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

Filing 801

Administrative Motion to File Under Seal filed by Samsung Electronics America, Inc.(a New York corporation), Samsung Electronics Co. Ltd.(a Korean corporation), Samsung Telecommunications America, LLC(a Delaware limited liability company). (Attachments: #1 Declaration, #2 Proposed Order, #3 Exhibit Public Redaction Version of Samsung's Opposition, #4 Declaration Gordon Dec ISO Samsung's Opposition, #5 Exhibit Exhibit 1 to Gordon's Dec, #6 Exhibit Exhibit 2 to Gordon's Dec, #7 Exhibit Exhibit 3 to Gordon's Dec, #8 Exhibit Exhibit 4 to Gordon's Dec, #9 Declaration Martin Dec ISO Samsung's Opposition, #10 Exhibit Exhibit 1 to Martin's Dec, #11 Exhibit Exhibit 10 to Martin's Dec, #12 Exhibit Exhibit 11 to Martin's Dec, #13 Exhibit Exhibit 12 to Martin's Dec, #14 Exhibit Exhibit 13 to Martin's Dec, #15 Declaration Price's Dec ISO Samsung's Opposition, #16 Exhibit Exhibit 2 to Price's Dec, #17 Exhibit Exhibit 5 to Price's Dec, #18 Exhibit Exhibit 6 to Price's Dec, #19 Exhibit Exhibit 8 to Price's Dec, #20 Exhibit Exhibit 11 to Price's Dec, #21 Exhibit Exhibit 13 to Price's Dec, #22 Declaration Sheppard's Dec ISO Samsung's Opposition, #23 Certificate/Proof of Service)(Maroulis, Victoria) (Filed on 3/13/2012)

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 ADMINISTRATIVE
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.


Date:
Time:
Place:
Judge:

April 3, 2012
10:00 a.m.
Courtroom 5, 4th Floor
Hon. Paul S. Grewal




02198.51855/4649627.1

Case No. 11-cv-01846-LHK
SAMSUNG’S ADMINISTRATIVE 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 the following:
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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 Alleged Violation of January 27, 2012

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Damages Discovery Order (―Samsung’s Opposition to Apple’s Motion for

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Sanctions‖);

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2. The confidential, unredacted version of the Declaration of Joby Martin in Support

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of Samsung's Opposition to Apple's Motion for Sanctions, and Exhibits 2 – 9

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thereto;

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3. Exhibits 5 and 6 to the Declaration of John S. Gordon in Support of Samsung's
Opposition to Apple's Motion for Sanctions;

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4. Exhibits 1, 3, 4, 7, 9, 10 and 12 to the Declaration of Christopher E. Price in

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Support of Samsung's Opposition to Apple's Motion for Sanctions; and

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5. The confidential, unredacted version of the Declaration of Timothy Sheppard in

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Support of Samsung's Opposition to Apple's Motion for Sanctions, and Exhibits A

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– F thereto.

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Samsung has established good cause to permit filing these documents under seal through

20 the Declaration of Joby Martin in Support of Samsung’s Administrative Motion to File Documents
21 Under Seal, filed herewith.

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

22 of documents that Samsung has designated as HIGHLY CONFIDENTIAL – ATTORNEY’S
23 EYES ONLY under the protective order.

The remaining documents discuss and refer to

24 documents and things that Apple has designated as HIGHLY CONFIDENTIAL — ATTORNEYS
25 EYES ONLY under the protective order; Samsung trusts that Apple will file the necessary
26 declaration validating these designations per Local Rule 79-5(d).
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Case No. 11-cv-01846-LHK
SAMSUNG’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL

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Pursuant to General Order No. 62, Samsung’s entire filing will be lodged with the Court

2 for in camera review and served on all parties.

A proposed redacted version of Samsung’s

3 Opposition to Apple’s Motion for Sanctions has been filed concurrently with this motion.
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5 DATED: March 12, 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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02198.51855/4649627.1

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

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