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

Filing 648

Declaration of Cyndi Wheeler in Support of #602 Administrative Motion to File Under Seal re Samsung's January 10, 2012 Filings filed byApple Inc.. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8, #9 Exhibit 9, #10 Exhibit 10, #11 Exhibit 11, #12 Exhibit 12, #13 Exhibit 13, #14 Exhibit 14, #15 Exhibit 15, #16 Exhibit 16, #17 Exhibit 17, #18 Proposed Order)(Related document(s) #602 ) (Hung, Richard) (Filed on 1/18/2012)

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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
MOTION 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 MOTION TO FILE DOCUMENTS UNDER SEAL
CASE NO. 11-CV-01846-LHK (PSG)

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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. No. 602.] In support of Samsung’s

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motion, Apple has filed the declaration required under Civil L.R. Rule 79-5(d) and General Order

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No. 62, which provides evidence of good cause for this Court to permit filing under seal. The

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declaration establishes that information contained in the documents listed below is “privileged or

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protectable as a trade secret or otherwise entitled to protection under the law.” Civil L.R. 79-5(a).

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The motion is narrowly tailored to seek the sealing only of sealable information.

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

Portions of Exhibits A, D, K, M, N, P, Q, U, W, Y, and Z to the Declaration of

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Diane C. Hutnyan in Support of Samsung’s Motion to Compel (“Hutnyan

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Declaration ISO MtC”) consistent with the proposed redacted exhibits identified in

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the Declaration of Cyndi Wheeler in Support of Samsung’s Motion to File Under

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Seal (“Wheeler Declaration”).

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2.

Exhibits L, M, S, and T to the Hutnyan Declaration ISO MtC in their entirety.

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3.

The Hutnyan Declaration ISO MtC and Samsung’s Motion to Compel to the extent

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they refer to the above-referenced exhibits or confidential information therefrom.
4.

Portions of Exhibit C to the Declaration of Diane C. Hutnyan in Support of

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Samsung’s Renewed Motion to Compel consisted with the proposed redacted

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exhibit identified in the Wheeler Declaration.

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5.

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to Enforce Various Court Orders (“Hutnyan Declaration ISO MtE”) in its entirety.
6.

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Portions of Exhibit D to the Hutnyan Declaration ISO MtE consistent with the
proposed redacted exhibit identified in the Wheeler Declaration.

7.

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Exhibit C to the Declaration of Diane C. Hutnyan in Support of Samsung’s Motion

Samsung’s Motion to Enforce Various Court Orders to the extent it refers to the
above-referenced exhibits or confidential information therefrom.

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Exhibits A-E and G of the Declaration of Brett Arnold in Support of Samsung’s
Motion for Clarification (“Arnold Declaration”) in their entirety.

[PROPOSED] ORDER GRANTING SAMSUNG’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL
CASE NO. 11-CV-01846-LHK (PSG)

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9.

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proposed redacted exhibits identified in the Wheeler Declaration.
10.

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Portions of Exhibits F and H to the Arnold Declaration consistent with the

Samsung’s Motion for Clarification and the Arnold Declaration to the extent they
refer to the above-referenced exhibits or confidential information therefrom.

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Portions of Exhibits B, C, D, and K to the Declaration of Diane C. Hutnyan in

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Support of Samsung’s Motion for a Protective Order (“Hutnyan Declaration ISO

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MPO”) consistent with the proposed redacted exhibits identified in the Wheeler

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Declaration.

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12.

Exhibits E-J to the Hutnyan Declaration ISO MPO in their entirety.

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13.

Samsung’s Motion for a Protective Order to the extent it refers to the above-

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referenced exhibits or confidential information therefrom.
The remainder of the documents at issue in Samsung’s Administrative Motion to File
Under Seal [Dkt. No. 602] shall not be filed under seal.

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IT IS SO ORDERED.

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Dated: January _____, 2012.

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HONORABLE PAUL S. GREWAL
United States Magistrate Judge

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[PROPOSED] ORDER GRANTING SAMSUNG’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL
CASE NO. 11-CV-01846-LHK (PSG)

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