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)

1
2
3
4
5
6
7
8
9
10
11

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]

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.,
Defendant and Counterclaim
Plaintiff.

Case No. C-09-01531 RS (PSG)
DECLARATION OF NATHAN
GREENBLATT IN SUPPORT OF
ADMINISTRATIVE MOTION TO
FILE UNDER SEAL APPLE INC.’S
OPPOSITION TO ELAN
MICROELECTRONICS
CORPORATION’S MOTION TO
COMPEL DISCOVERY ON VARIOUS
ISSUES

23
24

JUDGE: Hon. Paul S. Grewal

25
26
27
28
DECLARATION OF NATHAN GREENBLATT IN SUPPORT
OF ADMINISTRATIVE MOTION TO FILE UNDER SEAL

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

1

I, Nathan Greenblatt, declare:

2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23

I am an attorney with the law firm of Weil, Gotshal & Manges LLP, counsel of
record for Defendant and Counter-Claimant Apple Inc. (“Apple”) in the above-captioned matter.
I submit this declaration based on personal knowledge and following a reasonable investigation.
If called upon as a witness, I could competently testify to the truth of each statement herein.
1.

I prepared the redacted version of Apple Inc.’s Opposition to Elan

Microelectronics Corporation's Motion to Compel Discovery on Various Issues (“Apple’s
Motion”). Based on my review, the redacted portions contain confidential technical information
regarding the operation of Apple’s products, as well as internal codenames, which could harm
Apple if publicly disclosed.
2.

I have reviewed Exhibit 8 to the Declaration of Nathan Greenblatt in Support of

Apple’s Motion (“Greenblatt Declaration”).

Based on my review, the exhibit consists

predominantly of confidential technical information regarding the operation of Apple’s testing
tools, as well as internal codenames, which could harm Apple if publicly disclosed.
3.

I prepared the redacted version of Exhibit 9 to the Greenblatt Declaration. Based

on my review, the redacted portions consist of internal codenames, which could harm Apple if
publicly disclosed.
4.

I have reviewed Exhibit 10 to the Greenblatt Declaration. Based on my review,

the exhibit consists predominantly of confidential technical information regarding Apple’s
products, as well as internal codenames, which could harm Apple if publicly disclosed.
I declare under the penalty of perjury under the laws of the United States of
America that the foregoing is true and correct.
Executed on August 9, 2011, at Redwood Shores, California.

24
25
/s/ Nathan Greenblatt
Nathan Greenblatt

26
27
28
DECLARATION OF NATHAN GREENBLATT IN SUPPORT
OF ADMINISTRATIVE MOTION TO FILE UNDER SEAL

1

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