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

Filing 542

Administrative Motion to File Under Seal re Samsung's Response to Apple's Opening Claim Construction Brief filed by Samsung Electronics Co. Ltd.. (Attachments: #1 Declaration Declaration of Brian Mack in Support of Motion to Seal, #2 Exhibit Samsung's Response to Apple's Opening Claim Construction Brief, #3 Exhibit Declaration of Todd M. Briggs in Support of Samsung's Response to Apple's Opening Claim Construction Brief, #4 Exhibit Exhibit A to Briggs Decl, #5 Exhibit Exhibit B to Briggs Decl, #6 Exhibit Exhibit C to Briggs Decl, #7 Exhibit Exhibit D to Briggs Decl, #8 Exhibit Exhibit E to Briggs Decl, #9 Exhibit Exhibit F to Briggs Decl, #10 Exhibit Exhibit G to Briggs Decl, #11 Exhibit Exhibit H to Briggs Decl, #12 Exhibit Exhibit I to Briggs Decl, #13 Exhibit Exhibit J to Briggs Decl, #14 Exhibit Exhibit K to Briggs Decl, #15 Exhibit Exhibit L to Briggs Decl, #16 Exhibit Exhibit M to Briggs Decl, #17 Exhibit Exhibit N to Briggs Decl, #18 Exhibit Exhibit O to Briggs Decl, #19 Exhibit Exhibit P to Briggs Decl, #20 Exhibit Exhibit Q to Briggs Decl, #21 Exhibit Exhibit R to Briggs Decl, #22 Exhibit Exhibit S to Briggs Decl, #23 Exhibit Exhibit T to Briggs Decl, #24 Exhibit Exhibit U to Briggs Decl, #25 Exhibit Exhibit V to Briggs Decl, #26 Exhibit Exhibt W to Briggs Decl, #27 Exhibit Exhibit X to Briggs Decl, #28 Proposed Order Proposed Order Granting Motion to Seal)(Maroulis, Victoria) (Filed on 12/22/2011)

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
15
16

UNITED STATES DISTRICT COURT

17

NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

18 APPLE INC., a California corporation,

CASE NO. 11-cv-01846-LHK

19

SAMSUNG’S ADMINISTRATIVE
MOTION TO FILE DOCUMENTS
UNDER SEAL

20

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,
24
Defendants.
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02198.51855/4520627.1

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

1

Pursuant to Civil L.R. 7-11 and 79-5, and General Order No. 62, Defendants Samsung

2 Electronics Co. Ltd., Samsung Electronics America, Inc., and Samsung Telecommunications
3 America, LLC (collectively, “Samsung”) hereby bring this administrative motion for an order to
4 seal:
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1. Confidential portions of Samsung’s Response to Apple’s Opening Claim
Construction Brief; and
2. Exhibits B, I, J, M, N, O, and S attached to the Declaration of Todd M. Briggs in
Support of Samsung’s Response to Apple’s Opening Claim Construction Brief.
Samsung has established good cause to permit filing these documents under seal through

10 the Declaration of Brian E. Mack in Support of Samsung’s Administrative Motion to File
11 Documents Under Seal, filed herewith.

In short, the above documents discuss and refer to

12 documents and things that Apple, Inc. has designated as confidential or highly confidential under
13 the interim protective order.
14

Pursuant to General Order No. 62, Samsung’s entire filing will be lodged with the Court

15 for in camera review and served on all parties. Pursuant to this Court’s December 7, 2011 order
16 (Dkt No. 455), proposed public redacted versions of the documents listed above are attached
17 hereto as exhibits if appropriate.
18
19 DATED: December 22, 2011
20

QUINN EMANUEL URQUHART &
SULLIVAN, LLP

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By

/s/ Victoria 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

27
28
02198.51855/4520627.1

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

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