Elan Microelectronics Corporation v. Apple, Inc.

Filing 426

Administrative Motion to File Under Seal APPLE INC.'S MOTION FOR PARTIAL SUMMARY JUDGMENT OF NON-INFRINGEMENT OF ELAN'S '352 PATENT BY APPLE'S CURRENT PRODUCTS AND SUPPORTING DOCUMENTS filed by Apple, Inc.. (Attachments: # 1 Declaration, # 2 Proposed Order)(Greenblatt, Nathan) (Filed on 9/14/2011)

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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]
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,
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
ADMINISTRATIVE MOTION TO
FILE UNDER SEAL APPLE INC.’S
MOTION FOR PARTIAL SUMMARY
JUDGMENT OF NONINFRINGEMENT OF ELAN’S ‛352
PATENT BY APPLE’S CURRENT
PRODUCTS

JUDGE: Hon. Richard Seeborg

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

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

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I, Nathan Greenblatt, declare:

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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 Motion for Partial Summary

Judgment of Non-Infringement of Elan’s ‛352 Patent by Apple’s Current Products (“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 2 to the Declaration of Derek Walter in Support of

Apple’s Motion (“Walter Declaration”). Based on my review, the exhibit consists predominantly
of confidential technical information regarding the operation of Apple’s products, as well as
internal codenames, which could harm Apple if publicly disclosed.
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I have reviewed Exhibit 4 to the Walter Declaration. Based on my review, the

exhibit consists predominantly of confidential technical information regarding the operation of
Apple’s products, as well as internal codenames, which could harm Apple if publicly disclosed.
4.

I have reviewed Exhibit 5 to the Walter Declaration. Based on my review, the

exhibit consists predominantly of confidential technical information regarding the operation of
Apple’s products, as well as internal codenames, which could harm Apple if publicly disclosed.
5.

I have reviewed Exhibit 6 to the Walter Declaration. Based on my review, the

exhibit consists predominantly of confidential technical information regarding the operation of
Apple’s products which could harm Apple if publicly disclosed.
6.

I have reviewed Exhibit 7 to the Walter Declaration. Based on my review, the

exhibit consists of a diagram portions of which reveal confidential technical information
regarding the operation of Apple’s products, which could harm Apple if publicly disclosed.
7.

I have reviewed Exhibit 8 to the Walter Declaration. Based on my review, the

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

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

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exhibit consists of a computer animation that reveals confidential technical information regarding
the operation of Apple’s products, which could harm Apple if publicly disclosed.
8.

I have reviewed Exhibit 9 to the Walter Declaration. Based on my review, the

exhibit consists of a computer animation that reveals confidential technical information regarding
the operation of Apple’s products, which could harm Apple if publicly disclosed.
9.

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

exhibit consists predominantly of confidential technical information regarding the operation of
Apple’s products, as well as internal codenames, which could harm Apple if publicly disclosed.
10.

I have reviewed Exhibit 11 to the Walter Declaration. Based on my review, the

exhibit consists predominantly of confidential technical information regarding the operation of
Apple’s products, as well as internal codenames, which could harm Apple if publicly disclosed.
11.

I have reviewed Exhibit 12 to the Walter Declaration. Based on my review, the

exhibit consists predominantly of confidential technical information regarding the operation of
Apple’s products, as well as internal codenames, which could harm Apple if publicly disclosed.
12.

I have reviewed Exhibit 13 to the Walter Declaration. Based on my review, the

exhibit consists predominantly of confidential technical information regarding the operation of
Apple’s products, as well as internal codenames, which could harm Apple if publicly disclosed.
13.

I prepared the redacted version of the Declaration of Ravin Balakrishnan in

Support of 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.
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I have reviewed Exhibit 1 to the Balakrishnan Declaration. Based on my review,

the exhibit consists predominantly of confidential technical information regarding the operation
of Apple’s products, as well as internal codenames, which could harm Apple if publicly
disclosed.
15.

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

the exhibit consists predominantly of confidential technical information regarding the operation

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

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

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of Apple’s products, as well as internal codenames, which could harm Apple if publicly
disclosed.
16.

I have reviewed Exhibit 11 to the Balakrishnan Declaration. Based on my review,

the exhibit consists predominantly of confidential technical information regarding the operation
of Apple’s products, as well as internal codenames, which could harm Apple if publicly
disclosed.
17.

I have reviewed Exhibit 12 to the Balakrishnan Declaration. Based on my review,

the exhibit consists predominantly of confidential technical information regarding the operation
of Apple’s products which could harm Apple if publicly disclosed.
18.

I have reviewed Exhibit 13 to the Balakrishnan Declaration. Based on my review,

the exhibit consists predominantly of confidential technical information regarding the operation
of Apple’s products, as well as internal codenames, which could harm Apple if publicly
disclosed.
19.

I have reviewed Exhibit 14 to the Balakrishnan Declaration. Based on my review,

the exhibit consists of a computer animation that reveals confidential technical information
regarding the operation of Apple’s products, which could harm Apple if publicly disclosed.

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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 September 13, 2011, at Redwood Shores, California.

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/s/ Nathan Greenblatt
Nathan Greenblatt

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

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