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

Filing 553

Declaration of Cyndi Wheeler in Support of #548 Administrative Motion to File Under Seal , #542 Administrative Motion to File Under Seal re Samsung's Response to Apple's Opening Claim Construction Brief - in Support of Samsungs Administrative Motions To File Documents Under Seal filed byApple Inc.. (Attachments: #1 Proposed Order Proposed Order)(Related document(s) #548 , #542 ) (Bartlett, Jason) (Filed on 12/29/2011)

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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

[PROPOSED] ORDER GRANTING
SAMSUNG’S ADMINISTRATIVE
MOTIONS 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,
Defendants.

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[PROPOSED] ORDER GRANTING SAMSUNG’S ADMINISTRATIVE MOTIONS TO FILE DOCUMENTS UNDER SEAL
CASE NO. 11-CV-01846-LHK
sf-3088616

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By administrative motion, Samsung moved to file the below-listed documents, which

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contain Apple-confidential material, under seal. [Dkt. Nos. 542 and 548.] In support of

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Samsung’s motions, Apple has filed the declaration required under Civil L.R. Rule 79-5(d) and

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General Order No. 62, which provides evidence of good cause for this Court to permit filing

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under seal. The declaration establishes that information contained in the documents listed below

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is “privileged or protectable as a trade secret or otherwise entitled to protection under the law.”

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Civil L.R. 79-5(a). The motion is narrowly tailored to seek the sealing only of sealable

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information.

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Accordingly, for good cause shown, the Court ORDERS that the following documents
shall be filed under seal:
1.

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Response to Apple’s Opening Claim Construction Brief (“Briggs Declaration”).
2.

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Exhibit B, I, and J to the Declaration of Todd M. Briggs in Support of Samsung’s

Samsung’s Response to Apple’s Opening Claim Construction Brief, to the extent it
discusses or quotes the contents of Exhibits B, I, or J to the Briggs Declaration.

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Pages 74-76, 98, 209-10, 213, 222, 224-28, and 248 of Exhibit X to the

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Declaration of Mark Tung in Support of Samsung’s Notice of Lodging Materials

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in Opposition to Apple’s Motion for Preliminary Injunction (“Tung Declaration”).

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Exhibits M, N, S, and O to the Briggs Declaration and pages 24, 77-78, 100, 103, 106,
202-05, and 212 of Exhibit X to the Tung Declaration shall not be filed under seal.

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IT IS SO ORDERED.

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Dated: December _____, 2011.

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HONORABLE LUCY H. KOH
United States District Judge

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[PROPOSED] ORDER GRANTING SAMSUNG’S ADMINISTRATIVE MOTIONS TO FILE DOCUMENTS UNDER SEAL
CASE NO. 11-CV-01846-LHK
sf-3088616

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