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

Filing 502

Administrative Motion to File Under Seal filed by Apple Inc.. (Attachments: #1 Declaration, #2 Proposed Order, #3 Exhibit Apple's Opposition to Samsung's Motion to Compel, #4 Mazza Decl ISO Apple's Opposition to Samsung's Motion to Compel, #5 Ex. 1 to Mazza Decl ISO Apple's Opposition to Samsung's Motion to Compel, #6 Ex. 2 to Mazza Decl ISO Apple's Opposition to Samsung's Motion to Compel, #7 Proposed Order Denying Samsung's Motion to Compel, #8 Apple's Opposition to Samsung's Motion to Permit Samsung's Expert Itay Sherman to Review Design Materials Designated Under the Protective Order, #9 Kim Declaration ISO Apple's Opposition to Samsung's Motion to Permit Samsung's Expert Itay Sherman to Review Design Materials Designated Under the Protective Order, #10 Ex. 1 to the Kim Declaration, #11 Ex. 2 to the Kim Declaration, #12 Ex. 3 to the Kim Declaration, #13 Ex. 4 to the Kim Declaration, #14 Ex. 5 to the Kim Declaration, #15 Ex. 6 to the Kim Declaration, #16 Ex. 7 to the Kim Declaration, #17 Ex. 8 to the Kim Declaration, #18 Ex. 9 to the Kim Declaration, #19 Proposed Order Denying Samsung's Motion to Permit Samsung's Expert Itay Sherman to Review Design Materials Designated Under the Protective Order)(Hung, Richard) (Filed on 12/15/2011)

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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]

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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,
Plaintiff,

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v.

Case No.

11-cv-01846-LHK

APPLE’S 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.,

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Defendants.
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APPLE’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL
CASE NO. 11-CV-01846-LHK
sf-3083918

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In accordance with Civil L.R. 7-11 and 79-5, and General Order No. 62, Apple Inc.
(“Apple”) moves this Court for an order to seal the following documents:

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1.

Apple’s Opposition to Samsung’s Motion to Compel, filed herewith.

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2.

Declaration of Mia Mazza In Support of Apple’s Opposition to Samsung’s Motion

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to Compel, filed herewith.
3.

Apple’s Opposition to Samsung’s Motion to Permit Samsung’s Expert Itay

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Sherman to Review Design Materials Designated Under the Protective Order, filed

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herewith.

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4.

Exhibits 3-6 to the Declaration of Esther Kim in Support of Apple’s Opposition to

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Samsung’s Motion to Permit Samsung’s Expert Itay Sherman to Review Design

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Materials Designated Under the Protective Order, filed herewith.

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5.

Samsung’s Notice of Motion and Motion to Compel Apple to Produce Documents

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and Things and Provide Responsive Answers to Propounded Discovery;

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Memorandum of Points and Authorities in Support Thereof (“Samsung’s Motion

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to Compel”), filed on December 13, 2011.

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6.

Declaration of Diane C. Hutnyan in Support of Samsung’s Motion to Compel

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Production of Documents and Things and Provide Responsive Answers to

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Propounded Discovery (“Hutnyan Decl.”), filed on December 13. 2011.

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7.

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The above items 1-6 discuss and refer to documents and matters that Apple has designated

Hutnyan Decl. Exhibits 1-13 and 15-21.

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as confidential under the interim protective order. The Declaration of Cyndi Wheeler in Support

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of Apple’s Administrative Motion to File Documents Under Seal, filed herewith, establishes good

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cause to permit the sealing of these materials. Items 7 and 8 contains information that Samsung

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has designated as confidential. Apple expects that pursuant to Civil Local Rule 79(d), Samsung

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will file a declaration establishing good cause to permit the sealing of these materials.

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APPLE’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL
CASE NO. 11-CV-01846-LHK
sf-3083918

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Proposed redacted versions of items 1 and 2 are attached hereto as Exhibits A and B.

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Samsung has filed proposed redacted versions of items 3 and 4 on December 13, 2011, in

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conjunction with Samsung’s Motion to Compel.

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Dated: December 15, 2011

MORRISON & FOERSTER LLP

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By: /s/ Richard S.J. Hung
Richard S.J. Hung
Attorneys for Plaintiff
APPLE INC.

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APPLE’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL
CASE NO. 11-CV-01846-LHK
sf-3083918

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