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

Filing 736

Administrative Motion to File Under Seal filed by Apple Inc.. (Attachments: #1 Proposed Order granting administrative to file under seal, #2 [Public] APPLE INC.S MOTION TO COMPEL DEPOSITIONS OF 14 OF SAMSUNGS PURPORTED APEX WITNESSES, #3 Declaration [Public] Mazza Declaration in Support of APPLE INC.S MOTION TO COMPEL DEPOSITIONS OF 14 OF SAMSUNGS PURPORTED APEX WITNESSES, #4 Exhibit 15, #5 Exhibit 16, #6 Proposed Order granting motion to compel)(Jacobs, Michael) (Filed on 2/16/2012)

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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]
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]

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]

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Attorneys for Plaintiff and
Counterclaim-Defendant 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,

Case No.

11-cv-01846-LHK (PSG)

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Plaintiff,
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v.

APPLE’S ADMINISTRATIVE
MOTION TO FILE DOCUMENTS
UNDER SEAL

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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,
Defendants.

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APPLE’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL
CASE NO. 11-cv-01846-LHK
sf-3107598

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In accordance with Civil Local Rules 7-11 and 79-5, and General Order No. 62,

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Apple Inc. (“Apple”) submits this motion for an order to seal the following documents or portions

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thereof:

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1.

The confidential, unredacted version of Apple’s Motion To Compel Depositions of

14 of Samsung’s Purported “Apex” Witnesses (“Motion to Compel”);
2.

The confidential, unredacted version of the Declaration of Mia Mazza In Support

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of Apple’s Motion To Compel Depositions of 14 of Samsung’s Purported “Apex” Witnesses

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(“Mazza Declaration”);

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3.

Exhibits 1-14 and 17-55 to the Mazza Declaration.

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

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protective order entered in this case. Apple expects that pursuant to Civil Local Rule 79-5(d),

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Samsung will file a declaration establishing good cause to permit the sealing of these materials.

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Item 1 above contains materials that Apple has designated a confidential under the

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protective order entered in this case. Specifically, Apple’s Motion to Compel discusses Apple-

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confidential exhibits that are not publicly available and that could be used by Apple’s competitors

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to Apple’s disadvantage. Apple has established good cause to permit the sealing of these

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materials through the Declaration of Cyndi Wheeler in Support of Apple’s Administrative Motion

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to File Documents Under Seal, filed concurrently with the Declaration of S. Calvin Walden in

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Support of Apple’s Motion to Compel Depositions of 14 of Samsung’s Purported “Apex”

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Witnesses.

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APPLE’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL
CASE NO. 11-cv-01846-LHK
sf-3107598

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Proposed redacted versions of Items 1-2 are attached as exhibits hereto. Pursuant to Civil

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Local Rule 79-(c), Apple will lodge with the Clerk the documents at issue with the sealable

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portions highlighted.

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Dated: February 16, 2012

MORRISON & FOERSTER LLP

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By: /s/ Michael A. Jacobs
Michael A. Jacobs
Attorneys for Plaintiff
APPLE INC.

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APPLE’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL
CASE NO. 11-cv-01846-LHK
sf-3107598

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