Apple Inc. v. Samsung Electronics Co. Ltd. et al
Filing
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Administrative Motion to File Under Seal Apple's Stipulated Adminisrative Motion to File Documents Under Seal filed by Apple Inc.. (Attachments: #1 Declaration, #2 Proposed Order)(Bartlett, Jason) (Filed on 9/13/2011)
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HAROLD J. MCELHINNY (CA SBN 66781)
hmcelhinny@mofo.com
MICHAEL A. JACOBS (CA SBN 111664)
mjacobs@mofo.com
RICHARD S.J. HUNG (CA SBN 197425)
rhung@mofo.com
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: (415) 268-7000
Facsimile: (415) 268-7522
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Attorneys for Plaintiff and
Counterclaim-Defendant APPLE INC.
WILLIAM F. LEE
william.lee@wilmerhale.com
WILMER CUTLER PICKERING
HALE AND DORR LLP
60 State Street
Boston, MA 02109
Telephone: (617) 526-6000
Facsimile: (617) 526-5000
MARK D. SELWYN (SBN 244180)
mark.selwyn@wilmerhale.com
WILMER CUTLER PICKERING
HALE AND DORR LLP
950 Page Mill Road
Palo Alto, California 94304
Telephone: (650) 858-6000
Facsimile: (650) 858-6100
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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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Plaintiff,
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v.
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APPLE’S STIPULATED
ADMINISTRATIVE MOTION TO
FILE DOCUMENTS UNDER
SEAL
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.
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APPLE’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL
CASE NO. 11-CV-01846-LHK
sf-3044565
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In accordance with Civil L.R. 79-5 and 7-11, and General Order No. 62, Apple Inc.
(“Apple”) moves this Court for an order to seal:
1. The confidential, unredacted version of Apple’s Opposition to Samsung’s Motion to
Exclude Ordinary Observer Opinions of Apple Expert Cooper Woodring (“Opposition”); and
2. Exhibits B and C to the Declaration of Patrick J. Zhang in support of Apple’s
Opposition (“Zhang Declaration”).
Apple has established good cause to permit filing this information under seal through the
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Declaration of Erica Tierney in Support of Apple’s Administrative Motion to File Documents
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Under Seal (the “Sealing Declaration”), filed herewith.
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The Opposition and above-identified exhibits to the Zhang Declarations contain
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information relating to Apple’s industrial design process and competitive market research.
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(Sealing Decl. at ¶ 2.) It is Apple’s policy and practice not to disclose such information because
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it is confidential to Apple. (Id.) This information reveals the way in which Apple conducts
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product development and research into the competitive landscape surrounding its products, and
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thus can be used by Apple’s competitors to its disadvantage. (Id.)
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In conclusion, Apple requests that the Court order that the confidential, unredacted
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version of Apple’s Opposition to Samsung’s Motion to Exclude Ordinary Observer Opinions of
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Apple Expert Cooper Woodring and Exhibits B and C of the supporting Zhang Declaration be
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filed under seal.
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Pursuant to General Order No. 62, the complete, unredacted versions of Apple’s
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Opposition and the Zhang Declaration with unredacted Exhibits will be lodged with the Court for
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in camera review and served on all parties.
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Samsung does not oppose this motion.
Dated: September 13, 2011
MORRISON & FOERSTER LLP
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By: /s/ Jason R. Bartlett
JASON R. BARTLETT
Attorneys for Plaintiff
APPLE INC.
APPLE’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL
CASE NO. 11-CV-01846-LHK
sf-3044565
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