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

Filing 987

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 Motion to Seal, #2 Declaration of Daniel Shim in Support of Motion to Seal, #3 Samsung's Opposition to Apple's Motion for Adverse Inference Jury Instructions, #4 Declaration of Thomas Watson, #5 Exhibit 1 to Watson, #6 Exhibit 2 to Watson, #7 Exhibit 3 to Watson, #8 Exhibit 4 to Watson, #9 Exhibit 5 to Watson, #10 Exhibit 6 to Watson, #11 Exhibit 7 to Watson, #12 Exhibit 8 to Watson, #13 Exhibit 9 to Watson, #14 Exhibit 10 to Watson, #15 Exhibit 11 to Watson, #16 Exhibit 12 to Watson, #17 Exhibit 13 to Watson, #18 Exhibit 14 to Watson, #19 Exhibit 15 to Watson, #20 Exhibit 16 to Watson, #21 Exhibit 17 to Watson, #22 Exhibit 18 to Watson, #23 Exhibit 19 to Watson, #24 Exhibit 20 to Watson, #25 Exhibit 21 to Watson, #26 Exhibit 22 to Watson, #27 Exhibit 23 to Watson, #28 Exhibit 24 to Watson, #29 Exhibit 25 to Watson, #30 Exhibit 26 to Watson, #31 Exhibit 27 to Watson, #32 Exhibit 28 to Watson, #33 Exhibit 29 to Watson, #34 Exhibit 30 to Watson, #35 Exhibit 31 to Watson, #36 Exhibit 32 to Watson, #37 Exhibit 33 to Watson, #38 Declaration of Sara Jenkins, #39 Declaration of Alex Binder, #40 Exhibit 1 to Binder, #41 Exhibit 2 to Binder, #42 Exhibit 3 to Binder, #43 Exhibit 4 to Binder, #44 Declaration of Hankil Kang, #45 Declaration of Don Joo Lee, #46 Declaration of Giho Ro, #47 Declaration of Han-Yeol Ryu, #48 Declaration of Heontae Son, #49 Declaration of Ioi Lam, #50 Declaration of Jong Dae Park, #51 Declaration of Joo Hyuk Kang, #52 Declaration of Kang Hyun Lee, #53 Declaration of Min Cheol Shin, #54 Declaration of Minhyouk Lee, #55 Declaration of Nara Cho, #56 Declaration of Se-Hyun Cho, #57 Declaration of Sungsik Lee, #58 Declaration of Won Pyo Hong, #59 Declaration of Wooup Kwon, #60 Declaration of Young-jo Lim, #61 Declaration of YoungSoon Lee, #62 Declaration of Kyu Hyuk Lee, #63 Declaration of Michael Finnegan, #64 Declaration of Byungil Kim, #65 Declaration of M. James Daley, #66 Declaration of Raymond Warren, #67 Proposed Order Denying Apple's Motion for Adverse Inference Jury Instructions)(Maroulis, Victoria) (Filed on 5/29/2012)

Download PDF
1 QUINN EMANUEL URQUHART & SULLIVAN, LLP Charles K. Verhoeven (Cal. Bar No. 170151) 2 charlesverhoeven@quinnemanuel.com 50 California Street, 22nd Floor 3 San Francisco, California 94111 Telephone: (415) 875-6600 4 Facsimile: (415) 875-6700 5 Kevin P.B. Johnson (Cal. Bar No. 177129) kevinjohnson@quinnemanuel.com 6 Victoria F. Maroulis (Cal. Bar No. 202603) victoriamaroulis@quinnemanuel.com 7 555 Twin Dolphin Drive 5th Floor Redwood Shores, California 94065 8 Telephone: (650) 801-5000 Facsimile: (650) 801-5100 9 Michael T. Zeller (Cal. Bar No. 196417) 10 michaelzeller@quinnemanuel.com 865 S. Figueroa St., 10th Floor 11 Los Angeles, California 90017 Telephone: (213) 443-3000 12 Facsimile: (213) 443-3100 13 Attorneys for SAMSUNG ELECTRONICS CO., LTD., SAMSUNG ELECTRONICS 14 AMERICA, INC. and SAMSUNG TELECOMMUNICATIONS AMERICA, LLC 15 16 UNITED STATES DISTRICT COURT 17 NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION 18 APPLE INC., a California corporation, CASE NO. 11-cv-01846-LHK 19 SAMSUNG’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL 20 Plaintiff, vs. 21 SAMSUNG ELECTRONICS CO., LTD., a Korean business entity; SAMSUNG 22 ELECTRONICS AMERICA, INC., a New York corporation; SAMSUNG 23 TELECOMMUNICATIONS AMERICA, LLC, a Delaware limited liability company, 24 Defendants. 