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

Filing 994

Administrative Motion to File Under Seal Second Supplemental Price Declaration in Support of (Dkt No. 934) Samsung's Motion to Strike filed by Samsung Electronics Co. Ltd.. (Attachments: #1 Price Declaration in Support of Motion to Seal, #2 Proposed Order Granting Motion to Seal, #3 Second Supplemental Price Declaration, #4 Exhibit A, #5 Exhibit B, #6 Exhibit C, #7 Exhibit D, #8 Exhibit E)(Maroulis, Victoria) (Filed on 5/31/2012) Modified on 6/3/2012 attachment #1 Sealed pursuant to General Order No. 62 (dhm, COURT STAFF).

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP
Charles K. Verhoeven (Bar No. 170151)
 [e-mail]
50 California Street, 22nd Floor
 San Francisco, California 94111
Telephone: [phone]
 Facsimile: [phone]
 Kevin P.B. Johnson (Bar No. 177129)
[e-mail]
 Victoria F. Maroulis (Bar No. 202603)
[e-mail]
th
 555 Twin Dolphin Drive, 5 Floor
Redwood Shores, California 94065-2139
 Telephone: [phone]
Facsimile: [phone]

 Michael T. Zeller (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 (PSG)



DECLARATION OF CHRISTOPHER E.
PRICE IN SUPPORT OF 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.


02198.51855/4785609.1

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

1

DECLARATION OF CHRISTOPHER E. PRICE



I, Christopher E. Price, declare as follows:



1.

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

 counsel for Samsung Electronics Co., Ltd., Samsung Electronics America, Inc. and Samsung
 Telecommunications America, LLC (collectively, “Samsung”). I submit this declaration in
 support of Samsung’s Administrative Motion to File Documents Under Seal. I have personal
 knowledge of the facts set forth in this declaration, except as otherwise noted, and, if called upon
 as a witness, I could and would testify to such facts under oath.


2.

Exhibit 1 to this Declaration is the May 31, 2012 Second Supplemental

 Declaration of Christopher E. Price (“Second Supplemental Price Declaration”).


3.

Exhibit A to the Second Supplemental Price Declaration is a true and correct

 copy of a May 31, 2012 letter from Peter J. Kolovos, counsel for Apple, to Diane C. Hutnyan,
 counsel for Samsung. Apple has designated this letter Highly Confidential – Attorney Eyes
 Only (“AEO”) under the protective order in this case, and Samsung expects that Apple will file a
 declaration pursuant to Civ. L.R. 79-5(d) establishing the document as confidential, and
 therefore it should be sealed.


4.

Exhibit B to the Second Supplemental Price Declaration is a true and correct

 copy of a license agreement. Apple has designated this agreement AEO under the protective
 order in this case, and Samsung expects that Apple will file a declaration pursuant to Civ. L.R.
 79-5(d) establishing the document as confidential, and therefore it should be sealed.


5.

Exhibit C to the Second Supplemental Price Declaration is a true and correct

 copy of a license agreement. Apple has designated this agreement AEO under the protective
 order in this case, and Samsung expects that Apple will file a declaration pursuant to Civ. L.R.
 79-5(d) establishing the document as confidential, and therefore it should be sealed.


6.

Exhibit D to the Second Supplemental Price Declaration is a true and correct

 copy of a license agreement. Apple has designated this agreement AEO under the protective
 order in this case, and Samsung expects that Apple will file a declaration pursuant to Civ. L.R.
 79-5(d) establishing the document as confidential, and therefore it should be sealed.
02198.51855/4785609.1

Case No. 11-cv-01846-LHK (PSG)
-1PRICE DECLARATION IN SUPPORT OF SAMSUNG’S ADMINISTRATIVE MOTION

1

7.

Exhibit E to the Second Supplemental Price Declaration is a true and correct copy

2 of a license 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

8.

The requested relief is necessary to protect the confidentiality of information

6 contained in the Second Supplemental Price Declaration and Exhibits A-E attached thereto.
7

9.

The confidential, unredacted version of the Second Supplemental Price

8 Declaration discusses and references information that Apple has designated as AEO under the
9 protective order in this case, and Samsung expects that Apple will file a declaration pursuant to
10 Civ. L.R. 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.
13

Executed on May 31, 2012, at Los Angeles, California.

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Christopher E. Price

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02198.51855/4785609.1

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

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

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02198.51855/4785609.1

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