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

Filing 1179

Administrative Motion to File Under Seal Samsung's Reply In Support of Opening Memorandum re Claim Construction filed by Samsung Electronics America, Inc., Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC. (Attachments: #1 Trac Declaration In Support Of Administrative Motion to Seal, #2 Proposed Order re Motion to Seal, #3 Samsung's Reply In Support of Opening Memorandum re Claim Construction, #4 Barach Declaration In Support Of Samsung's Reply, #5 Barach Decl. Ex. 1, #6 Barach Decl. Ex. 2, #7 Barach Decl. Ex. 3)(Maroulis, Victoria) (Filed on 7/3/2012)

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
15
16

UNITED STATES DISTRICT COURT

17

NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

18 APPLE INC., a California corporation,

CASE NO. 11-cv-01846-LHK

19

DECLARATION OF BILL TRAC IN
SUPPORT OF SAMSUNG’S
ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL

20

Plaintiff,
vs.

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.
25
26
27
28
02198.51855/4842122.1

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

1

I, Bill Trac, declare:

2

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 Samsung's Administrative Motion to File Documents Under Seal.

I have personal

6 knowledge of the facts set forth in this Declaration and, if called as a witness, could and would
7 competently testify to them.
8

2.

The requested relief is necessary to protect the confidentiality of information

9 contained in the following documents:
10

a.

11

The confidential, unredacted version of Samsung's Reply in Support of
Opening Memorandum Regarding Claim Construction; and

12

b.

Exhibits 1-3 to the Declaration of Katharine Barach in Support of

13

Samsung's Reply in Support of Opening Memorandum Regarding Claim

14

Construction (“Barach Declaration”).

15
3.

Exhibit 1 to the Barach Declaration consists of excerpts from the October 25, 2011

16
deposition of Quin Hoellwarth.

Apple has designated this testimony HIGHLY

17
CONFIDENTIAL – ATTORNEY EYES ONLY under the protective order.

To the extent that

18
this document contains Apple confidential information, Samsung trusts that Apple will file the
19
declaration required by Civ. L. R. 79-5(d) establishing that the information therein as sealable.
20
4.

Exhibit 2 to the Barach Declaration consists of excerpts from the October 27, 2011

21
deposition of Daniel Coster.

Apple has designated this testimony HIGHLY CONFIDENTIAL –

22
ATTORNEY EYES ONLY under the protective order.

To the extent that this document contains

23
Apple confidential information, Samsung trusts that Apple will file the declaration required by
24
Civ. L. R. 79-5(d) establishing that the information therein as sealable.
25
5.

Exhibit 3 to the Barach Declaration consists of excerpts from the November 8,

26
2011 deposition of Douglas Satzger. Apple has designated this testimony HIGHLY
27
CONFIDENTIAL – ATTORNEY EYES ONLY under the protective order.
28
02198.51855/4842122.1

To the extent that

Case No. 11-cv-01846-LHK
-2DECLARATION OF BILL TRAC IN SUPPORT OF SAMSUNG’S ADMINISTRATIVE MOTIONS TO
FILE DOCUMENTS UNDER SEAL

1 this document contains Apple confidential information, Samsung trusts that Apple will file the
2 declaration required by Civ. L. R. 79-5(d) establishing that the information therein as sealable.
3
4

I declare under penalty of perjury that the foregoing is true and correct. Executed in

5 Redwood Shores, California on July 3, 2012.
6
7
8

/s/ Bill Trac
Bill Trac

9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

02198.51855/4842122.1

Case No. 11-cv-01846-LHK
-3DECLARATION OF BILL TRAC IN SUPPORT OF SAMSUNG’S ADMINISTRATIVE MOTIONS TO
FILE DOCUMENTS UNDER SEAL

1
2

GENERAL ORDER ATTESTATION
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.
5
6

/s/ Victoria Maroulis

7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

02198.51855/4842122.1

Case No. 11-cv-01846-LHK
-4DECLARATION OF BILL TRAC IN SUPPORT OF SAMSUNG’S ADMINISTRATIVE MOTIONS TO
FILE DOCUMENTS UNDER SEAL