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

Filing 1162

Declaration of Bill Trac in Support of #1125 Administrative Motion to File Under Seal Documents Regarding Apples Administrative Motion For Leave To File Objection To Reply Evidence filed bySamsung Electronics Co. Ltd.. (Related document(s) #1125 ) (Maroulis, Victoria) (Filed on 6/30/2012)

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP
Charles K. Verhoeven (Cal. Bar No. 170151)
2 [e-mail]
50 California Street, 22nd Floor
3 San Francisco, California 94111
Telephone: [phone]
4 Facsimile: [phone]
5 Kevin P.B. Johnson (Cal. Bar No. 177129)
[e-mail]
6 Victoria F. Maroulis (Cal. Bar No. 202603)
[e-mail]
7 555 Twin Dolphin Drive 5th Floor
Redwood Shores, California 94065
8 Telephone: [phone]
Facsimile: [phone]
9
Michael T. Zeller (Cal. Bar No. 196417)
10 [e-mail]
865 S. Figueroa St., 10th Floor
11 Los Angeles, California 90017
Telephone: [phone]
12 Facsimile: [phone]
13 Attorneys for SAMSUNG ELECTRONICS
CO., LTD., SAMSUNG ELECTRONICS
14 AMERICA, INC. and SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

18 APPLE INC., a California corporation,
Plaintiff,

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vs.

CASE NO. 11-cv-01846-LHK
DECLARATION OF BILL TRAC IN
SUPPORT OF APPLE’S
ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL

21 SAMSUNG ELECTRONICS CO., LTD., a
Korean business entity; SAMSUNG
22 ELECTRONICS AMERICA, INC., a New
York corporation; SAMSUNG
23 TELECOMMUNICATIONS AMERICA,
LLC, a Delaware limited liability company,
24
Defendants.
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02198.51855/4830896.1

Case No. 11-cv-01846-LHK
TRAC DECLARATION IN SUPPORT OF APPLE’S
MOTION TO FILE DOCUMENTS UNDER SEAL

1

I, Bill Trac, declare:

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1.

I am an associate in the law firm of Quinn Emanuel Urquhart & Sullivan, LLP,

3 counsel for Samsung Electronics Co., Ltd., Samsung Electronics America, Inc. and Samsung
4 Telecommunications America, LLC (collectively, “Samsung”).

I submit this declaration in

5 support of Apple’s Administrative Motion to File Under Seal Documents Regarding Apple’s
6 Administrative Motion for Leave to File Objection to Reply Evidence (Dkt No. 1125) .

Unless

7 otherwise indicated, I have personal knowledge of the facts set forth in this declaration and, if
8 called upon as a witness, I could and would testify as follows.
9

2.

The requested relief is necessary to protect the confidentiality of information

10 discussed in Apple’s Objection to Reply Evidence (“Objection”) and the Supplemental
11 Declaration of Ravin Balakrishnan, Ph.D. in Support of Apple’s Opposition to Samsung’s Motion
12 for Summary Judgment (“Balakrishnan Decl.”).
13

3.

Both Apple’s Objection and the Balakrishnan Decl. include discussion of and/or

14 screenshots from confidential files produced by Mitsubishi Electric Research Laboratories
15 (MERL), a third party to this litigation.

This discussion and the accompanying screenshots

16 include information regarding the contents and structure of DiamondTouch software files,
17 DTFlash libraries, demonstrations and videos for the DiamondTouch system, and other executable
18 files that have been produced by MERL as Highly Confidential – Attorney’s Eyes Only under the
19 Protective Order.
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I declare under penalty of perjury that the foregoing is true and correct.

Executed in San

22 Francisco, California on June 29, 2012.
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/s/ Bill Trac

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02198.51855/4830896.1

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Case No. 11-cv-01846-LHK
TRAC DECLARATION IN SUPPORT OF APPLE’S
MOTION TO FILE DOCUMENTS UNDER SEAL

1

Declaration of ECF Technical Failure

2

In compliance with General Order 45.VI.E and Local Rule 5-1, I made at least two

3 attempts on June 29, 2012 to file the Declaration of Bill Trac in Support of Apple’s Administrative
4 Motion to File Under Seal Documents Regarding Apple’s Administrative Motion for Leave to File
5 Objection to Reply Evidence (Dkt No. 1125), once at approximately 5pm and again at
6 approximately 8:30pm.

However, I was unable to file this Declaration due to technical

7 difficulties on the ECF website.
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I declare under penalty of perjury that the foregoing is true and correct.

Executed in San

10 Francisco, California on June 30, 2012.
11

/s/ Bill Trac

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02198.51855/4830896.1

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Case No. 11-cv-01846-LHK
TRAC DECLARATION IN SUPPORT OF APPLE’S
MOTION TO FILE DOCUMENTS UNDER SEAL

1 General Order 45 Attestation
2

I, Victoria F. Maroulis, am the ECF user whose ID and password are being used to file this

3 Declaration.

In compliance with General Order 45(X)(B), I hereby attest that Bill Trac has

4 concurred in this filing.
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/s/ Victoria Maroulis

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02198.51855/4830896.1

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Case No. 11-cv-01846-LHK
TRAC DECLARATION IN SUPPORT OF APPLE’S
MOTION TO FILE DOCUMENTS UNDER SEAL