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

Filing 340

Administrative Motion to File Under Seal Samsung's Opposition to Apple's Motion for a Protective Order 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 10/28/2011)

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
ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL



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.






02198.51855/4419022.1

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

The requested relief is necessary to protect the confidentiality of information

9 discussed in Samsung’s Opposition to Apple’s Motion for a Protective Order as well as the
10 supporting Declaration of Brett Arnold (the “Arnold Declaration”) and its accompanying exhibits.
11 These documents contain information relating to Apple’s product design processes, which Apple
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has declared to be CONFIDENTIAL — ATTORNEYS’ EYES ONLY.

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3.

Exhibits A, C-E, and G-N to the Arnold Declaration are deposition transcripts and

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excerpts thereof, all of which Apple has designated, at least in part, CONFIDENTIAL —

16 ATTORNEYS’ EYES ONLY.
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4.

Exhibit B is a DVD containing video excerpts from several depositions that have

18 also been designated by Apple as CONFIDENTIAL — ATTORNEYS’ EYES ONLY.
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5.

On Thursday, October 27, 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 October 28, 2011.
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/s/ Brett Arnold

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02198.51855/4419022.1

Case No. 11-cv-01846-LHK
-2ARNOLD DECLARATION IN SUPPORT OF SAMSUNG’S
MOTION TO FILE DOCUMENTS 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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02198.51855/4419022.1

Case No. 11-cv-01846-LHK
-3ARNOLD DECLARATION IN SUPPORT OF SAMSUNG’S
MOTION TO FILE DOCUMENTS UNDER SEAL