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

Filing 1160

Administrative Motion to File Under Seal Documents Regarding Apples Opposition To Samsungs Motion To Stay And Suspend The June 26, 2012 Preliminary Injunction Pending Appeal Or, Alternatively, Pending Decision By Federal Circuit On Stay Pending Appeal filed by Apple Inc.. (Attachments: #1 Proposed Order)(Jacobs, Michael) (Filed on 6/30/2012)

1
2
3
4
5
6
7
8
9

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]

10
11

Attorneys for Plaintiff and
Counterclaim-Defendant APPLE INC.

12
13

UNITED STATES DISTRICT COURT

14

NORTHERN DISTRICT OF CALIFORNIA

15

SAN JOSE DIVISION

16

APPLE INC., a California corporation,
Plaintiff,

17
18
19
20
21
22

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
OPPOSITION TO SAMSUNG’S
MOTION TO STAY AND SUSPEND
THE JUNE 26, 2012 PRELIMINARY
INJUNCTION PENDING APPEAL
OR, ALTERNATIVELY, PENDING
DECISION BY FEDERAL CIRCUIT
ON STAY PENDING APPEAL

Defendants.

23
24
25
26
27
28
ADMIN. MOT. TO FILE UNDER SEAL DOCUMENTS RE APPLE’S OPP. TO MOT. TO STAY
CASE NO. 11-CV-01846-LHK (PSG)
sf-3165600

1
2

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:

3

1.

The confidential, unreacted Opposition to Samsung’s Motion to Stay and Suspend

4

the June 26, 2012 Preliminary Injunction Pending Appeal or, Alternatively,

5

Pending Decision by Federal Circuit on Stay Pending Appeal (“Opposition”);

6

2.

Exhibits A to the Declaration of Jason R. Bartlett In Support of Apple’s

7

Opposition to Samsung’s Motion to Stay and Suspend the June 26, 2012

8

Preliminary Injunction Pending Appeal or, Alternatively, Pending Decision by

9

Federal Circuit on Stay Pending Appeal (“Bartlett Declaration”) which has been

10

designated confidential as set forth below.

11

The Opposition and Exhibit A to the Bartlett Declaration contain materials that Samsung

12

has designated as confidential under the protective order entered in this case. Apple expects that,

13

pursuant to Civil Local Rule 79-5(d), Samsung will file a declaration seeking to establish good

14

cause to permit the sealing of these materials.

15
16

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

17
18

Dated: June 29, 20121

MORRISON & FOERSTER LLP

19
By:

20
21

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

22
23
24
25
26
27

1

Reflects date of filing via email as instructed by the Court due to ECF outage.

28
ADMIN. MOT. TO FILE UNDER SEAL DOCUMENTS RE APPLE’S OPP. TO MOT. TO STAY
CASE NO. 11-CV-01846-LHK (PSG)
sf-3165600

1