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

Filing 1573

MOTION for Leave to File Reply to 1556 Reuters America LLC's Opposition to Motions to Seal Trial and Pretrial Evidence filed by Qualcomm Incorporated. (Attachments: # 1 Declaration of David A. Kays, # 2 Exhibit A to Declaration of David A. Kays, # 3 Proposed Order, # 4 Certificate/Proof of Service)(Kays, David) (Filed on 8/3/2012) Modified on 8/6/2012 linking entry to document #1556 (dhm, COURT STAFF).

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DAVID KAYS, ESQ. (SBN 120798)
FREEDA LUGO, ESQ. (SBN 244913 )
MORGAN, FRANICH, FREDKIN & MARSH
99 Almaden Boulevard, Suite 1000
San Jose, California 95113-1613
Telephone: [phone]
Facsimile: [phone]
ROGER G. BROOKS, Pro Hac Vice
CRAVATH, SWAIN & MOORE LLP
Worldwide Plaza
825 Eighth Avenue
New York, NY 10019-7475
Telephone: [phone]
Facsimile: [phone]
Attorneys for Non-Party,
QUALCOMM INCORPORATED

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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,,

Case No. 11-CV-01846-LHK

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Plaintiffs,

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NON-PARTY QUALCOMM
INCORPORATED’S MOTION FOR
vs.
LEAVE TO FILE REPLY TO
REUTERS AMERICA LLC’S
SAMSUNG ELECTRONICS CO., LTD., a
Korean corporation; SAMSUNG
OPPOSITION TO MOTIONS TO
ELECTRONICS AMERICA, INC., a New
SEAL TRIAL AND PRETRIAL
York corporation; and SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC, EVIDENCE
a Delaware limited liability company,
Defendants.

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Non-Party Qualcomm Incorporated respectfully requests leave to file a reply to

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address the erroneous argument in Reuters America LLC’s Opposition to Motions to Seal

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Trial and Pretrial Evidence that Qualcomm’s administrative motion to seal is moot. As set

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forth in Qualcomm’s reply, attached as Exhibit A to the declaration of David A. Kays

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filed herewith, despite the inadvertent disclosure of the licensing terms that were the

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subject of Qualcomm’s administrative motion to seal – which Qualcomm has addressed –
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Apple, Inc. v. Samsung Electronics, Case No: 11-CV-01846-LHK
QUALCOMM'S MOTION FOR LEAVE TO FILE REPLY TO
REUTERS OPPO TO MOT. TO SEAL TRAIL/PRE\-TRIAL EVIDENCE

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sealing Qualcomm’s confidential information in this Court’s record still matters in the real

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world.

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In light of this erroneous argument directed at Qualcomm’s administrative motion to

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seal, Qualcomm respectfully requests leave to file a short reply to address this argument, a

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copy of which is attached as Exhibit A to the declaration of David A. Kays filed

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concurrently herewith.

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Dated: August 3, 2012

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MORGAN, FRANICH, FREDKIN & MARSH
CRAVATH, SWAINE & MOORE, LLP

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By:
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Apple, Inc. v. Samsung Electronics, Case No: 11-CV-01846-LHK
QUALCOMM'S MOTION FOR LEAVE TO FILE REPLY TO
REUTERS OPPO TO MOT. TO SEAL TRAIL/PRE\-TRIAL EVIDENCE

/S/
DAVID KAYS
Attorneys for Non-Party
QUALCOMM INCORPORATED