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

Filing 282

STIPULATED ADMINISTRATIVE MOTION to File Under Seal Apple's Reply in Support of Its Motion for Preliminary Injunction and Related Documents filed by Apple Inc.. (Attachments: #1 Declaration, #2 Proposed Order)(Jacobs, Michael) (Filed on 9/30/2011) Modified text on 10/4/2011 (dhm, COURT STAFF).

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HAROLD J. MCELHINNY (CA SBN 66781)
[e-mail]
MICHAEL A. JACOBS (CA SBN 111664)
[e-mail]
RICHARD S.J. HUNG (CA SBN 197425)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff and
Counterclaim-Defendant APPLE INC.

WILLIAM F. LEE
[e-mail]
WILMER CUTLER PICKERING
HALE AND DORR LLP
60 State Street
Boston, MA 02109
Telephone: [phone]
Facsimile: [phone]
MARK D. SELWYN (SBN 244180)
[e-mail]
WILMER CUTLER PICKERING
HALE AND DORR LLP
950 Page Mill Road
Palo Alto, California 94304
Telephone: [phone]
Facsimile: [phone]

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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,
Plaintiff,

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v.
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.,

Case No.

11-cv-01846-LHK

[PROPOSED] ORDER GRANTING
APPLE’S STIPULATED
ADMINISTRATIVE MOTION TO
FILE UNDER SEAL ITS REPLY IN
SUPPORT OF ITS MOTION FOR A
PRELIMINARY INJUNCTION
AND SUPPORTING DOCUMENTS

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Defendants.
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[PROPOSED] ORDER GRANTING MOTION TO FILE DOCUMENTS UNDER SEAL
CASE NO. 11-CV-01846-LHK
sf-3051330

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By administrative motion, Plaintiff Apple Inc. (“Apple”) has moved to file under seal

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portions of its Reply in Support of its Motion for a Preliminary Injunction and certain supporting

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documents. In support of its motion, Apple has filed the declaration required under Civil L.R.

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Rule 79-5 and General Order No. 62, which provides evidence of good cause for this Court to

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permit filing under seal. The declaration establishes that information contained in the documents

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listed below is “privileged or protectable as a trade secret or otherwise entitled to protection under

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the law.” Civil L.R. 79-5(a). Apple’s request is narrowly tailored to seek the sealing only of

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sealable information.

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Samsung does not oppose this administrative motion.
Accordingly, for good cause shown, the Court ORDERS that the following documents
shall be filed under seal:
1.

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a Preliminary Injunction (“Reply”);
2.

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The confidential, unredacted version of Apple’s Reply in Support of its Motion for

The confidential, unredacted version of the Reply Declaration of Tony Blevins in
Support of Apple’s Motion for a Preliminary Injunction (“Blevins Declaration”);

3.

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The Reply Declaration of Richard J. Lutton, Jr. in Support of Apple’s Motion for a
Preliminary Injunction (“Lutton Reply Declaration”);

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4.

Exhibits A, B, and C to the Lutton Reply Declaration;

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5.

The Reply Declaration of Terry Musika in Support of Apple’s Motion for a

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Preliminary Injunction (“Musika Declaration”);

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6.

Exhibits 1, 2, 3, and 4 to the Musika Declaration;

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7.

The Reply Declaration of Arthur Rangel in Support of Apple’s Motion for a

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Preliminary Injunction (“Rangel Declaration”);

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8.

Exhibits A, B, and C to the Rangel Declaration;

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9.

The confidential, unredacted version of the Reply Declaration of Sanjay Sood in

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Support of Apple’s Motion for a Preliminary Injunction (“Sood Declaration”);
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Exhibits D and H to the Sood Declaration;

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[PROPOSED] ORDER GRANTING MOTION TO FILE DOCUMENTS UNDER SEAL

Case No. 11-cv-01846-LHK
sf-3051330

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11.

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The Reply Declaration of Christopher Stringer in Support of Apple’s Motion for a
Preliminary Injunction (“Stringer Declaration”);

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Exhibits 1-9 to the Stringer Declaration;

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The confidential, unredacted version of the Reply Declaration of Cooper C.

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Woodring in Support of Apple’s Motion for a Preliminary Injunction (“Woodring

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Reply Declaration”);

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14.

Exhibit 1 to the Woodring Reply Declaration; and

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15.

Exhibits A, B, C, D, M, P, S, W, Z, EE, FF, GG, JJ, KK and LL to the Declaration

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of Francis Ho in Support of Apple’s Motion for a Preliminary Injunction.

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The Court further ORDERS that redacted versions of the following documents shall be
filed on ECF:

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1. Apple’s Reply in Support of its Motion for a Preliminary Injunction;

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2. the Blevins Declaration;

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3. the Sood Declaration; and

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4. the Woodring Reply Declaration.

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IT IS SO ORDERED.

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Dated: ___________________, 2011

By:
HONORABLE LUCY H. KOH
UNITED STATES DISTRICT COURT
JUDGE

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[PROPOSED] ORDER GRANTING MOTION TO FILE DOCUMENTS UNDER SEAL

Case No. 11-cv-01846-LHK
sf-3051330

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