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)
charlesverhoeven@quinnemanuel.com
50 California Street, 22nd Floor
San Francisco, California 94111
Telephone: (415) 875-6600
Facsimile: (415) 875-6700
Kevin P.B. Johnson (Bar No. 177129)
kevinjohnson@quinnemanuel.com
Victoria F. Maroulis (Bar No. 202603)
victoriamaroulis@quinnemanuel.com
th
555 Twin Dolphin Drive, 5 Floor
Redwood Shores, California 94065-2139
Telephone: (650) 801-5000
Facsimile: (650) 801-5100
Michael T. Zeller (Bar No. 196417)
michaelzeller@quinnemanuel.com
865 S. Figueroa St., 10th Floor
Los Angeles, California 90017
Telephone: (213) 443-3000
Facsimile: (213) 443-3100
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.
14
15
16
17
18
Christopher E. Price
19
20
21
22
23
24
25
26
27
28
02198.51855/4785609.1
Case No. 11-cv-01846-LHK (PSG)
-2PRICE DECLARATION IN SUPPORT OF SAMSUNG’S ADMINISTRATIVE MOTION
1
2
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.
5
6
/s/ Victoria Maroulis
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
02198.51855/4785609.1
Case No. 11-cv-01846-LHK (PSG)
-3PRICE DECLARATION IN SUPPORT OF SAMSUNG’S ADMINISTRATIVE MOTION
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?