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

Filing 984

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 Declaration of Christopher Price in Support of Samsung's Administrative Motion to Seal, #2 Proposed Order Granting Samsung's Administrative Motion to Seal, #3 Exhibit 1 to Declaration of Christopher Price in Support of Motion to Seal (Supplemental Price Declaration), #4 Exhibit 1 to Supplemental Price Declaration (Filed Under Seal), #5 Exhibit 2 to Supplemental Price Declaration (Filed Under Seal), #6 Exhibit 3 to Supplemental Price Declaration (Filed Under Seal), #7 Exhibit 4 to Supplemental Price Declaration (Filed Under Seal), #8 Exhibit 5 to Supplemental Price Declaration (Filed Under Seal))(Maroulis, Victoria) (Filed on 5/29/2012)

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP
Charles K. Verhoeven (Bar No. 170151)
2 [e-mail]
50 California Street, 22nd Floor
3 San Francisco, California 94111
Telephone: [phone]
4 Facsimile: [phone]
5 Kevin P.B. Johnson (Bar No. 177129)
[e-mail]
6 Victoria F. Maroulis (Bar No. 202603)
[e-mail]
th
7 555 Twin Dolphin Drive, 5 Floor
Redwood Shores, California 94065-2139
8 Telephone: [phone]
Facsimile: [phone]
9
10 Michael T. Zeller (Bar No. 196417)
[e-mail]
11 865 S. Figueroa St., 10th Floor
Los Angeles, California 90017
12 Telephone: [phone]
Facsimile: [phone]
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14 Attorneys for SAMSUNG ELECTRONICS CO.,
LTD., SAMSUNG ELECTRONICS AMERICA,
15 INC. and SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

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20 APPLE INC., a California corporation,

CASE NO. 11-cv-01846-LHK (PSG)

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DECLARATION OF CHRISTOPHER E.
PRICE IN SUPPORT OF SAMSUNG’S
ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL

22

Plaintiff,
vs.

23 SAMSUNG ELECTRONICS CO., LTD., a
Korean business entity; SAMSUNG
24 ELECTRONICS AMERICA, INC., a New
York corporation; SAMSUNG
25 TELECOMMUNICATIONS AMERICA,
LLC, a Delaware limited liability company,
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Defendants.
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Date: June 26, 2012
Time: 10:00 a.m.
Place: Courtroom 5, 4th Floor
Judge: Hon. Paul S. Grewal

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Case No. 11-cv-01846-LHK (PSG)
PRICE DECLARATION IN SUPPORT OF SAMSUNG’S ADMINISTRATIVE MOTION

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DECLARATION OF CHRISTOPHER E. PRICE

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I, Christopher E. Price, declare as follows:

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1.

I am Of Counsel with the law firm of Quinn Emanuel Urquhart & Sullivan, LLP,

4 counsel for Samsung Electronics Co., Ltd., Samsung Electronics America, Inc. and Samsung
5 Telecommunications America, LLC (collectively, “Samsung”). I submit this declaration in
6 support of Samsung’s Administrative Motion to File Documents Under Seal. I have personal
7 knowledge of the facts set forth in this declaration, except as otherwise noted, and, if called upon
8 as a witness, I could and would testify to such facts under oath. Exhibit 1 to this Declaration is
9 the May 29, 2012 Supplemental Declaration of Christopher Price (“Supplemental Price
10 Declaration”).
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2.

Exhibit 1 to the Supplemental Price Declaration is a true and correct copy of a

12 licensing agreement. Apple has designated this agreement Highly Confidential – Attorney Eyes
13 Only (“AEO”) under the protective order in this case, and Samsung expects that Apple will file a
14 declaration pursuant to Civ. L.R. 79-5(d) establishing the document as confidential, and
15 therefore it should be sealed.
16

3.

Exhibit 2 to the Supplemental Price Declaration is a true and correct copy of a

17 licensing agreement. Apple has designated this agreement AEO under the protective order in
18 this case, and Samsung expects that Apple will file a declaration pursuant to Civ. L.R. 79-5(d)
19 establishing the document as confidential, and therefore it should be sealed.
20

4.

Exhibit 3 to the Supplemental Price Declaration is a true and correct copy of a

21 licensing agreement. Apple has designated this agreement AEO under the protective order in
22 this case, and Samsung expects that Apple will file a declaration pursuant to Civ. L.R. 79-5(d)
23 establishing the document as confidential, and therefore it should be sealed.
24

5.

Exhibit 4 to the Supplemental Price Declaration is a true and correct copy of a

25 licensing agreement. Apple has designated this agreement AEO under the protective order in
26 this case, and Samsung expects that Apple will file a declaration pursuant to Civ. L.R. 79-5(d)
27 establishing the document as confidential, and therefore it should be sealed.
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Case No. 11-cv-01846-LHK (PSG)
-1PRICE DECLARATION IN SUPPORT OF SAMSUNG’S ADMINISTRATIVE MOTION

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6.

Exhibit 5 to the Supplemental Price Declaration is a true and correct copy of a

2 licensing agreement. Apple has designated this agreement AEO under the protective order in
3 this case, and Samsung expects that Apple will file a declaration pursuant to Civ. L.R. 79-5(d)
4 establishing the document as confidential, and therefore it should be sealed.
5

7.

The requested relief is necessary to protect the confidentiality of information

6 contained in the Supplemental Price Declaration and Exhibits 1-5 attached thereto.
7

8.

The confidential, unredacted version of the Supplemental Price Declaration

8 discusses and references information that Apple has designated as AEO under the protective
9 order in this case, and Samsung expects that Apple will file a declaration pursuant to Civ. L.R.
10 79-5(d) establishing the document as confidential, and therefore it should be sealed.
11

I declare under penalty of perjury under the laws of the United States of America that the

12 foregoing is true and correct.
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Executed on May 29, 2012, at Los Angeles, California.

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Christopher E. Price

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Case No. 11-cv-01846-LHK (PSG)
-2PRICE DECLARATION IN SUPPORT OF SAMSUNG’S ADMINISTRATIVE MOTION

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GENERAL ORDER ATTESTATION
I, Victoria Maroulis, am the ECF user whose ID and password are being used to file the

5 foregoing document. I hereby attest pursuant to General Order 45.X.B. that concurrence in the
6 electronic filing of this document has been obtained from Christopher Price.
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/s/ Victoria Maroulis

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Case No. 11-cv-01846-LHK (PSG)
-3PRICE DECLARATION IN SUPPORT OF SAMSUNG’S ADMINISTRATIVE MOTION