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

Filing 1060

*** Declaration of Trevor Darrell in Support of Samsung's Reply and Exhibit D and E to Darrell Declaration FILED IN ERROR WITH CONFIDENTIAL INFORMATION. DOCUMENT LOCKED. *** Administrative Motion to File Under Seal filed by Samsung Electronics America, Inc.(a New York corporation), Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC(a Delaware limited liability company). (Attachments: #1 Proposed Order Granting Motion to File Documents Under Seal, #2 Samsung's Reply in Support of Motion to Strike Expert Testimony Based on Undislcosed Facts and Theories, #3 Declaration of Christopher E. Price in Support of Samsung's Reply, #4 Exhibit 1 to Price Declaration, #5 Exhibit 2 to Price Declaration, #6 Exhibit 3 to Price Declaration, #7 Exhibit 4 to Price Declaration, #8 Exhibit 5 to Price Declaration, #9 Exhibit 6 to Price Declaration, #10 Exhibit 7 to Price Declaration, #11 Exhibit 8 to Price Declaration, #12 Exhibit 9 to Price Declaration, #13 Exhibit 10 to Price Declaration, #14 Exhibit 11 to Price Declaration, #15 Exhibit 12 to Price Declaration, #16 Exhibit 13 to Price Declaration, #17 Exhibit 14 to Price Declaration, #18 Exhibit 15 to Price Declaration, #19 Exhibit 16 to Price Declaration, #20 Exhibit 17 to Price Declaration, #21 Exhibit 18 to Price Declaration, #22 Exhibit 19 to Price Declaration, #23 Exhibit 20 to Price Declaration, #24 Exhibit 21 to Price Declaration, #25 Exhibit 22 to Price Declaration, #26 Exhibit 23 to Price Declaration, #27 Exhibit 24 to Price Declaration, #28 Exhibit 25 to Price Declaration, #29 Exhibit 26 to Price Declaration, #30 Exhibit 27 to Price Declaration, #31 Exhibit 28 to Price Declaration, #32 Exhibit 29 to Price Declaration, #33 Exhibit 30 to Price Declaration, #34 Exhibit 31 to Price Declaration, #35 Declaration of Michael J. Wagner in Support of Samsung's Reply, #36 Exhibit A to Wagner Declaration, #37 Exhibit B to Wagner Declaration, #38 Exhibit C to Wagner Declaration, #39 Declaration of Trevor Darrell in Support of Samsung's Reply, #40 Exhibit A to Darrell Declaration, #41 Exhibit B to Darrell Declaration, #42 Exhibit C to Darrell Declaration, #43 Exhibit D to Darrell Declaration, #44 Exhibit E to Darrell Declaration)(Maroulis, Victoria) (Filed on 6/7/2012) Modified on 6/8/2012 (fff, COURT STAFF).

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP
Charles K. Verhoeven (Cal. Bar No. 170151)
 [e-mail]
50 California Street, 22nd Floor
 San Francisco, California 94111
Telephone: [phone]
 Facsimile: [phone]
 Kevin P.B. Johnson (Cal. Bar No. 177129)
[e-mail]
 Victoria F. Maroulis (Cal. Bar No. 202603)
[e-mail]
 555 Twin Dolphin Drive 5th Floor
Redwood Shores, California 94065
 Telephone: [phone]
Facsimile: [phone]

Michael T. Zeller (Cal. Bar No. 196417)
 [e-mail]
865 S. Figueroa St., 10th Floor
 Los Angeles, California 90017
Telephone: [phone]
 Facsimile: [phone]
 Attorneys for SAMSUNG ELECTRONICS
CO., LTD., SAMSUNG ELECTRONICS
 AMERICA, INC. and SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC



UNITED STATES DISTRICT COURT



NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

 APPLE INC., a California corporation,

CASE NO. 11-cv-01846-LHK



SAMSUNG’S ADMINISTRATIVE
MOTION TO FILE DOCUMENTS
UNDER SEAL



Plaintiff,
vs.

 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,

Defendants.




Case No. 11-cv-01846-LHK
SAMSUNG’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL

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Pursuant to Civil L.R. 7-11 and 79-5, and General Order No. 62, Defendants Samsung

2 Electronics Co., Ltd., Samsung Electronics America, Inc., and Samsung Telecommunications
3 America, LLC (collectively, “Samsung”) hereby bring this administrative motion for an order to
4 seal:
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1. The confidential, unredacted version of Samsung's Reply in Support of Motion to

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Strike Expert Testimony Based on Undisclosed Facts and Theories (“Reply”);

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2. The confidential, unredacted version of the Declaration of Michael J. Wagner in

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Support of the Reply (“Wagner Declaration”);

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3. Exhibits B and C to the Wagner Declaration; and

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4. Exhibits 1-6, 13, 20-21, and 29-30 to the Declaration of Christopher E. Price in
Support of the Reply (“Price Declaration”).
In short, the above documents discuss, refer to, or comprise information the parties have

13 designated as HIGHLY CONFIDENTIAL — ATTORNEYS' EYES ONLY.

The Reply; Wagner

14 Declaration; Exhibit C to the Wagner Declaration; and Exhibits 1-6, 13, 20-21, and 29-30 to the
15 Price Declaration discuss, refer to, or comprise documents Apple Inc. (“Apple”) has designated as
16 confidential. Exhibit B to the Wagner Declaration discusses information both Apple and
17 Samsung have designated as confidential.

Samsung has established good cause to seal Exhibit B

18 to the Wagner Declaration through the Declaration of Joby Martin in Support of Samsung’s
19 Administrative Motion to File Documents Under Seal.

Samsung expects that Apple will file the

20 declaration required by Local Rule 79-5(d) to permit the sealing of the Reply; Wagner
21 Declaration; Exhibits B and C to the Wagner Declaration; and Exhibits 1-6, 13, 20-21, and 29-30
22 to the Price Declaration.
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Pursuant to General Order No. 62, Samsung’s entire filing will be lodged with the Court

24 for in camera review and served on all parties.
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Case No. 11-cv-01846-LHK
-1SAMSUNG’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL

1 DATED: June 7, 2012
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QUINN EMANUEL URQUHART &
SULLIVAN, LLP

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By

/s/ Victoria Maroulis
Charles K. Verhoeven
Kevin P.B. Johnson
Victoria F. Maroulis
Michael T. Zeller
Attorneys for SAMSUNG ELECTRONICS CO.,
LTD., SAMSUNG ELECTRONICS AMERICA,
INC., and SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC

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Case No. 11-cv-01846-LHK
-2SAMSUNG’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL