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

Filing 1375

Administrative Motion to File Under Seal Samsung's Corrected Renewed Administrative Motion to File Under Seal (Dkt. Nos. 927, 991, 1013, 1022, 1060, 1206) filed by Samsung Electronics America, Inc.(a New York corporation), Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC(a Delaware limited liability company). (Attachments: # 1 Exhibit 1 to Samsung's Motion (Corrected), # 2 Declaration of GiHo Ro (Corrected), # 3 Declaration of Prashanth Chennakesavan (Corrected))(Maroulis, Victoria) (Filed on 7/26/2012)

CORRECTED EXHIBIT 1 TO SAMSUNG’S ADMINISTRATIVE MOTION
Table A – Documents to Be Sealed
Docket #

Name of Filing

Portion to Be Sealed

927

Samsung’s Motion to
Exclude Opinions of
Certain of Apple’s
Experts

Highly sensitive financial
information related to costs of
goods.

927

Ex. 1 to Martin
Declaration in Support
of Samsung’s Notice
of Motion and Motion
to Exclude Opinions
of Certain of Apple’s
Experts

Highly sensitive financial
information related to operating
profits

927

Ex. 2 to Martin Decl.
of Giho Ro in Support
of Samsung’s Motion
to Exclude Opinions
of Certain of Apple’s
Experts

Highly sensitive financial
information related to costs of
goods, and profits

02198.51855/4875937.1

Compelling Reason for
Sealing
Highly sensitive financial
information is subject to
extraordinary level of security
within Samsung, has never been
made public, represents
extensive investment, and could
be vehicle for improper
purposes in hands of
competitors and others. (Decl.
of Giho Ro at ¶¶ 3-4, 6.) See
Bauer Bros. LLC v. Nike, Inc.,
No. 09cv500–WQH–BGS, 2012
WL 1899838, at *3-4 (S.D. Cal.
May 24, 2012).
Highly sensitive financial
information is subject to
extraordinary level of security
within Samsung, has never been
made public, represents
extensive investment, and could
be vehicle for improper
purposes in hands of
competitors and others. (Decl.
of Giho Ro at ¶¶ 5-6.) See
Bauer Bros. LLC v. Nike, Inc.,
No. 09cv500–WQH–BGS, 2012
WL 1899838, at *3-4 (S.D. Cal.
May 24, 2012).
Highly sensitive financial
information is subject to
extraordinary level of security
within Samsung, has never been
made public, represents
extensive investment, and could
be vehicle for improper
purposes in hands of
competitors and others. (Decl.
of Giho Ro at ¶¶ 9-10.) See
Bauer Bros. LLC v. Nike, Inc.,
No. 09cv500–WQH–BGS, 2012
WL 1899838, at *3-4 (S.D. Cal.
May 24, 2012).

Docket #

Name of Filing

Portion to Be Sealed

927

Ex. 3 to Martin
Declaration in Support
of Samsung’s Motion
to Exclude Opinions
of Certain of Apple’s
Experts

Highly sensitive financial
information related to costs of
goods, profits, and transfer pricing

927

Ex. 5 to Martin
Declaration in Support
of Samsung’s Motion
to Exclude Opinions
of Certain of Apple’s
Experts

Highly sensitive financial
information related to costs of
goods and profits

927

Ex. 10 to Martin
Declaration in Support
of Samsung’s Motion
to Exclude Opinions
of Certain of Apple’s
Experts

Highly sensitive financial
information related to profits and
profit margins, losses, and costs of
goods

02198.51855/4875937.1

Compelling Reason for
Sealing
Highly sensitive financial
information is subject to
extraordinary level of security
within Samsung, has never been
made public, represents
extensive investment, and could
be vehicle for improper
purposes in hands of
competitors and others. (Decl.
of Giho Ro at ¶¶ 5-6.) See
Bauer Bros. LLC v. Nike, Inc.,
No. 09cv500–WQH–BGS, 2012
WL 1899838, at *3-4 (S.D. Cal.
May 24, 2012).
Highly sensitive financial
information is subject to
extraordinary level of security
within Samsung, has never been
made public, represents
extensive investment, and could
be vehicle for improper
purposes in hands of
competitors and others. (Decl.
of Giho Ro at ¶¶ 5-6.) See
Bauer Bros. LLC v. Nike, Inc.,
No. 09cv500–WQH–BGS, 2012
WL 1899838, at *3-4 (S.D. Cal.
May 24, 2012).
Highly sensitive financial
information is subject to
extraordinary level of security
within Samsung, has never been
made public, represents
extensive investment, and could
be vehicle for improper
purposes in hands of
competitors and others. (Decl.
of Giho Ro at ¶¶ 7-8.) See
Bauer Bros. LLC v. Nike, Inc.,
No. 09cv500–WQH–BGS, 2012
WL 1899838, at *3-4 (S.D. Cal.
May 24, 2012).

Docket #

Name of Filing

Portion to Be Sealed

991

Ex. F to Declaration of
Terry L. Musika in
Support of Apple’s
Opposition to
Samsung’s Motion for
Summary Judgment

Highly sensitive financial
information related to profits and
profit margins, losses, and costs of
goods

991

Ex. G to Declaration
of Terry L. Musika in
Support of Apple’s
Opposition to
Samsung’s Motion for
Summary Judgment

Highly sensitive financial
information related to profits and
profit margins, losses, and costs of
goods

1013

Exhibit O to the
Declaration of Michel
Maharbiz in Support
of Apple’s Opposition
to Samsung’s Motion
for Summary
Judgment

Highly sensitive financial
information related to costs of
goods.

