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

Filing 737

Administrative Motion to File Under Seal filed by Apple Inc.. (Attachments: #1 Declaration Cyndi Wheeler Declaration, #2 Declaration S. Calvin Walden Declaration, #3 Exhibit 1, #4 Exhibit 11, #5 Exhibit 12, #6 Exhibit 13, #7 Exhibit 14, #8 Exhibit 15, #9 Exhibit 16, #10 Exhibit 17, #11 Exhibit 18, #12 Exhibit 19, #13 Exhibit 20, #14 Proposed Order)(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-3108208

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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 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 (“Walden Declaration”);

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2.

Exhibits 2 through 6 and 21 through 25 to the Walden Declaration;

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3.

Exhibits 7 through 10 to the Walden Declaration.

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Item 2 above consists of exhibits 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 may contain Samsung-confidential information to the extent it incorporates the

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exhibits in Item 2.

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Item 3 above consists of exhibits that Apple has designated as confidential under the

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protective order entered in this case. These exhibits contain Apple-confidential information that

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is not publicly available and that could be used by Apple’s competitors to Apple’s disadvantage.

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Apple has established good cause to permit the sealing of these materials through the Declaration

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of Cyndi Wheeler in Support of Apple’s Administrative Motion to File Documents Under Seal,

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filed herewith.

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APPLE’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL
CASE NO. 11-cv-01846-LHK
sf-3108208

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A proposed redacted version of Item 1 is attached as an exhibit 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-3108208

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