25 26 27 28 Case No. 11-cv-01846-LHK SAMSUNG’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL 1 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: 5 1. 6 7 The confidential, unredacted version of Samsung’s Opposition to Apple’s Motion for Adverse Jury Instructions Due to Samsung’s Spoliation of Evidence; 2. The confidential, unredacted version of the Declaration of Hankil Kang in Support 8 of Opposition to Apple Inc.’s Motion for Adverse Inference Jury Instructions Due 9 to Samsung’s Spoliation of Evidence; 10 3. The confidential, unredacted version of the Declaration of Byungil Kim in Support 11 of Opposition to Apple Inc.’s Motion for Adverse Inference Jury Instructions Due 12 to Samsung’s Spoliation of Evidence; 13 4. The confidential, unredacted version of the Declaration of Young-jo Lim in 14 Support of Opposition to Apple Inc.’s Motion for Adverse Inference Jury 15 Instructions Due to Samsung’s Spoliation of Evidence; 16 5. The confidential, unredacted version of the Declaration of Giho Ro in Support of 17 Opposition to Apple Inc.’s Motion for Adverse Inference Jury Instructions Due to 18 Samsung’s Spoliation of Evidence; 19 6. The confidential, unredacted version of the Declaration of Han-Yeol Ryu in 20 Support of Opposition to Apple Inc.’s Motion for Adverse Inference Jury 21 Instructions Due to Samsung’s Spoliation of Evidence; 22 7. The confidential, unredacted version of the Declaration of Heontae Son in Support 23 of Opposition to Apple Inc.’s Motion for Adverse Inference Jury Instructions Due 24 to Samsung’s Spoliation of Evidence; 25 8. The confidential, unredacted version of the Declaration of Se-Hyun Cho in Support 26 of Opposition to Apple Inc.’s Motion for Adverse Inference Jury Instructions Due 27 to Samsung’s Spoliation of Evidence; 28 Case No. 11-cv-01846-LHK SAMSUNG’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL -1- 1 9. The confidential, unredacted version of the Declaration of Nara Cho in Support of 2 Opposition to Apple Inc.’s Motion for Adverse Inference Jury Instructions Due to 3 Samsung’s Spoliation of Evidence; 4 10. The confidential, unredacted version of the Declaration of Michael Finnegan in 5 Support of Opposition to Apple Inc.’s Motion for Adverse Inference Jury 6 Instructions Due to Samsung’s Spoliation of Evidence; 7 11. The confidential, unredacted version of the Declaration of Woo-up Kwon in 8 Support of Opposition to Apple Inc.’s Motion for Adverse Inference Jury 9 Instructions Due to Samsung’s Spoliation of Evidence; 10 12. The confidential, unredacted version of the Declaration of Ioi Lam in Support of 11 Opposition to Apple Inc.’s Motion for Adverse Inference Jury Instructions Due to 12 Samsung’s Spoliation of Evidence; 13 13. The confidential, unredacted version of the Declaration of Don Joo Lee in Support 14 of Opposition to Apple Inc.’s Motion for Adverse Inference Jury Instructions Due 15 to Samsung’s Spoliation of Evidence; 16 14. The confidential, unredacted version of the Declaration of Kang Hyun Lee in 17 Support of Opposition to Apple Inc.’s Motion for Adverse Inference Jury 18 Instructions Due to Samsung’s Spoliation of Evidence; 19 15. The confidential, unredacted version of the Declaration of Kyu Hyuk Lee in 20 Support of Opposition to Apple Inc.’s Motion for Adverse Inference Jury 21 Instructions Due to Samsung’s Spoliation of Evidence; 22 16. The confidential, unredacted version of the Declaration of Minhyouk Lee in 23 Support of Opposition to Apple Inc.’s Motion for Adverse Inference Jury 24 Instructions Due to Samsung’s Spoliation of Evidence; 25 17. The confidential, unredacted version of the Declaration of Sungsik Lee in Support 26 