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

Filing 667

Administrative Motion to File Under Seal re Samsung's Motion to Supplement Invalidity Contentions filed by Samsung Electronics Co. Ltd.. (Attachments: #1 Trac Declaration, #2 Proposed Order)(Maroulis, Victoria) (Filed on 1/26/2012)

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
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

18 APPLE INC., a California corporation,

CASE NO. 11-cv-01846-LHK

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DECLARATION OF BILL TRAC IN
SUPPORT OF SAMSUNG’S
ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL

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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,
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Defendants.
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02198.51855/4572495.1

Case No. 11-cv-01846-LHK
TRAC DECLARATION IN SUPPORT OF SAMSUNG’S
MOTION TO FILE DOCUMENTS UNDER SEAL

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I, Bill Trac, declare:

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1.

I am an associate in the law firm of Quinn Emanuel Urquhart & Sullivan, LLP,

3 counsel for Samsung Electronics Co., Ltd., Samsung Electronics America, Inc. and Samsung
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Telecommunications America, LLC (collectively, “Samsung”).

Unless otherwise indicated, I

have personal knowledge of the facts set forth in this declaration and, if called upon as a witness, I

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could and would testify as follows.
2.

The requested relief is necessary to protect the confidentiality of information

9 discussed in Samsung’s Motion to Supplement Invalidity Contentions (“Samsung’s Motion”),
10 Exhibits O-W to the Declaration of Alex Baxter in Support of Samsung’s Motion (“Baxter
11 Declaration”), and Exhibits 7-8 to the Declaration of Todd Briggs in Support of Samsung’s
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Motion (“Briggs Declaration”).

Those documents contain information and quotations from

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documents that the parties – or third parties – have designated as confidential.
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3.

Exhibits O, P, and Q to the Baxter Declaration are excerpts from the deposition of

16 Apple’s inventors Imran Chaudhri, Bas Ording, and Steven Christensen. These transcripts have
17 been designated as Highly Confidential – Attorneys’ Eyes Only by Apple.
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4.

Exhibits R, T, U and V to the Baxter Declaration are excerpts from the deposition

19 of Richard Woolley and accompanying exhibits from Cirque Corporation, a third party deponent.
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The transcript and exhibits discuss confidential information regarding both Apple and Cirque, and

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have been designated as Confidential – Attorneys’ Eyes Only by Apple.
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5.

Exhibit S to the Baxter Declaration are excerpts from the deposition of Dr. Shawn

24 P. Day from Synaptics Corporation, a third party deponent. The transcript discusses confidential
25 information regarding Synaptics that has been designated as Confidential – Attorneys’ Eyes Only
26 by Synaptics.
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02198.51855/4572495.1

Case No. 11-cv-01846-LHK
-2TRAC DECLARATION IN SUPPORT OF SAMSUNG’S
MOTION TO FILE DOCUMENTS UNDER SEAL

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6.

Exhibit W to the Baxter Declaration is an excerpt from Apple’s Objections and

2 Responses to Samsung’s First Set of Interrogatories.
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This document has been designated as

Highly Confidential – Attorneys’ Eyes Only by Apple.
7.

Exhibits 7 and 8 to the Briggs Declaration are Invalidity Contentions for the ’129

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and ’607 patents that reference confidential business information from Synaptics Corporation and
Cirque Corporation, and have been designated as Highly Confidential – Attorney’s Eyes Only

8 under the protective order.
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8.

Samsung’s Motion contains discussion of the aforementioned exhibits, which have

10 been designated as Confidential – Attorneys’ Eyes Only or Highly Confidential – Attorneys’ Eyes
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only by Apple, Synaptics, and/or Cirque.

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9.

Attached as Exhibits 1-3 are the [Proposed] Public Redacted Versions of the

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documents that are being submitted under seal.

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I declare under penalty of perjury that the foregoing is true and correct. Executed in

17 Redwood Shores, California on January 26, 2012.
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/s/ Bill Trac

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02198.51855/4572495.1

Case No. 11-cv-01846-LHK
-3TRAC DECLARATION IN SUPPORT OF SAMSUNG’S
MOTION TO FILE DOCUMENTS UNDER SEAL

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General Order 45 Attestation
I, Victoria F. Maroulis, am the ECF user whose ID and password are being used to file this

3 Declaration. In compliance with General Order 45(X)(B), I hereby attest that Bill Trac has
4 concurred in this filing.
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/s/ Victoria Maroulis

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02198.51855/4572495.1

Case No. 11-cv-01846-LHK
-4TRAC DECLARATION IN SUPPORT OF SAMSUNG’S
MOTION TO FILE DOCUMENTS UNDER SEAL