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

Filing 993

Administrative Motion to File Under Seal filed by Apple Inc.. (Attachments: #1 [Proposed] Order Granting Administrative Motion To File Documents Under Seal, #2 Apple Inc.s Reply In Support Of Motion Pursuant To Rule 62(C) For Entry Of Preliminary Injunction Without Further Hearing, #3 [Proposed] Findings Of Fact And Conclusions Of Law And Order Granting Preliminary Injunction)(Jacobs, Michael) (Filed on 5/31/2012)

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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,
Plaintiff,

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v.
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 UNDER SEAL
CASE NO. 11-CV-01846-LHK

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

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In accordance with Civil Local Rules 7-11 and 79-5, and General Order No. 62, Apple Inc.
(“Apple”) submits this motion for an order to seal the following documents or portions thereof:

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1. The confidential, unredacted version of Apple’s Reply In Support of Apple Inc.’s Motion

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Pursuant To Rule 62(c) For Entry Of Preliminary Injunction Without Further Hearing

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(“Reply”);

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2. The confidential, unredacted version of Apple’s [Proposed] Findings of Fact and

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Conclusions Of Law and Order Granting Preliminary Injunction (“Proposed Order”).

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The documents above discuss confidential information that has been previously ordered

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sealed by this Court. (See Dkt. No. 410 (sealing certain exhibits attached to the Declaration of

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Francis Ho and certain other documents).) They also contain information that Samsung has

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designated as confidential under the protective order entered in this case. Pursuant to Civil L.R.

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79-5(d), Samsung has filed the Declaration of Hankil Kang in Support of Samsung’s

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Administrative Motion to File Documents Under Seal (see Dkt. No. 977-2, the “Kang

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Declaration”) for the purpose of establishing that the designated information is sealable. The

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Kang Declaration provides evidence that the information designated as confidential in Apple’s

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Reply and Proposed Order is “privileged or protectable as a trade secret or otherwise entitled to

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protection under the law,” and thus sealable. Civil L.R. 79-5(a).

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Pursuant to Civil Local Rule 79-(c), Apple will lodge with the Clerk the documents at

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issue with the sealable portions highlighted. Redacted versions of the documents at issue are

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attached as an exhibits hereto.

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Dated: May 31, 2012

MORRISON & FOERSTER LLP

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By:

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/s/ Michael A. Jacobs
Michael A. Jacobs
Attorneys for Plaintiff
APPLE INC.

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APPLE’S ADMINISTRATIVE MOTION TO FILE UNDER SEAL
CASE NO. 11-CV-01846-LHK

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