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

Filing 1109

MOTION TO STAY ORDER DENYING ADMINISTRATIVE MOTIONS TO FILE UNDER SEAL, FOR EXTENSION OF TIME, AND TO SEAL DOCUMENTS filed by Samsung Electronics America, Inc.(a New York corporation), Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC(a Delaware limited liability company). Responses due by 7/5/2012. Replies due by 7/12/2012. (Attachments: #1 Declaration of Anthony Alden, #2 Declaration of Hankil Kang, #3 Proposed Order)(Maroulis, Victoria) (Filed on 6/20/2012)

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP
Charles K. Verhoeven (Bar No. 170151)
 [e-mail]
50 California Street, 22nd Floor
 San Francisco, California 94111
Telephone: [phone]
 Facsimile: [phone]
 Kevin P.B. Johnson (Bar No. 177129)
[e-mail]
 Victoria F. Maroulis (Bar No. 202603)
[e-mail]
th
 555 Twin Dolphin Drive, 5 Floor
Redwood Shores, California 94065-2139
 Telephone: [phone]
Facsimile: [phone]

 Michael T. Zeller (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,
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,


CASE NO. 11-cv-01846-LHK (PSG)
DECLARATION OF ANTHONY P.
ALDEN IN SUPPORT OF SAMSUNG'S
EMERGENCY MISCELLANEOUS
ADMINISTRATIVE REQUEST
PURSUANT TO CIVIL L. R. 7-11 TO
STAY ORDER DENYING
ADMINISTRATIVE MOTIONS TO FILE
UNDER SEAL (RE: DOCKET NOS. 769,
799, 822, 824, 845), FOR EXTENSION OF
TIME, AND TO SEAL DOCUMENTS

Defendants.






02198.51855/4819341.1

Case No. 11-cv-01846-LHK (PSG)
ALDEN DECL. ISO SAMSUNG'S EMERGENCY ADMIN. REQUEST TO STAY & FOR AN EXTENSION

1

DECLARATION OF ANTHONY P. ALDEN



I, Anthony P. Alden, declare as follows:



1.

I am a member of the Bar of the State of California and a partner at Quinn Emanuel

 Urquhart & Sullivan, LLP, attorneys for Samsung Electronics Co., Ltd., Samsung Electronics
 America, Inc., and Samsung Telecommunications America, LLC (collectively, “Samsung”). I
 make this declaration of personal, firsthand knowledge, and if called and sworn as a witness, I
 could and would testify competently thereto.


2.

I have reviewed the Court’s Order Denying Administrative Motions to File Under

 Seal (Re: Docket Nos. 769, 799, 822, 824, 845) (Dkt. No. 1105) (the “Order”). As a result of an
 administrative oversight, Samsung did not file the declarations in support of Apple’s motions to
 file under seal referenced in the Order earlier.


3.

On June 19, 2012, after reviewing the Order, I telephoned Richard Hung, counsel

 for Apple in this matter. I informed Mr. Hung that certain of the documents referenced in the
 Order contain highly confidential Samsung information, and that Samsung intended to file an
 emergency request to seal those documents. I asked Mr. Hung whether Apple would oppose such
 a request. Mr. Hung replied that he was not in a position to say whether Apple would agree to
 Samsung’s request because his client contact is out of town and may not be available until the
 morning of June 20, 2012. Mr. Hung agreed that, if Samsung needed to file the emergency
 request that night, I could inform the Court of his response. I requested that Mr. Hung advise me
 as soon as he had spoken with his client. But, as of the time of the filing of this declaration, I have
 not received any further response from Mr. Hung regarding Samsung’s request.


I declare under penalty of perjury under the laws of the United States of America that the

 foregoing is true and correct.


Executed June 19, 2012, at Los Angeles, California.





/s/ Anthony P. Alden
Anthony P. Alden




02198.51855/4819341.1

Case No. 11-cv-01846-LHK (PSG)
-1ALDEN DECL. ISO SAMSUNG'S EMERGENCY ADMIN. REQUEST TO STAY & FOR AN EXTENSION