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

Filing 1132

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 Samsung's Motion For Leave to Seek Reconsideration of the Court's June 25, 2012 Order (Public Redacted Version), #2 Declaration of Thomas Watson, #3 Exhibit 1, #4 Exhibit 2, #5 Exhibit 3, #6 Exhibit 4, #7 Exhibit 5, #8 Exhibit 6, #9 Exhibit 7, #10 Exhibit 8, #11 Exhibit 9, #12 Exhibit 10, #13 Exhibit 11, #14 Exhibit 12, #15 Exhibit 13, #16 Exhibit 14, #17 Exhibit 15, #18 Exhibit 16, #19 Exhibit 17, #20 Exhibit 18, #21 Exhibit 19, #22 Proposed Order Granting Samsung's Motion For Leave to Seek Reconsideration)(Maroulis, Victoria) (Filed on 6/26/2012)

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 (PSG)



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.






02198.51855/4828656.1

Case No. 11-cv-01846-LHK (PSG)
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 the following:
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1. The confidential, unredacted version of Samsung‟s Motion for Leave to Seek

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Reconsideration of the Court‟s June 25, 2012 Order to the Extent it Precludes

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Consideration of a Preliminary Injunction on the „889 Patent Based on Current

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Evidence (“the Motion”); and

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2. Unredacted Exhibits 1, 2, 3, 10, 12, 13, 14, and 20 to the Watson Declaration.
In short, the above documents discuss, refer to, or comprise excerpts of documents that has

11 been designated as HIGHLY CONFIDENTIAL – ATTORNEY‟S EYES ONLY under the
12 Protective Order.

This Administrative Motion is supported by the Court‟s June 4, 2012 Order

13 Granting in Part, Denying in Part Motions to Seal that upheld the sealing of the above referenced
14 documents except for Exhibit 20 to the Watson Declaration, which was not submitted to the Court
15 when Samsung initially sought leave for reconsideration of the Court‟s May 21, 2012 Order.
16 (See Dkt. 1034 at 1-3 (citing the Anderson Declaration [sic], which is actually the Watson
17 Declaration that is being refilled in support of this Motion; see also Dkt. 978-2.)
18

With respect to Exhibit 20 to the Watson Declaration, Apple has designated the Peter

19 Bressler deposition transcript as HIGHLY CONFIDENTIAL – ATTORNEYS‟ EYES ONLY.
20 Samsung expects that Apple will file a declaration pursuant to Civil L.R. 79-5(d) establishing
21 good cause to seal this exhibit.
22

Pursuant to General Order No. 62, Samsung‟s entire filing will be lodged with the Court

23 for in camera review and served on all parties. Redacted versions of Samsung‟s Motion and
24 Exhibits 3 and 10 to the Watson Declaration have been filed concurrently with this motion.
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02198.51855/4828656.1

Case No. 11-cv-01846-LHK (PSG)
SAMSUNG‟S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL

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1 DATED: June 26, 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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02198.51855/4828656.1

Case No. 11-cv-01846-LHK (PSG)
SAMSUNG‟S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL

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