Elan Microelectronics Corporation v. Apple, Inc.

Filing 391

Declaration of Nathan Greenblatt in Support of 387 Administrative Motion to File Under Seal Papers in Support of Elan Microelectronics Corporation's Reply to Motion to Compel Discovery Related to Apple iOS Applications for the Accused Products filed byApple, Inc.. (Attachments: # 1 Proposed Order)(Related document(s) 387 ) (Greenblatt, Nathan) (Filed on 8/11/2011)

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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]

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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.,
Defendant and Counterclaim
Plaintiff.

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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
PAPERS IN SUPPORT OF ITS REPLY
TO MOTION TO COMPEL
DISCOVERY RELATED TO APPLE
iOS APPLICATIONS FOR THE
ACCUSED PRODUCTS (DKT. NO. 387)

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DECLARATION OF NATHAN GREENBLATT IN SUPPORT
OF ELAN'S ADMINISTRATIVE MOTION TO FILE
EXHIBITS 1-3 UNDER SEAL RE iOS APPLICATIONS

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 Papers in Support of Its Reply to

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Motion to Compel Discovery Related to Apple iOS Applications for the Accused Products.”

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(Dkt. No. 387).

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1.

I have reviewed Exhibit 1 to the “Declaration of Jane H. Bu in Support of

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Elan Microelectronics Corporation’s Reply to Motion to Compel Discovery Related to Apple iOS

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Applications for the Accused Products.” (Dkt. No. 389). Based on my review, the document

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consists of predominantly confidential information related to web development for the Apple

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iPhone which could harm Apple if publicly disclosed.

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2.

I have reviewed Exhibit 2 to the Declaration of Jane H. Bu. Based on my

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review, the document consists of predominantly confidential information related to the Apple

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iPhone user interface design which could harm Apple if publicly disclosed.

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3.

I have reviewed Exhibit 3 to the Declaration of Jane H. Bu. Based on my

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review, the document consists of predominantly confidential information related to processing

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Multi-Touch in Apple’s products which could harm Apple if publicly disclosed.

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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 11, 2011, at

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Redwood Shores, California.

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DATED: August 11, 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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DECLARATION OF NATHAN GREENBLATT IN SUPPORT
OF ELAN'S ADMINISTRATIVE MOTION TO FILE
EXHIBITS 1-3 UNDER SEAL iOS APPLICATIONS

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