Elan Microelectronics Corporation v. Apple, Inc.

Filing 404

Declaration of Nathan Greenblatt in Support of 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 byApple, Inc.. (Attachments: # 1 Proposed Order)(Related document(s) 399 ) (Greenblatt, Nathan) (Filed on 8/18/2011)

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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.

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
IN SUPPORT OF MOTION TO
COMPEL DISCOVERY ON VARIOUS
ISSUES (DKT. NO. 399)

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DECLARATION OF NATHAN GREENBLATT IN SUPPORT
OF ELAN'S MOTION TO FILE UNDER SEAL EXHIBITS
1&3 RE REPLY ISO MOTION TO COMPEL DISCOVERY

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 In

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Support Of Motion To Compel Discovery On Various Issues.” (Dkt. No. 399).

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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 in Support of Motion to Compel Discovery on

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Various Issues” (“Bu Declaration”) (Dkt. No. 401). Based on my review, the document consists

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predominantly of confidential information regarding Apple testing tools and Apple codenames

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which could harm Apple if publicly disclosed.

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2.

I have reviewed the highlighted version of Exhibit 3 to the Bu Declaration

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which was provided to me via email on Tuesday, August 16, 2011 at 10:06 p.m. by Mr. Sissel

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Browder. Based on my review, the highlighted portions consist of confidential codenames for

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Apple products and testing tools 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 18, 2011, at

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Redwood Shores, California.

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DATED: August 18, 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 MOTION TO FILE UNDER SEAL EXHIBITS
1&3 RE REPLY ISO MOTION TO COMPEL DISCOVERY

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