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

Filing 1186

Administrative Motion to File Under Seal Apples Opening Supplemental Claim Construction Brief filed by Apple Inc.. (Attachments: #1 [Proposed] Order Granting Apple Inc.s Administrative Motion To File Documents Under Seal, #2 Apples Opening Supplemental Claim Construction Brief, #3 Declaration Of Ravin Balakrishnan, Ph.D., In Support Of Apples Opening Supplemental Claim Construction Brief, #4 Declaration Of Deok Keun Matthew Ahn In Support Of, #5 Exhibit 1, #6 Exhibit 2, #7 Exhibit 3, #8 Exhibit 4, #9 Exhibit 5, #10 Exhibit 6, #11 Exhibit 7)(Jacobs, Michael) (Filed on 7/5/2012)

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HAROLD J. MCELHINNY (CA SBN 66781)
[e-mail]
MICHAEL A. JACOBS (CA SBN 111664)
[e-mail]
RICHARD S.J. HUNG (CA SBN 197425)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff and
Counterclaim-Defendant APPLE INC.

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]

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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APPLE INC., a California corporation,
Plaintiff,

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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 OPENING
SUPPLEMENTAL CLAIM
CONSTRUCTION BRIEF

Defendants.

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ADMIN. MOT. TO FILE UNDER SEAL DOCUMENTS RE APPLE’S OPENING SUPPLEMENTAL CLAIM
CONSTRUCTION BRIEF
CASE NO. 11-CV-01846-LHK (PSG)
sf-3167363

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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:

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1.

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The confidential, unredacted version of Apple’s Opening Supplemental Claim
Construction Brief;

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2.

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The confidential, unredacted Declaration of Ravin Balakrishnan, Ph.D. in Support
of Apple’s Opening Supplemental Claim Construction Brief; and

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3.

Exhibit 6 to the Declaration of Deok Keun Matthew Ahn in Support of Apple’s

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Opening Supplemental Claim Construction Brief, which have been designated

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confidential as set forth below.

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All three documents contain information that Samsung has represented was designated

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“under the protective order” by third party MERL, and which Samsung designated “Highly

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Confidential – Attorneys’ Eyes Only” until it could confer with third Party MERL about the

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appropriate designation. Apple expects that, pursuant to Civil Local Rule 79-5(d), either

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Samsung or third party MERL will file a declaration seeking to establish good cause to permit the

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sealing of these materials. A copy of this motion will concurrently be sent to third party MERL.

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

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issue.

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Dated: July 5, 2012

MORRISON & FOERSTER LLP

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By:

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

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ADMIN. MOT. TO FILE UNDER SEAL DOCUMENTS RE APPLE’S OPENING SUPPLEMENTAL CLAIM
CONSTRUCTION BRIEF
CASE NO. 11-CV-01846-LHK (PSG)
sf-3167363

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