Apple Inc. v. Samsung Electronics Co. Ltd. et al
Filing
1424
Proposed Order re 1414 JOINT MOTION regarding Sealing of Trial Exhibits by Apple Inc.. (Jacobs, Michael) (Filed on 7/27/2012) Modified text on 7/30/2012 (dhm, COURT STAFF).
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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.
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[PROPOSED] ORDER GRANTING
JOINT MOTION REGARDING
SEALING OF TRIAL EXHIBITS
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,
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Case No. 11-cv-01846-LHK (PSG)
Defendants.
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02198.51855/4878038.1 PROPOSED ORDER GRANTING JOINT MOTION RE
CASE NO. 11-CV-01846-LHK (PSG)
sf-3175792
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Having considered the arguments and the papers submitted, the court ORDERS as
follows:
(1) The Parties shall use the following protocol to prepare and present to the Court any
requests for sealing trial exhibits anticipated to be received in evidence, or portions thereof:
In accordance with the Court’s previous orders, the parties shall disclose the names
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of witnesses to be examined and the exhibits and demonstratives to be used on
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direct examination no later than 7 p.m. two days before the witnesses are expected
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to testify. No later than 8 a.m. the following morning, the parties shall jointly
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lodge highlighted copies of exhibits and demonstratives showing the portions of
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the exhibits, if any, for which sealing treatment is requested.
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In accordance with the Court’s previous orders, the parties shall disclose the
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exhibits and demonstratives to be used on cross examination no later than 2 p.m.,
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one day before the witnesses are expected to testify. No later than 5 p.m. the
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same day, the parties shall jointly lodge highlighted copies of exhibits and
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demonstratives showing the portions of the exhibits, if any, for which sealing
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treatment is requested.
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(2) The Parties shall narrowly tailor their sealing requests to the following categories of
documents:
Highly sensitive financial information pertaining to costs, profit margins, revenues
and unit sales on a product-line or model basis;
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Manufacturing capacity information;
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Specific terms of licenses, settlements and acquisitions; and
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Specific portions of source code that are highly sensitive.
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(3) In addition to the above, receipt in evidence of other highly sensitive information may
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be limited to those exhibit portions that are actually published to the jury during trial. Such
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highly sensitive information may include:
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Other detailed technical documentation; or
Sensitive internal market research reports.
02198.51855/4878038.1 PROPOSED ORDER GRANTING JOINT MOTION RE
CASE NO. 11-CV-01846-LHK (PSG)
sf-3175792
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The parties shall meet and confer promptly at the end of each trial day to identify the portions of
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such documents that were published to the jury.
The categories listed above are not dispositive. The Court may evaluate all sealing
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requests on a document-by-document basis.
IT IS SO ORDERED.
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Dated: ____
_, 2012
By:
Honorable Lucy H. Koh
United States District Judge
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PROPOSED ORDER GRANTING APPLE’S MOTION TO FILE UNDER SEAL
L
02198.51855/4878038.1
sf-3175792
CASE NO. 11-CV-01846-LHK
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