Interserve, Inc. et al v. Fusion Garage PTE. LTD

Filing 124

Administrative Motion to File Under Seal its Notice of Further Challenges to Confidentiality Designations from Transcript of TechCrunch 30(b)(6) Deposition and Supporting Exhibits filed by Fusion Garage PTE. LTD. (Attachments: # 1 Proposed Order)(Doolittle, Patrick) (Filed on 5/12/2010)

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP Claude M. Stern (Bar No. 96737) 2 [e-mail] Evette Pennypacker (Bar No. 203515) 3 [e-mail] 555 Twin Dolphin Dr., 5th floor 4 Redwood Shores, CA 94065 Telephone: [phone] Facsimile: [phone] Patrick Doolittle (Bar No. 203659) [e-mail] 7 50 California Street, 22nd Floor San Francisco, California 94111 8 Telephone: [phone] Facsimile: [phone] 9 Attorneys for Defendant Fusion Garage PTE 10 Ltd. 11 12 13 14 15 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION 6

INTERSERVE, INC. dba TECHCRUNCH, a 16 Delaware corporation, and CRUNCHPAD, INC., a Delaware corporation, 17 Plaintiffs, 18 vs. 19 FUSION GARAGE PTE LTD., a Singapore 20 company, 21 22 23 24 25 26 27 28
04049.51632/3495071.1

CASE NO. C 09-cv-5812 RS (PVT) FUSION GARAGE'S ADMINISTRATIVE MOTION TO FILE UNDER SEAL ITS NOTICE OF FURTHER CHALLENGES TO CONFIDENTIALITY DESIGNATIONS FROM TRANSCRIPT OF TECHCRUNCH 30(B)(6) DEPOSITION AND SUPPORTING EXHIBITS (Civil Local Rule 79-5)

Defendant.

Case No. C 09-cv-5812 RS (PVT) MOTION TO FILE UNDER SEAL

1

Pursuant to Civil Local Rule 79-5, Defendant Fusion Garage PTE Ltd. hereby submits this

2 administrative motion for an order to provisionally file under seal its Notice of Further Challenges 3 to Confidentiality Designations From the Transcript of TechCrunch's 30(b)(6) Deposition 4 ("Notice") and Exhibits B-D of the Declaration of Patrick C. Doolittle in Support of the Notice 5 ("Exhibits"). Fusion Garage respectfully requests that it be allowed to file the Notice and Exhibits 6 under seal because these documents comprise and/or discuss deposition testimony and deposition 7 exhibits that plaintiffs have designated as Confidential. However, because Fusion Garage has 8 challenged these confidentiality designations, Fusion Garage respectfully requests that the Notice 9 and Exhibits be sealed only provisionally, so that they may be unsealed if the Court grants Fusion 10 Garage's challenge to the confidentiality designations. 11 Pursuant to Rule 79-5, Fusion Garage will file in the public record a redacted version of

12 the Notice that omits quotations and discussion of the Exhibits. 13 Pursuant to the declaration requirement of Rule 79-5, Fusion Garage respectfully refers the

14 Court to the Declaration of Patrick C. Doolittle in Support of the Notice. 15 16 17 18 19 20 21 22 23 24 25 26 27 28
04049.51632/3495071.1

DATED: May 12, 2010

QUINN EMANUEL URQUHART & SULLIVAN, LLP

By

/s/ Patrick Doolittle Patrick C. Doolittle Attorneys for Defendant Fusion Garage PTE Ltd,

MOTION TO FILE UNDER SEAL

-1-

Case No. C 09-cv-5812 RS( PVT)