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

Filing 519

Administrative Motion to File Under Seal Apples Motion to Augment Record on its Motion for Preliminary Injunction filed by Apple Inc.. (Attachments: #1 Proposed Order Proposed Order Sealing 10-11 Motion to Augment)(Hung, Richard) (Filed on 12/20/2011)

1
2
3
4
5
6

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: 415.268.7522

7
8
9

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 (CA SBN 244180)
[e-mail]
WILMER CUTLER PICKERING HALE
AND DORR LLP
950 Page Mill Road
Palo Alto, California 94304
Attorneys for Plaintiff
APPLE INC.

10
11

UNITED STATES DISTRICT COURT

12

NORTHERN DISTRICT OF CALIFORNIA

13

SAN JOSE DIVISION

14
15

APPLE INC., a California corporation,
Plaintiff,

16
17
18
19
20

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

21
Defendants.
22
23
24
25
26
27
28
ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL
CASE NO. 11-cv-01846-LHK
sf- 3085321

Case No.

11-cv-01846-LHK

ADMINISTRATIVE MOTION TO
SEAL APPLE’S MOTION TO
AUGMENT RECORD ON ITS
MOTION FOR PRELIMINARY
INJUNCTION

1

In accordance with Civil L.R. 7-11 and 79-5, and General Order No. 62, Apple moves this

2

Court for an Order sealing portions of: (1) Apple’s Administrative Motion to Augment Record on

3

Its Motion for Preliminary Injunction, which was filed on Oct. 11, 2011 (“Motion to Augment”);

4

and (2) Declaration of Minn Chung in Support of Apple’s Administrative Motion to Augment

5

Record (“Chung Decl.”).

6

Section B.1 of the Motion to Augment discusses Exhibits A through D of the Chung

7

Decl., which Samsung had designated as “Highly Confidential—Attorneys Eyes Only.” Section

8

B.2 of the Motion to Augment discusses Exhibit E of the Chung Declaration, which Samsung

9

also had designated as “Highly Confidential—Attorneys’ Eyes Only.” Paragraphs 3 through 6 of

10

the Chung Declaration discuss Exhibits A through D. Paragraph 7 of the Chung Declaration

11

discusses Exhibit E.

12

The Court’s December 16, 2011, Order granted Apple’s request to seal Exhibits A through

13

D, but denied the request to seal Exhibit E. See Order Granting in Part and Denying in Part

14

Motion to Seal (Dkt. 510) (“Order”).

15

Samsung has informed Apple that Samsung plans to ask the Court to reconsider its

16

decision not to seal Exhibit E to the Chung Declaration. Apple is therefore lodging herewith a

17

redacted version of the Motion to Augment, narrowly tailored to seal only Section B.1. It also

18

has lodged herewith a redacted version of the Chung Declaration, narrowly tailored to seal

19

portions of only Paragraphs 3 through 6. In the event Samsung’s motion for reconsideration is

20

granted, revised versions of the Motion to Augment and Chung Declaration lodged herewith will

21

need to be submitted.

22

Dated: December 20, 2011

MORRISON & FOERSTER LLP

23
24
25

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

26
27
28
ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL
CASE NO. 11-cv-01846-LHK
sf- 3085321

1