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

Filing 822

Administrative Motion to File Under Seal filed by Apple Inc.. (Attachments: #1 Proposed Order, #2 [Redacted Public Version] Apple's Reply Brief, #3 [Redacted Public Version] Olson Reply Declaration, #4 Exhibit C to [Redacted Public Version] Olson Reply Declaration, #5 Exhibit E to [Redacted Public Version] Olson Reply Declaration, #6 Exhibit G to [Redacted Public Version] Olson Reply Declaration, *** DOCUMENT LOCKED [822-7] AT FILER'S REQUEST. *** #7 Exhibit I to [Redacted Public Version] Olson Reply Declaration, #8 [Redacted Public Version] Roberts Reply Declaration, #9 [Redacted Public Version] Kim Reply Declaration, #10 Exhibit 1 to [Redacted Public Version] Kim Reply Declaration, #11 Exhibit 2 to [Redacted Public Version] Kim Reply Declaration, #12 Exhibit 3 to [Redacted Public Version] Kim Reply Declaration, #13 Exhibit 4 to [Redacted Public Version] Kim Reply Declaration, #14 Exhibit 5 to [Redacted Public Version] Kim Reply Declaration, #15 Exhibit 6 to [Redacted Public Version] Kim Reply Declaration, #16 Exhibit 7 to [Redacted Public Version] Kim Reply Declaration, #17 Exhibit 8 Part 1 to [Redacted Public Version] Kim Reply Declaration, #18 Exhibit 8 Part 2 to [Redacted Public Version] Kim Reply Declaration, #19 Exhibit 11 to [Redacted Public Version] Kim Reply Declaration, #20 Exhibit 12 to [Redacted Public Version] Kim Reply Declaration, #21 Certificate/Proof of Service)(Jacobs, Michael) (Filed on 3/20/2012) Modified on 3/21/2012 (wv, COURT STAFF). Modified on 3/21/2012 (wv, COURT STAFF).

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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 (PSG)
pa-1514313

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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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The confidential, unredacted version of Apple’s Reply Brief in Support of Rule

37(b)(2) Motion Re: Samsung’s Violation of January 27, 2012 Damages Discovery Order;
2.

The confidential, unredacted version of the Declaration Of Erik J. Olson in

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Support of Apple’s Reply in Support of Rule 37(B)(2) Motion Re: Samsung’s Violation of

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January 27, 2012 Damages Discovery Order (“Olson Reply Declaration”);

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3.

The confidential, unredacted version of the Declaration of Eric R. Roberts in

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Support of Apple’s Reply in Support of Rule 37(b)(2) Motion Re: Samsung’s Violation of

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January 27, 2012 Damages Discovery Order (“Roberts Reply Declaration”);

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4.

The confidential, unredacted version of the Declaration of Grant L. Kim in

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Support of Apple’s Reply in Support of Rule 37(b)(2) Motion Re: Samsung’s Violation of

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January 27, 2012 Damages Discovery Order (“Kim Reply Declaration”);

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5.

Exhibits A-B, D, F, & H to the Olson Reply Declaration;

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6.

Exhibits A-C to the Roberts Reply Declaration;

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7.

Exhibits 9-10 & 13-18 to the Kim Reply Declaration.

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APPLE’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL
CASE NO. 11-cv-01846-LHK (PSG)
pa-1514313

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The above items contain material 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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Pursuant to Civil Local Rule 79-(c), Apple will lodge with the Clerk the documents at issue with

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the sealable portions highlighted. Redacted versions of items 1-4 are attached as exhibits hereto.

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Dated: March 20, 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
pa-1514313

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