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)
hmcelhinny@mofo.com
MICHAEL A. JACOBS (CA SBN 111664)
mjacobs@mofo.com
JENNIFER LEE TAYLOR (CA SBN 161368)
jtaylor@mofo.com
ALISON M. TUCHER (CA SBN 171363)
atucher@mofo.com
RICHARD S.J. HUNG (CA SBN 197425)
rhung@mofo.com
JASON R. BARTLETT (CA SBN 214530)
jasonbartlett@mofo.com
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: (415) 268-7000
Facsimile: (415) 268-7522
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WILLIAM F. LEE
william.lee@wilmerhale.com
WILMER CUTLER PICKERING
HALE AND DORR LLP
60 State Street
Boston, MA 02109
Telephone: (617) 526-6000
Facsimile: (617) 526-5000
MARK D. SELWYN (SBN 244180)
mark.selwyn@wilmerhale.com
WILMER CUTLER PICKERING
HALE AND DORR LLP
950 Page Mill Road
Palo Alto, California 94304
Telephone: (650) 858-6000
Facsimile: (650) 858-6100
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,
Plaintiff,
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v.
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.,
Case No.
11-cv-01846-LHK (PSG)
DECLARATION OF CYNDI
WHEELER IN SUPPORT OF
APPLE’S ADMINISTRATIVE
MOTION TO FILE DOCUMENTS
UNDER SEAL
Defendants.
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WHEELER DECL. ISO APPLE’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL
CASE NO. 11-CV-01846-LHK (PSG)
sf-3108015
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I, Cyndi Wheeler, do hereby declare as follows:
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1.
I am an attorney for Apple Inc. (“Apple”). I submit this declaration in support of
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Apple’s Administrative Motion to File Documents Under Seal (“Administrative Motion”). I have
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personal knowledge of the matters set forth below. If called as a witness I could and would
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testify competently as follows.
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2.
Apple’s Motion to Compel Depositions of 14 of Samsung’s Purported “Apex”
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Witnesses (“Motion to Compel”) and certain exhibits to 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”) contain Apple-confidential information. Specifically:
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a. Apple’s Motion to Compel contains information regarding communications about
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license negotiations between Apple and Samsung. This information is not publicly
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available and could be used by Apple’s competitors to its disadvantage.
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b. Exhibits 7 through 10 to the Walden Declaration contain communications about
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license negotiations between Apple and Samsung. This information is not publicly
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available and could be used by Apple’s competitors to its disadvantage.
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3.
It is Apple’s policy not to disclose or describe information regarding negotiation of
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its license agreements. The above information is confidential to Apple. If disclosed, the
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information in the materials described above could be used by Apple’s competitors to Apple’s
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disadvantage.
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4.
The relief requested in Apple’s Administrative Motion is necessary and narrowly
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tailored to protect confidential information, focusing only on specific exhibits and specific
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portions of the briefs at issue.
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I declare under the penalty of perjury under the laws of the United States of America that
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the forgoing is true and correct to the best of my knowledge and that this declaration was
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executed this 15th day of February, 2012, at Cupertino, California.
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__/s/ Cyndi Wheeler____________________
Cyndi Wheeler
WHEELER DECL. ISO APPLE’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL
CASE NO. 11-CV-01846-LHK (PSG)
sf-3108015
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ATTESTATION OF E-FILED SIGNATURE
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I, Michael A. Jacobs, am the ECF User whose ID and password are being used to file this
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Declaration. In compliance with General Order 45, X.B., I hereby attest that Cyndi Wheeler has
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concurred in this filing.
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Dated: February 16, 2012
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/s/ Michael A. Jacobs
Michael A. Jacobs
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WHEELER DECL. ISO APPLE’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL
CASE NO. 11-CV-01846-LHK (PSG)
sf-3108015
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