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

Filing 213

Administrative Motion to File Under Seal Samsung's Reply in Support of its Motion to Compel filed by Samsung Electronics America, Inc., Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC. (Attachments: #1 Arnold Declaration, #2 Proposed Order)(Maroulis, Victoria) (Filed on 9/12/2011)

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP
Charles K. Verhoeven (Cal. Bar No. 170151)
 [e-mail]
50 California Street, 22nd Floor
 San Francisco, California 94111
Telephone: [phone]
 Facsimile: [phone]
 Kevin P.B. Johnson (Cal. Bar No. 177129)
[e-mail]
 Victoria F. Maroulis (Cal. Bar No. 202603)
[e-mail]
 555 Twin Dolphin Drive 5th Floor
Redwood Shores, California 94065
 Telephone: [phone]
Facsimile: [phone]

Michael T. Zeller (Cal. 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 BRETT ARNOLD IN
SUPPORT OF SAMSUNG’S
STIPULATED ADMINISTRATIVE
MOTION TO FILE UNDER SEAL ITS
REPLY BRIEF IN SUPPORT OF ITS
MOTION TO COMPEL



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,

Defendants.






02198.51855/4345537.1

Case No. 11-cv-01846-LHK
ARNOLD DECLARATION IN SUPPORT OF SAMSUNG’S MOTION TO FILE UNDER SEAL________

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I, Brett Arnold, declare:

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1.

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

3 counsel for Samsung Electronics Co., Ltd., Samsung Electronics America, Inc. and Samsung
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Telecommunications America, LLC (collectively, “Samsung”).

Unless otherwise indicated, I

have personal knowledge of the facts set forth in this declaration and, if called upon as a witness, I

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could and would testify as follows.
2.

Samsung’s Reply In Support of Its Motion to Compel Apple to Produce Documents

9 And Things In Response to Samsung’s Request for Production No. 1 and Further Responses to
10 Interrogatories Nos. 1, 3, and 6 (the “Reply”) contains information relating to Apple’s design trade
11 practices and policies, which Apple has declared to be highly confidential.
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3.

The Reply also contains reference to communications between counsel for Apple

and Samsung that Apple designated as HIGHLY CONFIDENTIAL – ATTORNEY’S EYES

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ONLY under the interim protective order.
4.

The Reply also contains reference to certain of Apple’s responses to Samsung’s

17 interrogatory requests, which Apple designated as HIGHLY CONFIDENTIAL – ATTORNEY’S
18 EYES ONLY under the interim protective order.
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5.

On Friday, September 9, 2011, counsel for Apple confirmed with counsel for

Samsung that Apple does not oppose Samsung’s Motion to Seal.

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

Executed in

24 Redwood Shores, California on September 12, 2011.
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/s/ Brett Arnold

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02198.51855/4345537.1

Case No. 11-cv-01846-LHK
ARNOLD DECLARATION IN SUPPORT OF SAMSUNG’S MOTION TO FILE UNDER SEAL

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General Order 45 Attestation
I, Victoria F. Maroulis, am the ECF user whose ID and password are being used to file this

3 Declaration.

In compliance with General Order 45(X)(B), I hereby attest that Brett Arnold has

4 concurred in this filing.
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/s/ Victoria Maroulis

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02198.51855/4345537.1

Case No. 11-cv-01846-LHK
ARNOLD DECLARATION IN SUPPORT OF SAMSUNG’S MOTION TO FILE UNDER SEAL

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