Cisco Systems Inc v. STMicroelectronics Inc

Filing 35

JOINT STIPULATION AND ORDER 31 to Extend Time to Submit Evidence in Support of Plaintiff Cisco Systems, Inc.'s Motion to Seal. Signed by Judge Ronald M. Whyte on 9/23/14. (jgS, COURT STAFF) (Filed on 9/23/2014)

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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 forthcoming)
[e-mail]
J. Erik Connolly (pro hac vice pending)
[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.,

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)

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 Defendant STMicroelectronics, Inc. (“ST Micro,”

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together with Plaintiff, the “Parties”), by and through their undersigned counsel, hereby stipulate as

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follows:

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WHEREAS, on August 29, 2014, Cisco filed its Amended Complaint (ECF No. 21);

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WHEREAS, the Amended Complaint references 24 exhibits, each of which was filed with

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the Court (ECF Nos. 21-1 through 24-2);

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WHEREAS, ST Micro’s position is that 5 of these exhibits—Exhibit 1 (ECF No. 21-1),

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Exhibit 2 (ECF No. 21-2), Exhibit 3 (ECF No. 21-3), Exhibit 4 (ECF No. 21-4), Exhibit 8 (ECF No.

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22), and Exhibit 15 (ECF No. 23)—should be filed under seal;

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101 California Street
San Francisco, CA 94111-5802

Winston & Strawn LLP

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WHEREAS, pursuant to Court order, these exhibits were removed from the publicly filed
docket pending adjudication of an administrative motion to seal them (ECF No. 28);

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WHEREAS, Cisco filed an administrative motion to seal each of these exhibits (ECF No.
29);
WHEREAS, pursuant to Local Rule 79-5(e), ST Micro has until September 15, 2014

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(because the fourth days from Cisco’s September 9, 2014 filing falls on a weekend day) to file its

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declaration to support the sealing;

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WHEREAS, the parties have agreed to extend ST Micro’s time to file a declaration as
required by Local Rule 79-5(e) to September 22, 2014;
NOW THEREFORE, Cisco and ST Micro stipulate as follows, subject to the Court’s
approval:
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ST Micro shall have until September 22, 2014, to file and serve a declaration in
support of sealing pursuant to Local Rule 79-5(e).

IT IS SO STIPULATED.
Dated: September 12, 2014

WINSTON & STRAWN LLP

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By:

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

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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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Dated: September 12, 2014

SIDLEY AUSTIN LLP

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By:

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

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Dated: September __, 2014
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Ronald M. Whyte
United States District Judge

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101 California Street
San Francisco, CA 94111-5802

Winston & Strawn LLP

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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

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

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Defendant, concurred in this filing.

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Dated: September 12, 2014

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