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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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 10 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 11 12 Attorneys for Plaintiff and Counterclaim-Defendant APPLE INC. 13 14 UNITED STATES DISTRICT COURT 15 NORTHERN DISTRICT OF CALIFORNIA 16 SAN JOSE DIVISION 17 18 APPLE INC., a California corporation, Case No. 11-cv-01846-LHK (PSG) 19 Plaintiff, 20 v. 21 22 23 24 25 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. 26 27 DECLARATION OF PETER KOLOVOS ISO SAMSUNG’S MOTION TO FILE UNDER SEAL CASE NO. 4:11-cv-01846-LHK 1 I, Peter Kolovos, do hereby declare as follows: 2 1. I am a partner with the law firm of Wilmer Cutler Pickering Hale and Dorr LLP 3 and counsel for plaintiff and counterclaim-defendant Apple Inc. (“Apple”). I am familiar with 4 and knowledgeable about the facts stated in this declaration and if called upon could and would 5 testify competently as to the statements made herein. 6 2. Exhibit Z to the Ward Declaration in Support of Samsung’s Opposition to Apple 7 Inc.’s Motion to Strike Portions of Samsung’s Expert Reports contains information that Apple has 8 designated confidential. Specifically: 9 A. Exhibit Z to the Ward Declaration is an excerpt from the May 8, 2012 10 deposition of Samsung expert Woodward Yang. This transcript was 11 designated Highly Confidential-Attorneys' Eyes Only in accordance with 12 the Protective Order entered in this Action. The excerpt contains non- 13 public Apple confidential information relating to components, features and 14 source code of accused Apple products, and could be used to Apple’s 15 disadvantage by competitors if it were not filed under seal. This exhibit 16 should be sealed in its entirety. 17 18 19 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 20 the forgoing is true and correct to the best of my knowledge and that this Declaration was 21 executed this 7th day of June, 2012, at Boston, Massachusetts. 22 23 Dated: June 7, 2012 By: __/s/ Peter Kolovos ______ Peter Kolovos 24 25 26 27 28 DECLARATION OF PETER KOLOVOS ISO SAMSUNG’S MOTION TO FILE UNDER SEAL CASE NO. 4:11-cv-01846-LHK 1 ATTESTATION OF E-FILED SIGNATURE 2 I, Mark D. Selwyn, am the ECF User whose ID and password are being used to file this 3 Declaration. In compliance with General Order 45, X.B., I hereby attest that Peter Kolovos has 4 concurred in this filing. 5 Dated: June 7, 2012 6 By: /s/ Mark D. Selwyn Mark D. Selwyn 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DECLARATION OF PETER KOLOVOS ISO SAMSUNG’S MOTION TO FILE UNDER SEAL CASE NO. 4:11-cv-01846-LHK 1 2 3 4 5 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. 6 7 /s/ Mark D. Selwyn Mark D. Selwyn 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DECLARATION OF PETER KOLOVOS ISO SAMSUNG’S MOTION TO FILE UNDER SEAL CASE NO. 4:11-cv-01846-LHK

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