Elan Microelectronics Corporation v. Apple, Inc.

Filing 399

Administrative Motion to File Under Seal Elan Microelectronics Corporation's Papers in Support of Its Reply in Support of Motion to Compel Discovery on Various Issues filed by Elan Microelectronics Corporation. (Liu, Jennifer) (Filed on 8/16/2011)

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YITAI HU (SBN 248085)
[e-mail]
SEAN P. DEBRUINE (SBN 168071)
[e-mail]
ELIZABETH H. RADER (SBN 184963)
[e-mail]
JANE HAN BU (SBN 240081)
[e-mail]
JENNIFER LIU (SBN 268990)
[e-mail]
PALANI P. RATHINASAMY (SBN 269852)
[e-mail]
ALSTON & BIRD LLP
275 Middlefield Road, Suite 150
Menlo Park, CA 94025-4008
Telephone:
650-838-2000
Facsimile:
650-838-2001
Attorneys for Plaintiff and Counterdefendant
ELAN MICROELECTRONICS
CORPORATION

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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 Counterdefendant,

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v.
APPLE, INC.,
Defendant and Counterplaintiff.

Case No. 5:09-cv-01531 RS (PSG)
PLAINTIFF ELAN
MICROELECTRONICS
CORPORATION’S ADMINISTRATIVE
MOTION TO FILE UNDER SEAL
PAPERS IN SUPPORT OF ITS REPLY
IN SUPPORT OF MOTION TO
COMPEL DISCOVERY ON VARIOUS
ISSUES

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AND RELATED COUNTERCLAIMS

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ELAN’S ADMIN. MOT. TO FILE UNDER SEAL PAPERS ISO ITS
REPLY ISO MOT TO COMPEL DISCOVERY ON VARIOUS
ISSUES

Case No. 5:09-cv-01531 RS (PSG)

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Pursuant to Civil Local Rules 7-11 and 79-5, Plaintiff Elan Microelectronics Corporation

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(“Elan”) hereby requests leave of Court to file under seal the following documents which have

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been lodged with the Clerk:

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1.

Exhibit 1 to the Declaration of Jane H. Bu in Support of Elan’s Reply in Support of

Motion to Compel Discovery on Various Issues (filed under seal).
2.

Exhibit 3 to the Declaration of Jane H. Bu in Support of Elan’s Reply in Support of

Motion to Compel Discovery on Various Issues (partially redacted).
As grounds for this motion, Elan states that Exhibit 1 to the Bu Declaration is designated
by Apple, Inc. (“Apple”) as “Confidential – Attorney Eyes Only” pursuant to the Amended

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Protective Order in this matter. In addition, Exhibit 3 to the Bu Declaration contains information

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designated by Apple as “Confidential – Attorney Eyes Only” pursuant to the Amended Protective

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Order in this matter.

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Pursuant to Civil Local Rule 79-5(d), Apple must file with the Court and serve a

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declaration establishing that the designated information is sealable, and must lodge and serve a

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narrowly tailored proposed sealing order, or must withdraw the designation of confidentiality.

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DATED: August 16, 2011

Respectfully submitted,
ALSTON & BIRD LLP

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By:

/s/ Jennifer Liu
Jennifer Liu
Attorneys for Plaintiff
ELAN MICROELECTRONICS CORPORATION

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ELAN’S ADMIN. MOT. TO FILE UNDER SEAL PAPERS ISO ITS
REPLY ISO MOT TO COMPEL DISCOVERY ON VARIOUS
ISSUES

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Case No. 5:09-cv-01531 RS (PSG)