Elan Microelectronics Corporation v. Apple, Inc.
Filing
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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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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
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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.
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.
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JUDGE: Hon. Paul S. Grewal
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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 Opposition to Elan Microelectronics Corporation's Motion to Compel
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Discovery on Various Issues (“Greenblatt Decl.”). Apple respectfully requests that the Court
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permit the following:
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1.
Apple Inc.’s Opposition to Elan Microelectronics Corporation's Motion to Compel
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Discovery on Various Issues (“Apple’s Motion”) may be filed under seal. A partially redacted
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public version may be filed in the public docket.
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2.
Exhibits 8 and 10 to the Declaration of Nathan Greenblatt in Support of Apple’s
Motion may be filed under seal.
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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.
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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 and testing tools, which could harm Apple if publicly disclosed. See Greenblatt
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Decl. ¶¶ 1-3. The documents listed above have been given particularized consideration, with
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attention to the Court’s policy of providing public access to the court proceedings. See id.
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Therefore, Apple respectfully requests that the Court grant this motion.
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Dated: August 9, 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)
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