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

Filing 1181

Declaration of Bill Trac in Support of #1140 Administrative Motion to File Under Seal filed bySamsung Electronics Co. Ltd.. (Attachments: #1 Exhibit 1)(Related document(s) #1140 ) (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
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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 (PSG)
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,
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Defendants.
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02198.51855/4841071.1

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

1

Pursuant to Civil L.R. 79-5(d), Defendants Samsung Electronics Co., Ltd., Samsung

2 Electronics America, Inc., and Samsung Telecommunications America, LLC (collectively,
3 “Samsung”) submit the Declaration of Bill Trac in Support of Apple’s Administrative Motion to
4 File Documents Under Seal (Dkt. No. 1140), to establish that portions of the following document
5 are sealable:
6

•

The Declaration of Peter W. Bressler, FIDSA, in Support of Apple’s Response to

7

Samsung’s Opening Memorandum Regarding Design Patent Claim Construction

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(“Bressler Declaration”).

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DECLARATION OF BILL TRAC

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I, Bill Trac, do hereby declare as follows:

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1.

I am an associate at Quinn Emanuel Urquhart & Sullivan, LLP, counsel for

12 Samsung Electronics Co., Ltd., Samsung Electronics America, Inc., and Samsung
13 Telecommunications America, LLC (collectively, “Samsung”).

I submit this Declaration in

14 support of Apple’s Administrative Motion to File Documents Under Seal Regarding Apple’s
15 Opposition to Samsung’s Design Claim Construction (Dkt. No. 1140).

I have personal

16 knowledge of the facts set forth in this Declaration and, if called as a witness, could and would
17 competently testify to them.
18

2.

The Bressler Declaration contains discussion regarding alternative designs

19 considered by Samsung during the design and development process leading to the release of
20 certain of the accused Samsung products.

Samsung has not yet implemented these designs in

21 released products, but may do so in the future.

The information conveyed by the discussion of

22 these images, which Samsung has designated HIGHLY CONFIDENTIAL-ATTORNEYS’ EYES
23 ONLY under the Protective Order, is therefore confidential and proprietary to Samsung, and could
24 be used to its disadvantage by competitors if it were not filed under seal.

A proposed redacted

25 version of the Bressler Declaration is attached as Exhibit 1.
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02198.51855/4841071.1

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

1

I declare under penalty of perjury that the forgoing is true and correct to the best of my

2 knowledge.

Executed this 3rd day of July, 2012, in Redwood Shores, California.

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/s/ Bill Trac
Bill Trac

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02198.51855/4841071.1

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

1
2

General Order 45 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.
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/s/ Victoria Maroulis

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02198.51855/4841071.1

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