of Opposition to Apple Inc.’s Motion for Adverse Inference Jury Instructions Due 27 to Samsung’s Spoliation of Evidence; 28 Case No. 11-cv-01846-LHK SAMSUNG’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL -2- 1 18. The confidential, unredacted version of the Declaration of Min Cheol Schin in 2 Support of Opposition to Apple Inc.’s Motion for Adverse Inference Jury 3 Instructions Due to Samsung’s Spoliation of Evidence; 4 19. The confidential, unredacted version of the Declaration of YoungSoon Lee in 5 Support of Opposition to Apple Inc.’s Motion for Adverse Inference Jury 6 Instructions Due to Samsung’s Spoliation of Evidence; 7 20. The confidential, unredacted version of the Declaration of Jong-Dae Park in 8 Support of Opposition to Apple Inc.’s Motion for Adverse Inference Jury 9 Instructions Due to Samsung’s Spoliation of Evidence; 10 21. The confidential, unredacted version of the Declaration of M. James Daley in 11 Support of Opposition to Apple Inc.’s Motion for Adverse Inference Jury 12 Instructions Due to Samsung’s Spoliation of Evidence; 13 22. The confidential, unredacted version of the Declaration of Joo Hyuk Kang in 14 Support of Opposition to Apple Inc.’s Motion for Adverse Inference Jury 15 Instructions Due to Samsung’s Spoliation of Evidence; 16 23. The confidential, unredacted version of the Declaration of Won Pyo Hong in 17 Support of Opposition to Apple Inc.’s Motion for Adverse Inference Jury 18 Instructions Due to Samsung’s Spoliation of Evidence; 19 24. The confidential, unredacted version of the Declaration of Alex Binder in Support 20 of Opposition to Apple Inc.’s Motion for Adverse Inference Jury Instructions Due 21 to Samsung’s Spoliation of Evidence (“the Binder Declaration”); 22 25. Exhibits 1 to the Binder Declaration; 23 26. Exhibits 2-3 to the Binder Declaration; 24 27. The confidential, unredacted version of the Declaration of Sara Jenkins in Support 25 of Opposition to Apple Inc.’s Motion for Adverse Inference Jury Instructions Due 26 to Samsung’s Spoliation of Evidence; and 27 28 Case No. 11-cv-01846-LHK SAMSUNG’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL -3- 1 28. Exhibits 1, 4-30, 32, and 33 to the Declaration of Thomas Watson in Support of 2 Opposition to Apple Inc.’s Motion for Adverse Inference Jury Instructions Due to 3 Samsung’s Spoliation of Evidence. 4 In short, the above documents discuss, refer to, or comprise excerpts of documents or other 5 information that Samsung or Apple have designated as HIGHLY CONFIDENTIAL – 6 ATTORNEYS’ EYES ONLY under the Protective Order. Apple has designated Exhibits 2 and 3 7 to the Binder Declaration HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY. 8 Samsung expects that Apple will file a declaration pursuant to Civil L.R. 79-5(d) establishing 9 good cause to seal these documents. Samsung has established good cause to permit filing items 10 1-25 and 27-28 under seal through the Declaration of Daniel Shim in Support of Samsung’s 11 Administrative Motion to File Documents Under Seal, filed herewith. 12 Pursuant to General Order No. 62, Samsung’s entire filing will be lodged with the Court 13 for in camera review and served on all parties. Proposed redacted versions of items 1-24 and 27 14 have been filed concurrently with this motion. 15 16 17 DATED: May 29, 2012 18 QUINN EMANUEL URQUHART & SULLIVAN, LLP 19 20 21 22 23 24 25 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 26 27 28 Case No. 11-cv-01846-LHK SAMSUNG’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL -4-

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?