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

Filing 1490

Administrative Motion to File Under Seal Samsung's Renewed Motion to 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. (Attachments: # 1 Declaration of GiHo Ro in Support of Samsung's Renewed Administrative Motion, # 2 Declaration of Prashanth Chennakesavan in Support of Samsung's Renewed Administrative Motion, # 3 Exhibit 1-15 to the Chennakesavan Declaration, # 4 Proposed Order Granting Samsung's Renewed Administrative Motion to File Under Seal)(Maroulis, Victoria) (Filed on 7/30/2012)

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP
Charles K. Verhoeven (Bar No. 170151)
 [e-mail]
50 California Street, 22nd Floor
 San Francisco, California 94111
Telephone: [phone]
 Facsimile: [phone]
 Kevin P.B. Johnson (Bar No. 177129)
[e-mail]
 Victoria F. Maroulis (Bar No. 202603)
[e-mail]
555 Twin Dolphin Drive, 5th Floor

Redwood Shores, California 94065-2139
 Telephone: [phone]
Facsimile: [phone]

Michael T. Zeller (Bar No. 196417)
 [e-mail]
865 S. Figueroa St., 10th Floor
 Los Angeles, California 90017
Telephone: [phone]
 Facsimile: [phone]
 Attorneys for SAMSUNG ELECTRONICS CO.,
LTD., SAMSUNG ELECTRONICS AMERICA,
 INC. and SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC



UNITED STATES DISTRICT COURT



NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION


 APPLE INC., a California corporation,

CASE NO. 11-cv-01846-LHK



DECLARATION OF PRASHANTH
CHENNAKESAVAN IN SUPPORT OF
SAMSUNG’S RENEWED
ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL



Plaintiff,
vs.

 SAMSUNG ELECTRONICS CO., LTD., a
Korean business entity; SAMSUNG
 ELECTRONICS AMERICA, INC., a New
York corporation; SAMSUNG
 TELECOMMUNICATIONS AMERICA,
LLC, a Delaware limited liability company,

Defendant.



02198.51855/4873814.3

Case No. 11-cv-01846-LHK
DECLARATION OF PRASHANTH CHENNAKESAVAN

1

I, Prashanth Chennakesavan, declare:



1.

I am an associate with the law firm of Quinn Emanuel Urquhart & Sullivan, LLP,

 counsel for Samsung Electronics Co., Ltd., Samsung Electronics America, Inc., and Samsung
 Telecommunications America, LLC (collectively “Samsung”). I have personal knowledge of the
 facts set forth in this declaration and, if called upon as a witness, I could and would testify to such
 facts under oath.


2.

I make this declaration in support of Samsung’s Renewed Administrative Motion to

 File Documents Under Seal.


3.

Attached hereto as Exhibit 1 is a proposed redacted version of Samsung’s Notice

 of Motion and Motion to Exclude Opinions of Certain of Apple’s Experts (Dkt. No. 927). The
 portions of the document that Samsung requests be sealed are highlighted in yellow.


4.

Attached hereto as Exhibits 2, 3, 4, and 5 are proposed redacted versions of

 Exhibits 1, 3, 5, and 2, respectively, to the Declaration of Joby Martin in Support of Samsung’s
 Motion to Exclude Opinions of Certain of Apple’s Experts (Dkt. No. 927). The portions of the
 documents that Samsung requests be sealed are highlighted in yellow.


5.

Attached hereto as Exhibits 6 and 7 are proposed redacted versions of Exhibits F

 and G, respectively, to the Declaration of Terry Musika, CPA in Support of Apple’s Opposition to
 Samsung’s Motion to Exclude Opinions of Certain of Apple’s Experts (Dkt. No. 991). The
 portions of the documents that Samsung requests be sealed are highlighted in yellow.


6.

Attached hereto as Exhibit 8 is a proposed redacted version of Exhibit O to the

 Declaration of Michel Maharbiz, Ph.D. in Support of Apple’s Opposition to Samsung’s Motion
 for Summary Judgment (Dkt. No. 1013). The portions of the document that Samsung requests be
 sealed are highlighted in yellow.


7.

Attached hereto as Exhibit 9 is a proposed redacted version of Exhibit 37 to the

 Declaration of Peter Bressler in Support of Apple’s Opposition to Samsung’s Motion for
 Summary Judgment (Dkt. No. 1022). The portions of the document that Samsung requests be
 sealed are highlighted in yellow.

02198.51855/4873814.3

Case No. 11-cv-01846-LHK
DECLARATION OF PRASHANTH CHENNAKESAVAN

-1-

1

8.

Attached hereto as Exhibit 10 is a proposed redacted version of Exhibit B to the

2 Declaration of Michael J. Wagner in Support of Samsung’s Motion to Strike Expert Testimony
3 Based on Undisclosed Facts and Theories (Dkt. No. 1060). The portions of the document that
4 Samsung requests be sealed are highlighted in yellow.
5

9.

Attached hereto as Exhibit 11 is a proposed redacted version of Apple’s

6 Oppositions to Samsung’s Motions in Limine (Dkt. No. 1206). The portions of the document that
7 Samsung requests be sealed are highlighted in yellow.
8

10.

Attached hereto as Exhibits 12, 13, and 14 are proposed redacted versions of

9 Exhibits 42, 43, and 44, respectively, to the Declaration of Joseph Kanada in Support of Apple’s
10 Oppositions to Samsung’s Motions in Limine (Dkt. No. 1206). The portions of the documents that
11 Samsung requests be sealed are highlighted in yellow.
12

11.

Attached hereto as Exhibit 15 is a proposed redacted version of Exhibit 10 to the

13 Declaration of Joby Martin in Support of Samsung’s Motion to Exclude Opinions of Certain of
14 Apple’s Experts (Dkt. No. 927). The portions of the document that Samsung requests be sealed are
15 highlighted in yellow.
16
17

I declare under penalty of perjury that the foregoing is true and correct. Executed in Los

18 Angeles, California on July 30, 2012.
19
20
/s/ Prashanth Chennakesavan

21
22

Prashanth Chennakesavan

23
24
25
26
27
28
02198.51855/4873814.3

Case No. 11-cv-01846-LHK
DECLARATION OF PRASHANTH CHENNAKESAVAN

-2-

1

GENERAL ORDER ATTESTATION

2
I, Victoria Maroulis, am the ECF user whose ID and password are being used to file the
3
foregoing document. I hereby attest pursuant to General Order 45.X.B. that concurrence in the
4
electronic filing of this document has been obtained from Prashanth Chennakesavan.
5
6
/s/ Victoria Maroulis
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
02198.51855/4873814.3

Case No. 11-cv-01846-LHK
DECLARATION OF PRASHANTH CHENNAKESAVAN

-3-