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

Filing 390

Administrative Motion to File Under Seal filed by Apple Inc.. (Attachments: #1 Declaration, #2 Proposed Order)(Olson, Erik) (Filed on 11/9/2011)

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HAROLD J. MCELHINNY (CA SBN
66781)
[e-mail]
MICHAEL A. JACOBS (CA SBN 111664)
[e-mail]
JENNIFER LEE TAYLOR (CA SBN
161368)
[e-mail]
ALISON M. TUCHER (CA SBN 171363)
[e-mail]
RICHARD S.J. HUNG (CA SBN 197425)
[e-mail]
JASON R. BARTLETT (CA SBN 214530)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: [phone]

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]

Attorneys for Plaintiff and
Counterclaim-Defendant APPLE INC

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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.

Case No. 11-cv-01846-LHK
DECLARATION OF ERIK J. OLSON
IN SUPPORT OF APPLE’S
ADMINISTRATIVE MOTION TO
FILE UNDER SEAL

SAMSUNG ELECTRONICS CO., LTD., a
Korean business entity; SAMSUNG
ELECTRONICS AMERICA, INC., a New
York corporation; and SAMSUNG
TELECOMMUNICATIONS AMERICA,
LLC, a Delaware limited liability company,
Defendants.

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DECLARATION OF ERIK J. OLSON. OLSON IN OPPOSITION TO SAMSUNG’S MOTION TO COMPEL
CASE NO. 11-CV-01846-LHK
sf-3069485

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I, Erik J. Olson, declare as follows:

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1.

I am a partner at Morrison & Foerster LLP. The facts set forth in this declaration

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are personally known to me to be true and, if called upon to testify as to the matters contained

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herein, I could and would competently testify thereto.

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2.

The requested relief is necessary to protect the confidentiality of information

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discussed in Apple’s Supplemental Statement Regarding Apple’s Motion for a Protective Order.

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That document contain information that the parties have designated as confidential, that the parties

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have jointly requested be placed under seal, and that the Court has sealed.

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3.

Apple’s statement also contains a discussion of two motions (Apple’s Motion for a

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Protective Order and Samsung’s Motion to Compel Apple to Produce Documents and Things)

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that were submitted under seal because they contained references to, and quotations from,

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documents that Apple and Samsung had designated as highly confidential.

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I declare under penalty of perjury that the foregoing is true and correct. Executed this 9th
day of November, 2011 at San Francisco, California.
/s/ Erik J. Olson
Erik J. Olson

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DECLARATION OF ERIK J. OLSON IN OPPOSITION TO SAMSUNG’S MOTION TO COMPEL
CASE NO. 11-CV-01846-LHK
sf-3069485

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