Cisco Systems Inc v. STMicroelectronics Inc

Filing 112

JOINT STIPULATION AND ORDER 109 to Extend Time to Submit Evidence in Support of Plaintiff Cisco Systems, Inc.'s Motion to Seal. Signed by Judge Ronald M. Whyte on 7/24/15. (jgS, COURT STAFF) (Filed on 7/24/2015)

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101 California Street
San Francisco, CA 94111-5802

Winston & Strawn LLP

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Krista M. Enns (SBN: 206430)
[e-mail]
WINSTON & STRAWN LLP
101 California Street
San Francisco, CA 94111-5802
Telephone:
[phone]
Facsimile:
[phone]
Dan K. Webb (pro hac vice)
[e-mail]
J. Erik Connolly (pro hac vice)
[e-mail]
WINSTON & STRAWN LLP
35 West Wacker Drive
Chicago, IL 60601
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Plaintiff
CISCO SYSTEMS, INC.

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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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CISCO SYSTEMS, INC.,

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Plaintiff,
v.
STMICROELECTRONICS, INC. and
STMICROELECTRONICS, S.r.l.,

Case No. 5:14-cv-03236-RMW-HRL
JOINT STIPULATION AND []
ORDER TO EXTEND TIME TO SUBMIT
EVIDENCE IN SUPPORT OF PLAINTIFF
CISCO SYSTEMS, INC.’S MOTION TO
SEAL PURSUANT TO LOCAL RULE
79-5(e)

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Defendant.
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JOINT STIPULATION AND [] ORDER TO EXTEND TIME TO SUBMIT EVIDENCE ISO PLAINTIFF CISCO SYSTEMS,
INC.’S MOTION TO SEAL PURSUANT TO LOCAL RULE 79-5(e) – CASE NO. 5:14-CV-03236-RMW-HRL

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Plaintiff Cisco Systems, Inc. (“Cisco”) and Defendants STMicroelectronics, Inc. (“STMicro-

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US”) and STMicroelectronics, S.r.l. (“STMicro-Italy,” and collectively, “Defendants”), by and

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through their undersigned counsel, hereby stipulate as follows:

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WHEREAS, on July 14, 2015, Cisco filed its opposition to STMicro-Italy’s motion to
dismiss for lack of personal jurisdiction (the “Opposition,” ECF No. 106);
WHEREAS, the Opposition includes various exhibits, including seven with respect to which

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Cisco believes STMicro-US and/or STMicro-Italy will take the position that they should be filed

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under seal, specifically:

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101 California Street
San Francisco, CA 94111-5802

Winston & Strawn LLP

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1. ECF No. 105-3 – Exhibit B to DECLARATION OF THIERRY SOLOMON IN
SUPPORT OF PLAINTIFF CISCO SYSTEMS, INC.’S OPPOSITION TO
STMICROELECTRONICS, S.R.L.’S MOTION TO DISMISS FOR LACK OF
PERSONAL JURISDICTION. UNREDACTED VERSION OF DOCUMENT(S)
SOUGHT TO BE SEALED.
2. ECF No. 105-5 – Exhibit C to DECLARATION OF THIERRY SOLOMON IN
SUPPORT OF PLAINTIFF CISCO SYSTEMS, INC.’S OPPOSITION TO
STMICROELECTRONICS, S.R.L.’S MOTION TO DISMISS FOR LACK OF
PERSONAL JURISDICTION. UNREDACTED VERSION OF DOCUMENT(S)
SOUGHT TO BE SEALED.
3. ECF No. 105-7 – Exhibit D to DECLARATION OF THIERRY SOLOMON IN
SUPPORT OF PLAINTIFF CISCO SYSTEMS, INC.’S OPPOSITION TO
STMICROELECTRONICS, S.R.L.’S MOTION TO DISMISS FOR LACK OF
PERSONAL JURISDICTION. UNREDACTED VERSION OF DOCUMENT(S)
SOUGHT TO BE SEALED.
4. ECF No. 105-9 – Exhibit E to DECLARATION OF THIERRY SOLOMON IN
SUPPORT OF PLAINTIFF CISCO SYSTEMS, INC.’S OPPOSITION TO
STMICROELECTRONICS, S.R.L.’S MOTION TO DISMISS FOR LACK OF
PERSONAL JURISDICTION. UNREDACTED VERSION OF DOCUMENT(S)
SOUGHT TO BE SEALED.
5. ECF No. 105-11 – Exhibit F to DECLARATION OF THIERRY SOLOMON IN
SUPPORT OF PLAINTIFF CISCO SYSTEMS, INC.’S OPPOSITION TO
STMICROELECTRONICS, S.R.L.’S MOTION TO DISMISS FOR LACK OF
PERSONAL JURISDICTION. UNREDACTED VERSION OF DOCUMENT(S)
SOUGHT TO BE SEALED.
6. ECF No. 105-13 – Exhibit A to DECLARATION OF ARDAVAN POURHAMZEH IN
SUPPORT OF PLAINTIFF CISCO SYSTEMS, INC.'S OPPOSITION TO
STMICROELECTRONICS, S.R.L.'S MOTION TO DISMISS FOR LACK OF
PERSONAL JURISDICTION. UNREDACTED VERSION OF DOCUMENT(S)
SOUGHT TO BE SEALED.
7. ECF No. 105-15 – Exhibit A to DECLARATION OF RICHARD MARSZALIK IN
SUPPORT OF PLAINTIFF CISCO SYSTEMS, INC.'S OPPOSITION TO
STMICROELECTRONICS, S.R.L.'S MOTION TO DISMISS FOR LACK OF
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JOINT STIPULATION AND [] ORDER TO EXTEND TIME TO SUBMIT EVIDENCE ISO PLAINTIFF CISCO SYSTEMS,
INC.’S MOTION TO SEAL PURSUANT TO LOCAL RULE 79-5(e) – CASE NO. 5:14-CV-03236-RMW-HRL

