Google Inc. v. Rockstar Consortium US LP et al

Filing 35

Declaration of David Sochia in Support of 30 Administrative Motion to File Under Seal Google Inc.'s Opposition to Defendants' Motion to Dismiss or Transfer filed byMobileStar Technologies LLC, Rockstar Consortium US LP. (Related document(s) 30 ) (Sochia, David) (Filed on 2/13/2014)

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Courtland L. Reichman (SBN 268873)
[e-mail]
McKool Smith Hennigan, P.C.
255 Shoreline Drive Suite 510

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Redwood Shores, CA 94065

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[phone]
[phone] (facsimile)

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Mike McKool (Pro Hac Vice Application Pending)
Douglas A. Cawley (Admitted Pro Hac Vice)
Ted Stevenson HI (Admitted Pro Hac Vice)
David Sochia (Admitted Pro Hac Vice)
McKool Smith, P.C.
300 Crescent Court, Suite 1500
Dallas, TX 75201
[phone]
[phone] (facsimile)

Attorneys for Defendants
Rockstar Consortium U.S. LP and

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MobileStar Technologies LLC

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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OAKLAND
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Google, Inc.
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Plaintiff,
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Case No. 13-cv-5933
HON. CLAUDIA WILKEN

vs.

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Rockstar Consortium U.S. LP and MobileStar
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DECLARATION OF DAVID

Technologies LLC

SOCHIA IN SUPPORT OF
PLAINTIFF GOOGLE INC.'S

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Defendants.

ADMINISTRATIVE MOTION TO
FILE UNDER SEAL

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I, David Sochia, declare:

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I am an attorney with the law firm ofMcKool Smith P.C,, counsel of record for

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Defendants Rockstar Consortium U.S. 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 ofTexas. 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 ifcalled upon as a witness, I could and would testify competently as to the matters

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set forth below.

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2.

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

confidential the information contained in certain portions of Google Inc.'s Objection to Defendants'

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Motion to Dismiss or Transfer (hereinafter "Objection") and Exhibits 11 and 33 to Madigan's

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Declaration in Support of Google's Objection.

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

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confidential information contained in certain portions of Rockstar's Motion to Dismiss, the

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Declaration ofAfeal Dean in Support ofRockstar's Motion to Dismiss, both cited in the Objection.

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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 ofRockstar 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 ofthis information because the identities of the parties to licensing negotiations with

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Rockstar and the timing of those negotiations are essential to Rockstar's business and licensing

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strategies, as shown by the parties' execution of non-disclosure agreements.

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5.

I have served this declaration on the Declaratory Judgment Plaintiff on February 13,

2014 pursuant to Local Rule 79-5(e).

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An unredacted copy of Google's Opposition, along with all supporting materials,

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including Exhibits 11 and 33 to Madigan's Declaration in Support of Google's Objection and the

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confidential portions described above, was filed with the Court on February 6, 2014, and an

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unredacted copy ofthe Declaration of Afzal Dean in Support of Rockstar's Motion to Dismiss, along

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with supporting materials, was attached to the Declaration of Josh Budwin on January 23, 2014.
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I declare under penalty of perjury under the laws of the State of California that the

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foregoing is true and correct, and that this declaration was executed on February 13, 2014, at Dallas,

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Texas.

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David Sochia

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