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

Filing 758

Administrative Motion to File Under Seal filed by Samsung Electronics America, Inc., Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC. (Attachments: #1 Declaration of Melissa Chan In Support of Samsung's Administrative Motion to File Under Seal, #2 Proposed Order Granting Samsung's Motion to Seal, #3 REDACTED Samsung's Opposition to Apple's Motion for Sanctions, #4 Declaration of Sara Jenkins In Support of Samsung's Opposition to Apple's Motion for Sanctions - REDACTED, #5 Exhibit A to Jenkins Declaration, #6 Exhibit B to Jenkins Declaration, #7 Exhibit C to Jenkins Declaration, #8 Exhibit D to Jenkins Declaration, #9 Exhibit E to Jenkins Declaration, #10 Exhibit F to Jenkins Declaration, #11 Exhibit G to Jenkins Declaration, #12 Exhibit H to Jenkins Declaration, #13 Exhibit I to Jenkins Declaration, #14 Exhibit J to Jenkins Declaration, #15 Exhibit K to Jenkins Declaration, #16 Exhibit L to Jenkins Declaration, #17 Exhibit M to Jenkins Declaration, #18 Exhibit N to Jenkins Declaration, #19 Exhibit O to Jenkins Declaration, #20 Certificate/Proof of Service)(Maroulis, Victoria) (Filed on 2/25/2012)

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP
Charles K. Verhoeven (Cal. Bar No. 170151)
 [e-mail]
50 California Street, 22nd Floor
 San Francisco, California 94111
Telephone: [phone]
 Facsimile: [phone]
 Kevin P.B. Johnson (Cal. Bar No. 177129)
[e-mail]
 Victoria F. Maroulis (Cal. Bar No. 202603)
[e-mail]
 555 Twin Dolphin Drive 5th Floor
Redwood Shores, California 94065
 Telephone: [phone]
Facsimile: [phone]

Michael T. Zeller (Cal. Bar No. 196417)
 [e-mail]
865 S. Figueroa St., 10th Floor
 Los Angeles, California 90017
Telephone: [phone]
 Facsimile: [phone]
 Attorneys for SAMSUNG ELECTRONICS
CO., LTD., SAMSUNG ELECTRONICS
 AMERICA, INC. and SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC



UNITED STATES DISTRICT COURT



NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

 APPLE INC., a California corporation,

CASE NO. 11-cv-01846-LHK



SAMSUNG’S MOTION TO FILE
DOCUMENTS UNDER SEAL



Plaintiff,
vs.

 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,

Defendants.




Case No. 11-cv-01846-LHK
SAMSUNG’S MOTION TO FILE DOCUMENTS UNDER SEAL

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Pursuant to Civil L.R. 7-11 and 79-5, and General Order No. 62, Defendants Samsung

2 Electronics Co. Ltd., Samsung Electronics America, Inc., and Samsung Telecommunications
3 America, LLC (collectively, “Samsung”) hereby bring this administrative motion for an order to
4 seal:
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1. The confidential, unredacted version of Samsung’s Opposition To Apple’s Motion

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For Rule 37(B)(2) Sanctions For Samsung's Violation Of Two Discovery Orders

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(“Samsung’s Opposition to Apple’s Motion for Sanctions”);

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2. The confidential, unredacted version of the Declaration of Sara Jenkins in Support

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of Samsung’s Opposition To Apple’s Motion For Rule 37(B)(2) Sanctions For

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Samsung's Violation Of Two Discovery Orders;
3. Exhibits A, C-F, H-N to the Declaration of Sara Jenkins in Support of Samsung’s
Opposition to Apple’s Motion for Sanctions; and
4. The Declaration of Hankil Kang in Support of Samsung’s Opposition to Apple’s
Motion For Rule 37(B)(2) Sanctions.
Samsung has established good cause to permit filing these documents under seal through

16 the Declaration of Melissa Chan in Support of Samsung’s Administrative Motion to File
17 Documents Under Seal, filed herewith.

In short, the above documents discuss, refer to, or

18 comprise excerpts of depositions and/or documents that Samsung has designated as HIGHLY
19 CONFIDENTIAL – ATTORNEY’S EYES ONLY under the protective order, or is a declaration
20 describing the confidential business structure, practices, and documents of Samsung.

The

21 remaining documents discuss and refer to documents and things that Apple has designated as
22 CONFIDENTIAL — ATTORNEYS EYES ONLY under the protective order; Samsung trusts that
23 Apple will file the necessary declaration validating these designations per Local Rule 79-5(d).
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Pursuant to General Order No. 62, Samsung’s entire filing will be lodged with the Court

25 for in camera review and served on all parties.

A proposed redacted version of Samsung’s

26 Opposition to Apple’s Motion for Sanctions has been filed concurrently with this motion.
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Case No. 11-cv-01846-LHK
SAMSUNG’S MOTION TO FILE DOCUMENTS UNDER SEAL

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1 DATED: February 24, 2012
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QUINN EMANUEL URQUHART &
SULLIVAN, LLP

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By /s/ Victoria Maroulis
Charles K. Verhoeven
Kevin P.B. Johnson
Victoria F. Maroulis
Michael T. Zeller
Attorneys for SAMSUNG ELECTRONICS CO.,
LTD., SAMSUNG ELECTRONICS AMERICA,
INC., and SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC

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Case No. 11-cv-01846-LHK
SAMSUNG’S MOTION TO FILE DOCUMENTS UNDER SEAL

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