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PERSONAL JURISDICTION. UNREDACTED VERSION OF DOCUMENT(S)
SOUGHT TO BE SEALED.

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WHEREAS, Cisco filed an administrative motion to seal each of these exhibits (ECF No.

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105);
WHEREAS, pursuant to Local Rule 79-5(e), Defendants have until July 20, 2015 (because

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the fourth day from Cisco’s July 14, 2015 filing falls on a weekend day) to file a declaration to

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support the sealing;

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101 California Street
San Francisco, CA 94111-5802

Winston & Strawn LLP

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WHEREAS, the parties have agreed to extend Defendants’ time to file a declaration as
required by Local Rule 79-5(e) to July 30, 2015;
NOW THEREFORE, Cisco and Defendants stipulate as follows, subject to the Court’s
approval:


Defendants shall have until July 30, 2015, to file and serve a declaration in support of
sealing pursuant to Local Rule 79-5(e).

IT IS SO STIPULATED.

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Dated: July 17, 2015

WINSTON & STRAWN LLP

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By:
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/s/Krista M. Enns
Krista M. Enns
Attorneys for Plaintiff
CISCO SYSTEMS, INC.

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Dated: July 17, 2015

SIDLEY AUSTIN LLP

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By:
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Dated: July 17, 2015

/s/ Nicole Ryan
Nicole Ryan
Attorneys for Defendant
STMICROELECTRONICS, INC.

SIDLEY AUSTIN LLP

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By:
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/s/ Nicole Ryan
Nicole Ryan
Attorneys for Defendant
STMICROELECTRONICS, S.r.l.
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JOINT STIPULATION AND [] ORDER TO EXTEND TIME TO SUBMIT EVIDENCE ISO PLAINTIFF CISCO SYSTEMS,
INC.’S MOTION TO SEAL PURSUANT TO LOCAL RULE 79-5(e) – CASE NO. 5:14-CV-03236-RMW-HRL

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Dated: July __, 2015
Ronald M. Whyte
United States District Judge

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LOCAL RULE 5-1 ATTESTATION

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I, Krista M. Enns, am the ECF User whose ID and password was used to file this JOINT

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STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO SUBMIT EVIDENCE IN

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SUPPORT OF PLAINTIFF CISCO SYSTEMS, INC.’S MOTION TO SEAL PURSUANT TO

101 California Street
San Francisco, CA 94111-5802

LOCAL RULE 79-5(e). In compliance with Local Rule 5-1(i)(3), I hereby attest that, counsel for

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Winston & Strawn LLP

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Defendants, concurred in this filing.

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Dated: July 17, 2015

By:

/s/Krista M. Enns
Krista M. Enns

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JOINT STIPULATION AND [] ORDER TO EXTEND TIME TO SUBMIT EVIDENCE ISO PLAINTIFF CISCO SYSTEMS,
INC.’S MOTION TO SEAL PURSUANT TO LOCAL RULE 79-5(e) – CASE NO. 5:14-CV-03236-RMW-HRL