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

Filing 60

Administrative Motion to File Under Seal Apple's Stipulated Administrative Motion to File Documents Under Seal filed by Apple Inc.. (Attachments: #1 Whitt Declaration, #2 Bartlett Declaration, #3 Proposed Order)(Bartlett, Jason) (Filed on 6/7/2011) Modified on 6/8/2011 (ewn, COURT STAFF).

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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]
JASON R. BARTLETT (CA SBN 214530)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: 415.268.7522
Attorneys for Plaintiff
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.
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.,

Case No.

4:11-cv-01846-LHK

DECLARATION OF JAYNA R.
WHITT IN SUPPORT OF
APPLE’S STIPULATED
ADMINISTRATIVE MOTION TO
FILE DOCUMENTS UNDER
SEAL

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Defendants.
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DECLARATION OF JAYNA R. WHITT
Case No. 4:11-cv-01846-LHK
sf-3004768

ISO APPLE’S STIPULATED ADMINISTRATIVE MOTION TO FILE UNDER SEAL

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I, Jayna R. Whitt, do hereby declare as follows:

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1.

I hold the position of Director, Patent Litigation at Apple Inc. (“Apple”). I submit

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this declaration in support of Apple’s Administrative Motion to File Documents Under Seal. If

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called as a witness, I could and would testify competently as follows.

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2.

The requested relief is necessary and narrowly tailored to protect the

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confidentiality of the information contained in the Declaration of Richard J. Lutton in Support of

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Apple’s Opposition to Defendants’ Motion to Compel Apple to Produce Expedited Reciprocal

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Discovery (the “Lutton Opposition Declaration”), and portions of Apple’s opposition brief that

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reference this declaration. Specifically, the Lutton Opposition Declaration contains information

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relating to Apple’s product launch and marketing strategies, as well as its business practices.

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Apple does not to disclose or comment on speculation about its business practices. This

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information can be used by Apple’s competitors to its disadvantage.

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I declare under the penalty of perjury under the laws of the United States of America that

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the forgoing is true and correct to the best of my knowledge and that this Declaration was

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executed this 7th day of June, 2011, at Cupertino, California.

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Dated: June 7, 2011

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By: /s/ Jayna R. Whitt_______________
Senior Director and Chief Patent Counsel at
Apple Inc.

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DECLARATION OF JAYNA R. WHITT
Case No. 4:11-cv-01846-LHK
sf-3004768

ISO APPLE’S STIPULATED ADMINISTRATIVE MOTION TO FILE UNDER SEAL

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ECF ATTESTATION

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I, JASON R. BARTLETT, am the ECF User whose ID and password are being used to

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file the following document: DECLARATION OF JAYNA R. WHITT IN SUPPORT OF

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APPLE’S STIPULATED ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER

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SEAL. In compliance with General Order 45, X.B., I hereby attest that Jayna R. Whitt has

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concurred in this filing.

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Dated: June 7, 2011

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JASON R. BARTLETT
MORRISON & FOERSTER LLP
By: /s/ Jason R. Bartlett
JASON R. BARTLETT

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DECLARATION OF JAYNA R. WHITT
Case No. 4:11-cv-01846-LHK
sf-3004768

ISO APPLE’S STIPULATED ADMINISTRATIVE MOTION TO FILE UNDER SEAL

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