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

Filing 977

*** ATTACHMENTS 2 and 3 FILED IN ERROR WITH CONFIDENTIAL INFORMATION. DOCUMENT LOCKED. *** Administrative Motion to File Under Seal filed by Samsung Electronics America, Inc.(a New York corporation), Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC(a Delaware limited liability company). (Attachments: #1 Proposed Order Granting Administrative Motion to File Under Seal, #2 Declaration of Hankil Kang in Support of Administrative Motion to File Under Seal, #3 Samsung's Opposition to Apple's Rule 62(C) Motion, #4 Declaration of Paul Chapple in Support of Samsung's Opposition, #5 Declaration of Travis Merrill in Support of Samsung's Opposition, #6 Declaration of Carl Anderson in Support of Samsung's Opposition, #7 Exhibit 1 to the Declaration of Carl Anderson, #8 Exhibit 2 to the Declaration of Carl Anderson, #9 Exhibit 3 to the Declaration of Carl Anderson, #10 Exhibit 4 to the Declaration of Carl Anderson, #11 Proposed Order Denying Apple's Rule 62(C) Motion)(Maroulis, Victoria) (Filed on 5/25/2012) Modified on 5/29/2012 Attachment #2 Sealed pursuant to General Order No. 62 (dhm, COURT STAFF). Modified on 6/5/2012 (fff, COURT STAFF).

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.




02198.51855/4776997.1

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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Pursuant to Rule 62(c) For Entry of Preliminary Injunction Without Further

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Hearing (“the Opposition”);

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2. Exhibits 1, 2, and 4 to the Declaration of Carl Anderson in Support of the

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Opposition (“Anderson Declaration”);
3. The confidential, unredacted version of the Declaration of Paul Chapple in Support

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of the Opposition (“Chapple Declaration”); and
4. The confidential, unredacted version of the Declaration of Travis Merrill in Support

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of the Opposition (“Merrill Declaration”).
In short, the above documents discuss, refer to, or comprise excerpts of documents that

15 Samsung or Apple have designated as HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
16 ONLY under the Protective Order. Apple has designated Exhibits 1 and 2 to the Anderson
17 Declaration HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY.

Samsung expects that

18 Apple will file a declaration pursuant to Civil L.R. 79-5(d) establishing good cause to seal these
19 documents.

Samsung has established good cause to permit filing Exhibit 4 to the Anderson

20 Declaration and the confidential unredacted versions of the Opposition, Chapple Declaration, and
21 Merrill Declaration under seal through the Declaration of Hankil Kang in Support of Samsung’s
22 Administrative Motion to File Documents Under Seal, filed herewith.
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Pursuant to General Order No. 62, Samsung’s entire filing will be lodged with the Court

24 for in camera review and served on all parties. Proposed redacted versions of the Opposition, the
25 Chapple Declaration, and the Merrill Declaration have been filed concurrently with this motion.
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02198.51855/4776997.1

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

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1 DATED: May 25, 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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02198.51855/4776997.1

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

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