim Plaintiff. 23 JUDGE: Hon. Paul S. Grewal 24 25 26 27 28 ADMINISTRATIVE MOTION TO FILE UNDER SEAL Case No. C-09-01531 RS (PSG) 1 Apple Inc. submits this Administrative Motion for a sealing order pursuant to Civil Local 2 Rule 79-5. This motion is based on the points and authorities herein, and on the accompanying 3 Declaration of Nathan Greenblatt in Support of Apple Inc.’s Administrative Motion to File Under 4 Seal Apple Inc.’s Opposition to Elan Microelectronics Corporation's Motion to Compel 5 Discovery on Various Issues (“Greenblatt Decl.”). Apple respectfully requests that the Court 6 permit the following: 7 1. Apple Inc.’s Opposition to Elan Microelectronics Corporation's Motion to Compel 8 Discovery on Various Issues (“Apple’s Motion”) may be filed under seal. A partially redacted 9 public version may be filed in the public docket. 10 11 12 13 2. Exhibits 8 and 10 to the Declaration of Nathan Greenblatt in Support of Apple’s Motion may be filed under seal. 3. Exhibit 9 to the Declaration of Nathan Greenblatt in Support of Apple’s Motion may be filed under seal. A partially redacted public version may be filed in the public docket. 14 As grounds for the motion, Apple states that the documents or portions of documents for 15 which sealing is requested contain highly confidential technical information and codenames for 16 Apple products and testing tools, which could harm Apple if publicly disclosed. See Greenblatt 17 Decl. ¶¶ 1-3. The documents listed above have been given particularized consideration, with 18 attention to the Court’s policy of providing public access to the court proceedings. See id. 19 Therefore, Apple respectfully requests that the Court grant this motion. 20 21 Dated: August 9, 2011 WEIL, GOTSHAL & MANGES LLP 22 23 By: 24 25 /s/ Nathan Greenblatt Nathan Greenblatt Attorneys for Defendant and Counterclaim Plaintiff Apple Inc. 26 27 28 ADMINISTRATIVE MOTION TO FILE UNDER SEAL 1 Case No. C-09-01531 RS (PSG)

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