Google Inc. v. Rockstar Consortium US LP et al

Filing 19

Administrative Motion to File Under Seal certain portions of Defendant's Motion to dismiss and supporting declaration filed by MobileStar Technologies LLC, Rockstar Consortium US LP. (Attachments: # 1 Declaration OF JOSHUA BUDWIN, # 2 Proposed Order, # 3 REDACTED Motion to Dimiss, # 4 UNREDACTED Motion to Dismiss, # 5 REDACTED Declaration of Afzal Dean, # 6 UNREDACTED Declaration of Afzal Dean)(Reichman, Courtland) (Filed on 1/23/2014)

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Courtland L. Reichman (SBN 268873)
[e-mail]
MCKOOL SMITH HENNIGAN P.C.
255 Shoreline Drive, Suite 510
Redwood Shores, CA 94065
Telephone: [phone]
Fax: [phone]
Mike McKool (pro hac vice application to be filed)
[e-mail]
Douglas A. Cawley (pro hac vice application to be filed)
[e-mail]
Ted Stevenson III (pro hac vice application to be filed)
[e-mail]
David Sochia (pro hac vice application filed)
[e-mail]
300 Crescent Court Suite 1500
Dallas, TX 75201
[phone]
[phone] (facsimile)

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255 Shoreline Drive, Suite 510
Redwood Shores, CA 94065

McKool Smith Hennigan, P.C.

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Attorneys for Defendants Rockstar
Consortium US LP and MobileStar
Technologies LLC

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
OAKLAND DIVISION

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GOOGLE INC.,
Plaintiffs,

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vs.
ROCKSTAR CONSORTIUM US LP, and
MOBILESTAR TECHNOLOGIES LLC,

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Defendant.

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Case No. 13-CV-05933 (CW)
DECLARATION OF JOSHUA BUDWIN
IN SUPPORT OF DEFENDANT
ROCKSTAR CONSORTIUM US LP, AND
MOBILESTAR TECHNOLOGIES LLC’S
ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL

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Case No. 13-CV-05933 (CW)

Declaration of Joshua Budwin

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I, Joshua Budwin, declare:
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I am an attorney with the law firm of McKool Smith P.C., counsel of record for

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Defendants Rockstar Consortium US LP and Mobilestar Technologies LLC. (collectively

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“Rockstar”) in the above-entitled action. I am duly licensed to practice law in the State of Texas. I

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make this declaration based on my personal knowledge, the record in this action, and matters of

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public record, and if called upon as a witness, I could and would testify competently as to the

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matters set forth below.

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2.

Rockstar is bound by non-disclosure agreements with various non-parties to keep

Fed. R. Civ. P. 12(b)(2) and 12(b)(3) for Lack of Personal Jurisdiction and Improper Venue and to

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255 Shoreline Drive, Suite 510
Redwood Shores, CA 94065

confidential the information contained in certain portions of Rockstar’s Motion to Dismiss under

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McKool Smith Hennigan, P.C.

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Decline Exercising Jurisdiction under the Declaration Judgment Act (hereinafter “Motion to

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Dismiss”).

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3.

Rockstar is also bound by non-disclosure agreements with various non-parties to

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keep confidential the information contained in certain portions of the Declaration of Afzal Dean in

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Support of Rockstar’s Motion to Dismiss.

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4.

Details of Rockstar’s licensing negotiations with non-parties, including the identities

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of entities currently negotiating with Rockstar, is sensitive, confidential and proprietary business

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information of Rockstar and these non-party entities. Such information is relevant to Rockstar’s

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licensing and business strategies. Rockstar and these non-party entities will be harmed by public

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disclosure of this information.

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5.

I have served this declaration on the Declaratory Judgment Plaintiff on January 23,

2014 pursuant to Local Rule 79-5(e).
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An unredacted copy of Rockstar’s Motion to Dismiss and Declaration of Afzal Dean

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in Support of Rockstar’s Motion to Dismiss is attached hereto with all supporting materials,

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including the confidential portions described above.

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-2Case No. 13-CV-05933 (CW)

Declaration of Joshua Budwin