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

Filing 613

Administrative Motion to File Under Seal filed by Apple Inc.. (Attachments: #1 Apple's Motion to Compel Production of Documents and Things, #2 Mazza Declaration ISO Apple's Motion to Compel, #3 Ex A to Mazza Decl, #4 Ex B to Mazza Decl, #5 Ex C to Mazza Decl, #6 Ex D to Mazza Decl, #7 Ex E to Mazza Decl, #8 Ex F to Mazza Decl, #9 Ex G to Mazza Decl, #10 Ex H to Mazza Decl, #11 Ex I to Mazza Decl, #12 Ex J to Mazza Decl, #13 Ex K to Mazza Decl, #14 Ex L to Mazza Decl, #15 Ex M to Mazza Decl, #16 Ex N to Mazza Decl, #17 Proposed Order)(Jacobs, Michael) (Filed on 1/11/2012) Modified on 6/8/2012 (ofr, COURT STAFF).

1
2
3
4
5
6
7
8
9

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]

10

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]

11
12

Attorneys for Plaintiff and
Counterclaim-Defendant APPLE INC.

13
14

UNITED STATES DISTRICT COURT

15

NORTHERN DISTRICT OF CALIFORNIA

16

SAN JOSE DIVISION

17
18

APPLE INC., a California corporation,

19
20
21
22
23

Plaintiff,
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,

24
Defendants.
25
26
27
28
ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL
CASE NO. 11-cv-01846-LHK
sf-3091581

Case No.

11-cv-01846-LHK

ADMINISTRATIVE MOTION TO
SEAL APPLE’S MOTION TO
COMPEL

1
2

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:

3

1.

Apple’s Motion to Compel Production of Documents and Things;

4

2.

Exhibits A, H, and J to the Declaration of Mia Mazza in Support of Apple’s

5

Motion to Compel Production of Documents and Things (“Mazza Declaration”).

6

The above items contain material that Samsung has designated as confidential under the

7

interim protective order. In particular, item 1 includes references to a deposition transcript that

8

Samsung designated as containing confidential business information. Exhibit A to the Mazza

9

Declaration consists of the selections to the deposition transcript designated by Samsung as

10

containing confidential business information referenced in item 1. Exhibit H to the Mazza

11

Declaration is a letter containing references to documents that were designated by Samsung as

12

confidential when produced. Exhibit J to the Mazza Declaration is a letter sent by Samsung to

13

Apple that Samsung’s counsel subsequently designated as Highly Confidential.

14

Apple expects that pursuant to Civil L.R. 79-5(d), Samsung will file a declaration

15

establishing good cause to permit the sealing of these materials. Proposed public redacted

16

versions of the documents listed above are attached hereto as exhibits if appropriate.

17
18

Dated: January 11, 2012

MORRISON & FOERSTER LLP

19
20

By: /s/ Michael A. Jacobs
Michael A. Jacobs

21

Attorneys for Plaintiff
APPLE INC.

22
23
24
25
26
27
28
ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL
CASE NO. 11-cv-01846-LHK
sf-3091581

1