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

Filing 999

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 Samsung's Opposition to Apple's Motion to Exclude Testimony of Samsung's Experts, #3 Declaration of Joby Martin in Support of Samsung's Opposition, #4 Exhibit A to the Martin Declaration, #5 Exhibit B to the Martin Declaration, #6 Exhibit C to the Martin Declaration, #7 Exhibit D to the Martin Declaration, #8 Exhibit E to the Martin Declaration, #9 Exhibit F to the Martin Declaration, #10 Exhibit G to the Martin Declaration, #11 Exhibit H to the Martin Declaration, #12 Exhibit I to the Martin Declaration, #13 Exhibit J to the Martin Declaration, #14 Exhibit K to the Martin Declaration, #15 Exhibit L to the Martin Declaration, #16 Exhibit M to the Martin Declaration, #17 Exhibit N to the Martin Declaration, #18 Exhibit O to the Martin Declaration, #19 Exhibit P to the Martin Declaration, #20 Exhibit Q to the Martin Declaration, #21 Exhibit R to the Martin Declaration, #22 Exhibit S to the Martin Declaration, #23 Proposed Order Denying Apple's Motion to Exclude Testimony of Samsung's Experts)(Maroulis, Victoria) (Filed on 5/31/2012)

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP
Charles K. Verhoeven (Cal. Bar No. 170151)
2 [e-mail]
50 California Street, 22nd Floor
3 San Francisco, California 94111
Telephone: [phone]
4 Facsimile: [phone]
5 Kevin P.B. Johnson (Cal. Bar No. 177129)
[e-mail]
6 Victoria F. Maroulis (Cal. Bar No. 202603)
[e-mail]
7 555 Twin Dolphin Drive 5th Floor
Redwood Shores, California 94065
8 Telephone: [phone]
Facsimile: [phone]
9
Michael T. Zeller (Cal. Bar No. 196417)
10 [e-mail]
865 S. Figueroa St., 10th Floor
11 Los Angeles, California 90017
Telephone: [phone]
12 Facsimile: [phone]
13 Attorneys for SAMSUNG ELECTRONICS
CO., LTD., SAMSUNG ELECTRONICS
14 AMERICA, INC. and SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

18 APPLE INC., a California corporation,
Plaintiff,

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CASE NO. 11-cv-01846-LHK
SAMSUNG’S ADMINISTRATIVE
MOTION TO FILE DOCUMENTS
UNDER SEAL

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,
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Defendants.
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Case No. 11-cv-01846-LHK
SAMSUNG’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL

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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:
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1. The confidential, unredacted version of Samsung's Opposition to Apple's Motion to

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Exclude Testimony of Samsung's Experts;
2. Exhibits D -G, I, N, O and Q to the Declaration of Joby Martin in Support of the

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Opposition to Exclude Testimony of Samsung's Experts;
3. The confidential, unredacted version of Samsung's Opposition to Apple's Motion to

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Strike Portions of Samsung's Expert Reports;
4. Exhibits B - D, G - M, P, Q, S - U, X, Y, BB, DD - FF to the Declaration of James

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Ward in Support of the Opposition to Apple's Motion to Strike Portions of

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Samsung's Expert Reports ("Ward Declaration"); and

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5. Exhibits 1, 3-9, 12-17 and 20 to the Declaration of Joby Martin in Support of the

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Opposition to Apple's Motion to Strike Portions of Samsung's Expert Reports.

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In short, the above documents discuss, refer to, or comprise interrogatory objections and

17 responses that either Samsung or Apple has designated as HIGHLY CONFIDENTIAL —
18 ATTORNEYS' EYES ONLY.
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The documents identified below contain Apple confidential business information or have

20 been designated by Apple as HIGHLY CONFIDENTIAL — ATTORNEYS' EYES ONLY.
21 Samsung expects that Apple will file the declaration require by Local Rule 79-5(d) to establish the
22 following documents as sealable:
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•

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Exhibits I and N to the Declaration of Joby Martin in Support of the Opposition to
Exclude Testimony of Samsung's Experts;

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Exhibits H - L, T, X and Y to James Ward's Declaration in Support of Samsung's

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Opposition to Apple Inc.'s Motion to Strike Portions of Samsung's Expert Reports;

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and

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Case No. 11-cv-01846-LHK
-1SAMSUNG’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL

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Exhibits 3, 7-9, 12-17 and 20 to the Declaration of Joby Martin in Support of the
Opposition to Apple's Motion to Strike Portions of Samsung's Expert Reports

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Pursuant to General Order No. 62, Samsung’s entire filing will be lodged with the Court

5 for in camera review and served on all parties.

A proposed redacted version of Samsung's

6 exhibits have been filed concurrently with this motion.
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8 DATED: May 31, 2012
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QUINN EMANUEL URQUHART &
SULLIVAN, LLP

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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

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Case No. 11-cv-01846-LHK
-2SAMSUNG’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL