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

Filing 707

Administrative Motion to File Under Seal Samsung's Unopposed Motion for Issuance of a Request for Judicial Assistance and related exhibits filed by Samsung Electronics America, Inc., Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC. (Attachments: #1 Declaration, #2 Proposed Order, #3 Public Redacted Motion, #4 Declaration, #5 Letter of Request, #6 Proposed Order)(Maroulis, Victoria) (Filed on 2/2/2012)

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,
Plaintiff,

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vs.

CASE NO. 11-cv-01846-LHK
DECLARATION OF SAM STAKE IN
SUPPORT OF SAMSUNG’S
ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL

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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02198.51855/4582678.1

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

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I, Sam Stake, 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 Unopposed Motion for Issuance of a Request for Judicial Assistance and
10 exhibits 1-6 to the Declaration of Sam Stake in Support of Samsung's Unopposed Motion for
11 Issuance of a Request for Judicial Assistance ("the Stake Declaration").
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3.

Exhibits 1, 2, 5 and 6 to the Stake Declaration consist of excerpts of deposition

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testimony of Apple employees that has been marked as Highly Confidential – Attorney’s Eyes
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Only – under the protective order.
4.

Exhibits 3 and 4 to the Stake Declaration consist of internal Apple reports and

17 emails that Apple has marked as Highly Confidential – Attorney’s Eyes Only – under the
18 protective order.
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5.

It is necessary to redact the public versions of Samsung's Unopposed Motion for

Issuance of a Request for Judicial Assistance to the extent this document quotes from or reveals

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information from the confidential materials discussed above.
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I declare under penalty of perjury that the foregoing is true and correct.

Executed in San

24 Francisco, California on February 3, 2012.
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/s/ Sam Stake
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Sam Stake

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Case No. 11-cv-01846-LHK

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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 Alex Baxter has

4 concurred in this filing.
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/s/ Victoria Maroulis

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Case No. 11-cv-01846-LHK