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

Filing 193

Declaration of Cyndi Wheeler in Support of #169 Administrative Motion to File Under Seal filed byApple Inc.. (Attachments: #1 Proposed Order)(Related document(s) #169 ) (Bartlett, Jason) (Filed on 8/30/2011)

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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,

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Plaintiff,
v.
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,
Defendants.

Case No. 11-cv-01846-LHK
[PROPOSED] ORDER SEALING
SAMSUNG’S UNREDACTED
MOTION TO EXCLUDE ORDINARY
OBSERVER OPINIONS OF APPLE
EXPERT COOPER WOODRING
AND SUPPORTING MATERIALS
Date:
Time:
Place:
Judge:

Hon. Lucy H. Koh

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[PROPOSED] ORDER SEALING SAMSUNG’S UNREDACTED MOTION TO EXCLUDE ORDINARY
OBSERVER OPINIONS OF APPLE EXPERT COOPER WOODRING AND SUPPORTING MATERIALS
CASE NO. 11-CV-01846-LHK
sf-3040123

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Defendants Samsung Electronics Co. Ltd., Samsung Electronics America, Inc., and

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Samsung Telecommunications America, LLC (collectively, “Samsung”) filed Samsung’s

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Stipulated Administrative Motion to File Under Seal Pursuant to Civil Local Rules 7-11 and 79-5

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on August 22, 2011 in support of Samsung’s Motion to Exclude Ordinary Observer Opinions of

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Apple Expert Cooper Woodring. (D.N. 169.) Pursuant to Civil L.R. 79-5(d), Samsung moved to

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seal certain documents designated as “CONFIDENTIAL” and “HIGHLY CONFIDENTIAL

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ATTORNEYS’ EYES ONLY” by plaintiff Apple Inc. (“Apple”) under the interim protective

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order for the Northern District of California. Also pursuant to Civil L.R. 79-5(d), for the purpose

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of establishing that the designated information is sealable, Apple filed the Declaration of Cyndi

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Wheeler in Support of Sealing Samsung’s Unredacted Motion to Exclude Ordinary Observer

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Opinions of Apple Expert Cooper Woodring and Exhibits 3, 5, and 8 of the Declaration of

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Michael T. Zeller (“Wheeler Declaration”). The Wheeler Declaration provides sufficient

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evidence that the documents and information designated as confidential by Apple, and filed under

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seal by Samsung, are “privileged or protectable as a trade secret or otherwise entitled to

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protection under the law” and thus sealable. Civil L.R. 79-5(a).

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Accordingly, IT IS HEREBY ORDERED that the following documents shall be filed
under seal:
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Exhibits 3, 5 and 8 to the Declaration of Michael T. Zeller in Support of Samsung’s

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Motion to Exclude Ordinary Observer Opinions of Apple Expert Cooper Woodring
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(“Zeller Declaration”) (D.N. 177); and

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The confidential, unredacted version of Samsung’s Motion to Exclude Ordinary Observer

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Opinions of Apple Expert Cooper Woodring (D.N. 176), which includes information from

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Exhibits 3, 5 and 8 to the Zeller Declaration.

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[PROPOSED] ORDER SEALING SAMSUNG’S UNREDACTED MOTION TO EXCLUDE ORDINARY
OBSERVER OPINIONS OF APPLE EXPERT COOPER WOODRING AND SUPPORTING MATERIALS
CASE NO. 11-CV-01846-LHK
sf-3040123

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IT IS SO ORDERED.

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Dated: _______________________
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______________________________
Hon. Lucy H. Koh
United States District Judge

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[PROPOSED] ORDER SEALING SAMSUNG’S UNREDACTED MOTION TO EXCLUDE ORDINARY
OBSERVER OPINIONS OF APPLE EXPERT COOPER WOODRING AND SUPPORTING MATERIALS
CASE NO. 11-CV-01846-LHK
sf-3040123

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