Apple Inc. v. Samsung Electronics Co. Ltd. et al

Filing 1023

Administrative Motion to File Under Seal Documents Re Apples Opposition To Samsungs Motion For Summary Judgment filed by Apple Inc.. (Attachments: #1 Proposed Order, #2 Declaration Of Russell S. Winer In Support Of Apples Opposition To Samsungs Motion For Summary Judgment, #3 Declaration Of Dr. Alan Hedge In Support Of Apples Opposition To Samsungs Motion For Summary Judgment, #4 Exhibit A (Volume 1 of 5), #5 Exhibit A (Volume 2 of 5), #6 Exhibit A (Volume 3 of 5), #7 Exhibit A (Volume 4 of 5), #8 Exhibit A (Volume 5 of 5))(Jacobs, Michael) (Filed on 6/1/2012)

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1 2 3 4 5 6 7 8 9 HAROLD J. MCELHINNY (CA SBN 66781) hmcelhinny@mofo.com MICHAEL A. JACOBS (CA SBN 111664) mjacobs@mofo.com JENNIFER LEE TAYLOR (CA SBN 161368) jtaylor@mofo.com ALISON M. TUCHER (CA SBN 171363) atucher@mofo.com RICHARD S.J. HUNG (CA SBN 197425) rhung@mofo.com JASON R. BARTLETT (CA SBN 214530) jasonbartlett@mofo.com MORRISON & FOERSTER LLP 425 Market Street San Francisco, California 94105-2482 Telephone: (415) 268-7000 Facsimile: (415) 268-7522 WILLIAM F. LEE william.lee@wilmerhale.com WILMER CUTLER PICKERING HALE AND DORR LLP 60 State Street Boston, MA 02109 Telephone: (617) 526-6000 Facsimile: (617) 526-5000 MARK D. SELWYN (SBN 244180) mark.selwyn@wilmerhale.com WILMER CUTLER PICKERING HALE AND DORR LLP 950 Page Mill Road Palo Alto, California 94304 Telephone: (650) 858-6000 Facsimile: (650) 858-6100 10 11 Attorneys for Plaintiff and Counterclaim-Defendant APPLE INC. 12 UNITED STATES DISTRICT COURT 13 NORTHERN DISTRICT OF CALIFORNIA 14 SAN JOSE DIVISION 15 16 17 APPLE INC., a California corporation, 18 19 20 21 22 23 24 Plaintiff, v. SAMSUNG ELECTRONICS CO., LTD., a Korean corporation; SAMSUNG ELECTRONICS AMERICA, INC., a New York corporation; and SAMSUNG TELECOMMUNICATIONS AMERICA, LLC, a Delaware limited liability company, Case No. 11-cv-01846-LHK APPLE’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL RE APPLE’S OPPOSITION TO SAMSUNG’S MOTION FOR SUMMARY JUDGMENT Defendants. 25 26 27 28 APPLE’S ADMIN. MOTION TO FILE UNDER SEAL RE OPP. TO SAMSUNG’S MOT. FOR SUMMARY JUDGMENT CASE NO. 11-CV-01846-LHK sf-3150843 1 2 3 4 5 6 7 In accordance with Civil Local Rules 7-11 and 79-5, and General Order No. 62, Apple Inc. (“Apple”) submits this motion for an order to seal the following documents or portions thereof: 1. Exhibit A to the Declaration of Dr. Alan Hedge in Support of Apple’s Opposition to Samsung’s Motion for Summary Judgment (“Hedge Declaration”); and 2. Exhibit 1 to the Declaration of Dr. Russell S. Winer in Support of Apple’s Opposition to Samsung’s Motion for Summary Judgment (“Winer Declaration”). Exhibit A to the Hedge Declaration and Exhibit 1 to the Winer Declaration contain 8 information that is highly confidential as set out in the Declaration of Cyndi Wheeler in Support 9 of Apple’s Administrative Motion to File Documents Under Seal (“Wheeler Declaration”), filed 10 herewith. It is Apple’s policy not to disclose or describe to third parties its confidential financial, 11 design, trade secrets, design, or product development information. (Wheeler Declaration ¶ 11.) 12 The Apple-confidential material in these exhibits relate to such confidential information, as 13 detailed in the Wheeler Declaration. (Id. ¶ 1-10.) This information is highly confidential to 14 Apple and could be used by Apple’s competitors to Apple’s disadvantage if disclosed publicly. 15 (Id. ) The relief requested in this motion is necessary and is narrowly tailored to protect 16 confidential information, focusing only on specific portions of the documents at issue. (Id. ¶ 14.) 17 Exhibit 1 to the Winer Declaration also contains materials that Samsung has designated as 18 confidential under the protective order entered in this case. Apple expects that, pursuant to Civil 19 Local Rule 79-5(d), Samsung will file a declaration seeking to establish good cause to permit the 20 sealing of these materials. 21 Pursuant to Civil Local Rule 79-(c), Apple will lodge with the Clerk the documents at 22 issue with the sealable portions highlighted. 23 Dated: May 31, 2012 MORRISON & FOERSTER LLP 24 25 26 27 By: /s/ Michael A. Jacobs MICHAEL A. JACOBS Attorneys for Plaintiff APPLE INC. 28 APPLE’S ADMIN. MOTION TO FILE UNDER SEAL RE OPP. TO SAMSUNG’S MOT. FOR SUMMARY JUDGMENT CASE NO. 11-CV-01846-LHK sf-3150843 1

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