02198.51855/4875937.1

Compelling Reason for
Sealing
Highly sensitive financial
information is subject to
extraordinary level of security
within Samsung, has never been
made public, represents
extensive investment, and could
be vehicle for improper
purposes in hands of
competitors and others. (Decl.
of Giho Ro at ¶ 11.) See Bauer
Bros. LLC v. Nike, Inc., No.
09cv500–WQH–BGS, 2012 WL
1899838, at *3-4 (S.D. Cal.
May 24, 2012).
Highly sensitive financial
information is subject to
extraordinary level of security
within Samsung, has never been
made public, represents
extensive investment, and could
be vehicle for improper
purposes in hands of
competitors and others. (Decl.
of Giho Ro at ¶ 11.) See Bauer
Bros. LLC v. Nike, Inc., No.
09cv500–WQH–BGS, 2012 WL
1899838, at *3-4 (S.D. Cal.
May 24, 2012).
Highly sensitive financial
information is subject to
extraordinary level of security
within Samsung, has never been
made public, represents
extensive investment, and could
be vehicle for improper
purposes in hands of
competitors and others. (Decl.
of Giho Ro at ¶ 12.) See Bauer
Bros. LLC v. Nike, Inc., No.
09cv500–WQH–BGS, 2012 WL
1899838, at *3-4 (S.D. Cal.
May 24, 2012).

Docket #

Name of Filing

Portion to Be Sealed

1022

Ex. 37 to Declaration
of Peter Bressler in
support of Apple’s
Opposition to
Samsung’s Motion for
Summary Judgment

Highly sensitive financial
information related to profits and
costs of goods

1060

Ex. B to Declaration
of Michael J. Wagner
in Support of
Samsung’s Reply in
Support of Motion to
Strike Expert
Testimony Based on
Undisclosed Facts and
Theories

Highly sensitive information
related to revenues, pricing, and
profits.

1206

Apple’s Opposition to
Samsung’s Motions in
Limine

Highly sensitive information
related to tax accounting and
profits

02198.51855/4875937.1

Compelling Reason for
Sealing
Highly sensitive financial
information is subject to
extraordinary level of security
within Samsung, has never been
made public, represents
extensive investment, and could
be vehicle for improper
purposes in hands of
competitors and others. (Decl.
of Giho Ro at ¶ 13.) See Bauer
Bros. LLC v. Nike, Inc., No.
09cv500–WQH–BGS, 2012 WL
1899838, at *3-4 (S.D. Cal.
May 24, 2012).
Highly sensitive financial
information is subject to
extraordinary level of security
within Samsung, has never been
made public, represents
extensive investment, and could
be vehicle for improper
purposes in hands of
competitors and others. (Decl.
of Giho Ro at ¶¶ 14-15.) See
Bauer Bros. LLC v. Nike, Inc.,
No. 09cv500–WQH–BGS, 2012
WL 1899838, at *3-4 (S.D. Cal.
May 24, 2012).
Highly sensitive financial
information is subject to
extraordinary level of security
within Samsung, has never been
made public, represents
extensive investment, and could
be vehicle for improper
purposes in hands of
competitors and others. (Decl.
of Giho Ro at ¶ 16.) See Bauer
Bros. LLC v. Nike, Inc., No.
09cv500–WQH–BGS, 2012 WL
1899838, at *3-4 (S.D. Cal.
May 24, 2012).

Docket #

Name of Filing

Portion to Be Sealed

1206

Ex. 42 to Declaration
of Kanada in Support
of Apple’s Opposition
to Samsung’s Motions
in Limine

Highly sensitive financial
information related to profits
(broken down by product)

1206

Ex. 43 to Declaration
of Kanada in Support
of Apple’s Opposition
to Samsung’s Motions
in Limine

Highly sensitive financial
information related to profits

1206

Ex. 44 to Declaration
of Kanada in Support
of to Apple’s
Opposition to
Samsung’s Motions in
Limine

Highly sensitive financial
information related to profits

02198.51855/4875937.1

Compelling Reason for
Sealing
Highly sensitive financial
information is subject to
extraordinary level of security
within Samsung, has never been
made public, represents
extensive investment, and could
be vehicle for improper
purposes in hands of
competitors and others. (Decl.
of Giho Ro at ¶ 17.) See Bauer
Bros. LLC v. Nike, Inc., No.
09cv500–WQH–BGS, 2012 WL
1899838, at *3-4 (S.D. Cal.
May 24, 2012).
Highly sensitive financial
information is subject to
extraordinary level of security
within Samsung, has never been
made public, represents
extensive investment, and could
be vehicle for improper
purposes in hands of
competitors and others. (Decl.
of Giho Ro at ¶ 18.) See Bauer
Bros. LLC v. Nike, Inc., No.
09cv500–WQH–BGS, 2012 WL
1899838, at *3-4 (S.D. Cal.
May 24, 2012).
Highly sensitive financial
information is subject to
extraordinary level of security
within Samsung, has never been
made public, represents
extensive investment, and could
be vehicle for improper
purposes in hands of
competitors and others. (Decl.
of Giho Ro at ¶ 19.) See Bauer
Bros. LLC v. Nike, Inc., No.
09cv500–WQH–BGS, 2012 WL
1899838, at *3-4 (S.D. Cal.
May 24, 2012).