Google Inc. v. Rockstar Consortium US LP et al

Filing 39

Administrative Motion to File Under Seal filed by MobileStar Technologies LLC, Rockstar Consortium US LP. (Attachments: # 1 Proposed Order, # 2 Declaration of David Sochia, # 3 REDACTED Reply re Motion to Dismiss, # 4 UNREDACTED Reply re Motion to Dismiss)(Reichman, Courtland) (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
Redwood Shores, CA 94065
[phone]
[phone] (facsimile)
Mike McKool (Pro Hac Vice Application Pending)
Douglas A. Cawley (Admitted Pro Hac Vice)
Ted Stevenson III (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
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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vs.
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Rockstar Consortium U.S. LP and MobileStar
Technologies LLC

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Defendants.

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Case No. 13-cv-5933
HON. CLAUDIA WILKEN
[PROPOSED] ORDER TO SEAL
DOCUMENTS FILED IN SUPPORT
OF DEFENDANT’S REPLY TO
GOOGLE’S OPPOSITION TO
PLAINTIFF’S MOTION TO
DISMISS AND TO DECLINE
EXERCISING JURISDICTION
UNDER THE DECLARATORY
JUDGMENT ACT

)

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13-CV-05933

[PROPOSED] Order to Seal Documents Filed in Support of Defendant’s Reply

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TO ALL PARTIES HEREIN:

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The Court has read and considered Defendants Rockstar Consortium U.S. LP and MobileStar

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Technologies LLC’s Administrative Motion for a Sealing Order in Support of Its Opposition to

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Defendant’s Motion to Dismiss or Transfer (“Reply”), pursuant to Local Rules 79-5 and 7-11, to file

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selected documents comprised of highly sensitive information regarding Rockstar Consortium U.S.

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LP and MobileStar Technologies LLC’s (collectively, “Defendants”) private negotiations and trade

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secrets.

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Defendants’ interest in protecting information concerning private negotiations and trade
secrets overcomes the right of public access to these records, and is good cause to support the sealing

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of the records. If the records are not sealed, there is a substantial probability that Defendants’

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interests in the confidential information and trade secrets will be prejudiced. The sealing is narrowly

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tailored in that it is limited only to those documents containing such information. Good cause

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appearing therefor, this Court finds pursuant to Civil L.R. 79-5, that:

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(1)

The documents to be sealed, or portions thereof, are
entitled to protection under the law, that overcomes the
right of public access to the record; and

(2)

The proposed sealing is narrowly tailored.

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IT IS ORDERED THAT the Motion (1) to seal the highly confidential information contained

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in the Defendants’ Reply to Google’s Opposition to Plaintff’s Motion to Dismiss and to Decline

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Exercising Jurisdiction Under the Declaratory Judgment Act is GRANTED and that those

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documents and portions of documents are hereby ordered to be filed under seal.

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DATED:_________________

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___________________________________
Hon. Claudia Wilken
UNITED STATES DISTRICT JUDGE

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13-CV-05933

-2[PROPOSED] Order to Seal Documents Filed in Support of Defendant’s Reply