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

Filing 456

Administrative Motion to File Under Seal filed by Samsung Electronics America, Inc.(a New York corporation), Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC(a Delaware limited liability company). (Attachments: #1 Declaration Chan Declaration, #2 Proposed Order, #3 Exhibit Tung Declaration, #4 Exhibit Exhibit A Tung Declaration, #5 Exhibit Exhibit B Tung Declaration, #6 Exhibit Exhibit C Tung Declaration, #7 Exhibit Exhibit D Tung Declaration, #8 Exhibit Exhibit E Tung Declaration, #9 Exhibit Exhibit F Tung Declaration, #10 Exhibit Exhibit G Tung Declaration, #11 Exhibit Exhibit H Tung Declaration, #12 Exhibit Exhibit I Tung Declaration, #13 Exhibit Exhibit J Tung Declaration, #14 Exhibit Exhibit K Tung Declaration, #15 Exhibit Exhibit L Tung Declaration, #16 Exhibit Exhibit M Tung Declaration, #17 Exhibit Exhibit N Tung Declaration, #18 Exhibit Exhibit O Tung Declaration, #19 Exhibit Exhibit P Tung Declaration, #20 Exhibit Exhibit Q Tung Declaration, #21 Exhibit Exhibit R Tung Declaration, #22 Exhibit Exhibit S Tung Declaration, #23 Exhibit Exhibit T Tung Declaration, #24 Exhibit Exhibit U Tung Declaration, #25 Exhibit exhibit V Tung Declaration, #26 Exhibit Exhibit W Tung Declaration, #27 Exhibit Exhibit X Tung Declaration)(Maroulis, Victoria) (Filed on 12/7/2011)

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP
Charles K. Verhoeven (Cal. Bar No. 170151)
2 [e-mail]
50 California Street, 22nd Floor
3 San Francisco, California 94111
Telephone: [phone]
4 Facsimile: [phone]
5 Kevin P.B. Johnson (Cal. Bar No. 177129)
[e-mail]
6 Victoria F. Maroulis (Cal. Bar No. 202603)
[e-mail]
7 555 Twin Dolphin Drive 5th Floor
Redwood Shores, California 94065
8 Telephone: [phone]
Facsimile: [phone]
9
Michael T. Zeller (Cal. Bar No. 196417)
10 [e-mail]
865 S. Figueroa St., 10th Floor
11 Los Angeles, California 90017
Telephone: [phone]
12 Facsimile: [phone]
13 Attorneys for SAMSUNG ELECTRONICS
CO., LTD., SAMSUNG ELECTRONICS
14 AMERICA, INC. and SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

18 APPLE INC., a California corporation,

CASE NO. 11-cv-01846-LHK

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SAMSUNG’S ADMINISTRATIVE
MOTION TO FILE DOCUMENTS
UNDER SEAL

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Plaintiff,
vs.

21 SAMSUNG ELECTRONICS CO., LTD., a
Korean business entity; SAMSUNG
22 ELECTRONICS AMERICA, INC., a New
York corporation; SAMSUNG
23 TELECOMMUNICATIONS AMERICA,
LLC, a Delaware limited liability company,
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Defendants.
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Case No. 11-cv-01846-LHK
SAMSUNG’S MOTION TO FILE DOCUMENTS UNDER SEAL

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Pursuant to Civil L.R. 7-11 and 79-5, and General Order No. 62 and the Court’s Order

2 dated December 2, 2011, Defendants Samsung Electronics Co. Ltd., Samsung Electronics
3 America, Inc., and Samsung Telecommunications America, LLC (collectively, “Samsung”)
4 hereby bring this administrative motion for an order to seal:
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1. The Declaration of Mark Tung in Support of Samsung’s Notice of Lodging of

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Materials in Opposition to Apple’s Motion for a Preliminary Injunctions (“Tung

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Declaration”); and

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2. Exhibits E, G, N, T, V, and X of the Tung Declaration.
These documents were lodged with the Court on October 17, 2011 in connection with

10 Docket Numbers 306 and 307.

Samsung has established good cause to permit filing these

11 documents under seal through the Declaration of Melissa N. Chan in Support of Samsung’s
12 Administrative Motion to File Documents Under Seal, filed herewith. In short, the above
13 documents discuss and refer to documents and things that the parties have designated as
14 confidential under the interim protective order.
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Pursuant to General Order No. 62, Samsung’s entire filing will be lodged with the Court

16 for in camera review and served on all parties.
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18 DATED: December 7, 2011
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QUINN EMANUEL URQUHART &
SULLIVAN, LLP

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By

/s/ Victoria F. Maroulis
Charles K. Verhoeven
Kevin P.B. Johnson
Victoria F. Maroulis
Michael T. Zeller
Attorneys for SAMSUNG ELECTRONICS CO.,
LTD., SAMSUNG ELECTRONICS AMERICA,
INC., and SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC

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Case No. 11-cv-01846-LHK
SAMSUNG’S MOTION TO FILE DOCUMENTS UNDER SEAL

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