Apple Inc. v. Samsung Electronics Co. Ltd. et al
Filing
996
Administrative Motion to File Under Seal Documents Under Seal Re Apples Opposition To Samsungs Motion To Strike Expert Testimony filed by Apple Inc.. (Attachments: #1 Declaration Of Cyndi Wheeler In Support Of Apples Administrative Motion To File Under Seal Documents Re Apples Opposition To Samsungs Motion To Strike Expert Testimony, #2 Declaration Of Mia Mazza In Support Of Apples Administrative Motion To File Documents Under Seal Re Apples Opposition To Samsungs Motion To Strike Expert Testimony, #3 [Proposed] Order Granting Apples Administrative Motion To File Documents Under Seal Re Apples Opposition To Samsungs Motion To Strike, #4 Apples Opposition To Samsungs Motion To Strike Expert Testimony Based On Undisclosed Facts And Theories, #5 Declaration Of Marc J. Pernick In Support Of Apples Opposition To Samsungs Motion To Strike Expert Testimony Based On Undisclosed Facts And Theories, #6 Exhibit Pernick Decl. Ex. 8, #7 Exhibit Pernick Decl. Ex. 10, #8 Exhibit Pernick Decl. Ex. 11, #9 Exhibit Pernick Decl. Ex. 12, #10 Exhibit Pernick Decl. Ex. 16, #11 Exhibit Pernick Decl. Ex. 17, #12 Exhibit Pernick Decl. Ex. 19, #13 Declaration Of Michel Maharbiz, Ph.D. In Support Of Apples Opposition To Samsungs Motion To Strike Expert Testimony, #14 Exhibit Maharbiz Decl. Ex. A, #15 Exhibit Maharbiz Decl. Ex. B, #16 [Proposed] Order Denying Samsungs Motion To Strike Expert Testimony (Dkt. No. 936))(Jacobs, Michael) (Filed on 5/31/2012) Modified on 6/3/2012 pursuant to General Order No. 62, attachment #1 and #2 Sealed (dhm, COURT STAFF).
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HAROLD J. MCELHINNY (CA SBN 66781)
hmcelhinny@mofo.com
MICHAEL A. JACOBS (CA SBN 111664)
mjacobs@mofo.com
JENNIFER LEE TAYLOR (CA SBN 161368)
jtaylor@mofo.com
ALISON M. TUCHER (CA SBN 171363)
atucher@mofo.com
RICHARD S.J. HUNG (CA SBN 197425)
rhung@mofo.com
JASON R. BARTLETT (CA SBN 214530)
jasonbartlett@mofo.com
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: (415) 268-7000
Facsimile: (415) 268-7522
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WILLIAM F. LEE
william.lee@wilmerhale.com
WILMER CUTLER PICKERING
HALE AND DORR LLP
60 State Street
Boston, MA 02109
Telephone: (617) 526-6000
Facsimile: (617) 526-5000
MARK D. SELWYN (SBN 244180)
mark.selwyn@wilmerhale.com
WILMER CUTLER PICKERING
HALE AND DORR LLP
950 Page Mill Road
Palo Alto, California 94304
Telephone: (650) 858-6000
Facsimile: (650) 858-6100
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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,
Case No.
11-cv-01846-LHK (PSG)
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Plaintiff,
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v.
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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,
DECLARATION OF
MIA MAZZA IN SUPPORT OF
APPLE’S ADMINISTRATIVE
MOTION TO FILE DOCUMENTS
UNDER SEAL RE APPLE’S
OPPOSITION TO SAMSUNG’S
MOTION TO STRIKE EXPERT
TESTIMONY
Defendants.
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DECLARATION OF MIA MAZZA ISO APPLE’S MOTION TO FILE UNDER SEAL
CASE NO. 4:11-cv-01846-LHK (PSG)
sf-3153339
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I, Mia Mazza, do hereby declare as follows:
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1.
I am an attorney with the law firm of Morrison & Foerster LLP and counsel for
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plaintiff and counterclaim-defendant Apple Inc. (“Apple”). I am familiar with and
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knowledgeable about the facts stated in this declaration and if called upon could and would testify
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competently as to the statements made herein. I submit this declaration in support of Apple’s
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Administrative Motion to File Documents Under Seal re Apple’s Opposition to Samsung’s
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Motion to Strike Expert Testimony (“Opposition”).
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2.
The Declaration of Marc Pernick in Support of Apple’s Opposition to Samsung’s
Motion to Strike Expert Testimony (“Pernick Declaration”), the Declaration of Terry L. Musika,
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CPA in Support of Apple’s Opposition to Samsung’s Motion to Strike Expert Testimony
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(“Musika Declaration”), and the Declaration of Dr. Michel Maharbiz in Support of Apple’s
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Opposition to Samsung’s Motion to Strike Expert Testimony (“Maharbiz Declaration”) contain
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information that third parties have designated confidential. Specifically:
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A.
Exhibit 10 to the Pernick Declaration is excerpts from the Expert Report of
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Tony Givargis, Ph.D. Regarding Invalidity of the Asserted Claims of U.S.
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Patent No. 7,698,711. This Report contains confidential information
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supplied by third party Sony Ericsson in paragraphs 96 and 99. .
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B.
As indicated in the Wheeler Declaration, the Musika Declaration contains
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confidential information relating to Apple licensing agreements. Due to
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the nature of a license, these agreements also contain confidential
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information supplied by third parties.
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C.
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The Maharbiz Declaration and Exhibit D attached thereto contain
confidential information supplied by third party Atmel.
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D.
To the extent Apple’s Opposition and the Maharbiz and Musika
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Declarations refer to or discuss the above-referenced materials, they
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contain third-party confidential information and should therefore be sealed
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for the same reasons.
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DECLARATION OF MIA MAZZA ISO APPLE’S MOTION TO FILE UNDER SEAL
CASE NO. 4:11-cv-01846-LHK (PSG)
sf-3153339
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3.
The relief requested in this motion is necessary and is narrowly tailored to protect
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confidential information, focusing only on the specific exhibits and specific portions of the briefs
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and declarations at issue.
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I declare under the penalty of perjury under the laws of the United States of America that
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the forgoing is true and correct to the best of my knowledge and that this Declaration was
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executed this 31st day of May, 2012, at Palo Alto, California.
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Dated: May 31, 2012
By: __/s/ Mia Mazza ____________
Mia Mazza
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DECLARATION OF MIA MAZZA ISO APPLE’S MOTION TO FILE UNDER SEAL
CASE NO. 4:11-cv-01846-LHK (PSG)
sf-3153339
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ATTESTATION OF E-FILED SIGNATURE
I, Michael A. Jacobs, am the ECF User whose ID and password are being used to file this
Declaration. In compliance with General Order 45, X.B., I hereby attest that Mia Mazza has
concurred in this filing
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/s/ Michael A. Jacobs
Michael A. Jacobs
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DECLARATION OF MIA MAZZA ISO APPLE’S MOTION TO FILE UNDER SEAL
CASE NO. 4:11-cv-01846-LHK (PSG)
sf-3153339
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