Apple Inc. v. Samsung Electronics Co. Ltd. et al
Filing
1051
Declaration of Peter Kolovos in Support of #999 Administrative Motion to File Under Seal Samsung's Opposition to Apple's Motion to Strike Portions of Samsung's Expert Reports filed byApple Inc.(a California corporation). (Attachments: #1 Proposed Order)(Related document(s) #999 ) (Selwyn, Mark) (Filed on 6/7/2012)
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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
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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
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Attorneys for Plaintiff and
Counterclaim-Defendant APPLE INC.
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN JOSE DIVISION
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APPLE INC., a California corporation,
Case No.
11-cv-01846-LHK (PSG)
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Plaintiff,
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v.
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SAMSUNG ELECTRONICS CO., LTD., A
Korean business entity; SAMSUNG
ELECTRONICS AMERICA, INC., a New York
corporation; SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC, a
Delaware limited liability company,
DECLARATION OF
PETER KOLOVOS IN SUPPORT
OF SAMSUNG’S
ADMINISTRATIVE MOTION TO
FILE DOCUMENTS UNDER
SEAL
Defendants.
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DECLARATION OF PETER KOLOVOS ISO SAMSUNG’S MOTION TO FILE UNDER SEAL
CASE NO. 4:11-cv-01846-LHK
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I, Peter Kolovos, do hereby declare as follows:
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1.
I am a partner with the law firm of Wilmer Cutler Pickering Hale and Dorr LLP
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and counsel for plaintiff and counterclaim-defendant Apple Inc. (“Apple”). I am familiar with
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and knowledgeable about the facts stated in this declaration and if called upon could and would
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testify competently as to the statements made herein.
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2.
Exhibit Z to the Ward Declaration in Support of Samsung’s Opposition to Apple
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Inc.’s Motion to Strike Portions of Samsung’s Expert Reports contains information that Apple has
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designated confidential. Specifically:
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A.
Exhibit Z to the Ward Declaration is an excerpt from the May 8, 2012
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deposition of Samsung expert Woodward Yang. This transcript was
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designated Highly Confidential-Attorneys' Eyes Only in accordance with
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the Protective Order entered in this Action. The excerpt contains non-
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public Apple confidential information relating to components, features and
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source code of accused Apple products, and could be used to Apple’s
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disadvantage by competitors if it were not filed under seal. This exhibit
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should be sealed in its entirety.
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3.
The relief requested in this motion is necessary and is narrowly tailored to protect
confidential information, focusing only on the specific exhibit at issue.
I declare under the penalty of perjury under the laws of the United States of America that
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the forgoing is true and correct to the best of my knowledge and that this Declaration was
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executed this 7th day of June, 2012, at Boston, Massachusetts.
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Dated: June 7, 2012
By: __/s/ Peter Kolovos ______
Peter Kolovos
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DECLARATION OF PETER KOLOVOS ISO SAMSUNG’S MOTION TO FILE UNDER SEAL
CASE NO. 4:11-cv-01846-LHK
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ATTESTATION OF E-FILED SIGNATURE
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I, Mark D. Selwyn, am the ECF User whose ID and password are being used to file this
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Declaration. In compliance with General Order 45, X.B., I hereby attest that Peter Kolovos has
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concurred in this filing.
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Dated: June 7, 2012
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By:
/s/ Mark D. Selwyn
Mark D. Selwyn
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DECLARATION OF PETER KOLOVOS ISO SAMSUNG’S MOTION TO FILE UNDER SEAL
CASE NO. 4:11-cv-01846-LHK
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CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the above and foregoing document has been
served on June 7, 2012 to all counsel of record who are deemed to have consented to electronic
service via the Court’s CM/ECF system per Civil Local Rule 5.4. Any other counsel of record
will be served by electronic mail, facsimile and/or overnight delivery.
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/s/ Mark D. Selwyn
Mark D. Selwyn
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DECLARATION OF PETER KOLOVOS ISO SAMSUNG’S MOTION TO FILE UNDER SEAL
CASE NO. 4:11-cv-01846-LHK
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