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

Filing 147

Administrative Motion to File Under Seal filed by Samsung Electronics America, Inc., Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC. (Maroulis, Victoria) (Filed on 8/8/2011)

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]
th
7 555 Twin Dolphin Drive 5 Floor
Redwood Shores, California 94065
8 Telephone: [phone]
Facsimile: [phone]
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Edward DeFranco (Cal. Bar No.165596)
10 [e-mail]
51 Madison Avenue, 22nd Floor
11 New York, New York 10010
Telephone: [phone]
12 Facsimile: [phone]
13 Michael T. Zeller (Cal. Bar No. 196417)
[e-mail]
14 865 S. Figueroa St., 10th Floor
Los Angeles, California 90017
15 Telephone: [phone]
Facsimile: [phone]
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Attorneys for Samsung Electronics America, Inc.
17 and Samsung Telecommunications America LLC
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

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APPLE INC., a California corporation,
Plaintiff,

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vs.

SAMSUNG ELECTRONICS CO., LTD., a
24 Korean business entity; SAMSUNG
ELECTRONICS AMERICA, INC., a New
25 York corporation; SAMSUNG
TELECOMMUNICATIONS AMERICA,
26 LLC, a Delaware limited liability company,
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CASE NO. 11-cv-01846-LHK
SAMSUNG’S ADMINISTRATIVE
MOTION TO FILE DOCUMENTS
UNDER SEAL
Date: August 24, 2011
Time: 2:00 pm
Place: Courtroom 4, 5th Floor
Judge: Hon. Lucy H. Koh

Defendants.

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Case No. 11-cv-01846-LHK
SAMSUNG’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL

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Pursuant to Civil L.R. 79-5 and 7-11, and General Order No. 62, Samsung Electronics

2 America, Inc. (“SEA”) and Samsung Telecommunications America, LLC (“STA”) (collectively
3 “Samsung”) hereby bring this administrative motion for a sealing order to seal portions of the
4 Declaration of Eunha Kim In Support of Samsung’s Reply In Support of its Motion to Disqualify
5 Bridges & Mavrakakis LLP. (the “Kim Reply Declaration”), Exhibit F attached to the Declaration
6 of Austin Tarango In Support of Samsung's Reply In Support of its Motion to Disqualify Bridges
7 & Mavrakakis, LLP (“Tarango Reply Declaration”) and the corresponding discussion of this
8 confidential information in Samsung's Reply In Support of Its Motion to Disqualify Bridges &
9 Mavrakakis LLP. (“Reply”).
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The Kim Reply Declaration, contains confidential, non-public information regarding a

11 settlement meeting that occurred between Apple and Samsung in or about September 2010.
12 Pursuant to General Order No. 62, a copy of the Declaration has been lodged with the Court for in
13 camera review, served on all parties, and will be e-filed with the Court pending the Court’s
14 granting of this Motion to Seal. The following portions of the Declaration of Eunha Kim have
15 been properly filed under seal because they contain confidential information: ¶¶ 5-6.
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Exhibit F of the Tarango Reply Declaration contains excerpts from the deposition of Mr.

17 Richard Lutton. Apple has designated this deposition HIGHLY CONFIDENTIAL18 ATTORNEYS' EYES ONLY under the interim protective order. These deposition excerpts also
19 relate to the settlement meetings between Samsung and Apple and include detailed descriptions of
20 the confidential discussions that took place at these meetings between the parties. Pursuant to
21 General Order No. 62, a copy of Exhibit F has been lodged with the Court for in camera review,
22 served on all parties, and will be e-filed with the Court pending the Court's granting of this Motion
23 to Seal.
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Samsung’s Reply contains confidential, non-public information regarding a settlement

25 meeting that occurred between Apple and Samsung. This includes discussion of the September
26 2010 meeting between Samsung and Apple, as well as the other meetings discussed by Mr.
27 Richard Lutton in his deposition. Pursuant to General Order No. 62, a copy of the Reply has been
28 lodged with the Court for in camera review, served on all parties, and will be e-filed with the
Case No. 11-cv-01846-LHK
-1SAMSUNG’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL

1 Court pending the Court’s granting of this Motion to Seal. The following portions of the Reply
2 have been properly filed under seal because they contain confidential information: Lines 18-20
3 and 22-24 on page 12, and lines 7-10 and 11-14 on page 14.
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This request is narrowly tailored to seal only the material for which good cause to seal has

5 been established. Accordingly, Samsung respectfully requests that the Court order that Paragraphs
6 5-6 of the Kim Reply Declaration, Exhibit F attached to the Tarango Reply Declaration, and the
7 portions of Samsung’s Reply discussing this confidential information be filed under seal.
8 DATED: August 8, 2011
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QUINN EMANUEL URQUHART &
SULLIVAN, LLP

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By /s/ Victoria F. Maroulis
Charles K. Verhoeven
Kevin P.B. Johnson
Victoria F. Maroulis
Edward DeFranco
Michael T. Zeller
Attorneys for SAMSUNG ELECTRONICS
AMERICA, INC., and SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC

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Case No. 11-cv-01846-LHK
-2SAMSUNG’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL