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

Filing 1122

Administrative Motion to File Under Seal Documents Regarding Apples Administrative Motion For Leave To File Objection To Reply Evidence filed by Apple Inc.. (Attachments: #1 Proposed Order)(Jacobs, Michael) (Filed on 6/22/2012)

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HAROLD J. MCELHINNY (CA SBN 66781)
[e-mail]
MICHAEL A. JACOBS (CA SBN 111664)
[e-mail]
JENNIFER LEE TAYLOR (CA SBN 161368)
[e-mail]
ALISON M. TUCHER (CA SBN 171363)
[e-mail]
RICHARD S.J. HUNG (CA SBN 197425)
[e-mail]
JASON R. BARTLETT (CA SBN 214530)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: [phone]

WILLIAM F. LEE
[e-mail]
WILMER CUTLER PICKERING
HALE AND DORR LLP
60 State Street
Boston, MA 02109
Telephone: [phone]
Facsimile: [phone]
MARK D. SELWYN (SBN 244180)
[e-mail]
WILMER CUTLER PICKERING
HALE AND DORR LLP
950 Page Mill Road
Palo Alto, California 94304
Telephone: [phone]
Facsimile: [phone]

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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,
Plaintiff,

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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 (PSG)
ADMINISTRATIVE MOTION TO
FILE UNDER SEAL DOCUMENTS
REGARDING APPLE’S
ADMINISTRATIVE MOTION FOR
LEAVE TO FILE OBJECTION TO
REPLY EVIDENCE

Defendants.

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ADMIN. MOT. TO FILE UNDER SEAL DOCUMENTS RE APPLE’S MOT. FOR LEAVE TO FILE OBJECTION
CASE NO. 11-CV-01846-LHK (PSG)
sf-3162717

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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:

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1.

The confidential, unredacted Supplemental Declaration of Ravin Balakrishnan,

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Ph.D. in Support of Apple’s Opposition to Samsung’s Motion for Summary

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Judgment (“Supplemental Balakrishnan Declaration”) (Exhibit B to Apple’s

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Administrative Motion for Leave to File Objection to Reply Evidence), which has

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been designated confidential as set forth below.

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The Supplemental Balakrishnan Declaration contains information that Samsung has
represented was designated “under the protective order” by third party MERL, and which

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Samsung designated “Highly Confidential – Attorneys’ Eyes Only” until it could confer with

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third Party MERL about the appropriate designation. Apple expects that, pursuant to Civil Local

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Rule 79-5(d), either Samsung or third party MERL will file a declaration seeking to establish

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good cause to permit the sealing of these materials. A copy of this motion will concurrently be

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sent to third party MERL.

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Pursuant to Civil Local Rule 79-5(c), Apple will lodge with the Clerk the documents at

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issue.

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Dated: June 22, 2012

MORRISON & FOERSTER LLP

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By:

/s/ Michael A. Jacobs
MICHAEL A. JACOBS
Attorneys for Plaintiff
APPLE INC.

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ADMIN. MOT. TO FILE UNDER SEAL DOCUMENTS RE APPLE’S MOT. FOR LEAVE TO FILE OBJECTION
CASE NO. 11-CV-01846-LHK (PSG)
sf-3162717

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