Leader Technologies Inc. v. Facebook Inc.

Filing 677

REPLY to Response to Motion re 673 MOTION to Redact 672 Transcript, (March 12, 2010 Hearing) filed by Facebook Inc.(a Delaware corporation). (Caponi, Steven)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
LEADER TECHNOLOGIES, INC., a
Delaware corporation,
Plaintiff-Counterdefendant,
Civil Action No. 08-862-LPS
v.
FACEBOOK, INC., a Delaware corporation,
Defendant-Counterclaimant.
DEFENDANT FACEBOOK, INC.’S REPLY IN SUPPORT OF ITS MOTION FOR
REDACTION OF ELECTRONIC TRANSCRIPT OF THE MARCH 12, 2010 HEARING
I.

REPLY
Judge Stark presided over a discovery hearing in the above referenced matter on March

12, 2010.

During this hearing highly confidential and proprietary information regarding

Defendant Facebook was discussed. Leader has opposed Facebook’s Motion to Redact the
transcript of this hearing on the basis that the discussions therein reveal neither the source code
nor the actual contents of internal Facebook documents. Leader’s view of the contents of the
discussion, however, is oversimplified. Leader disregards the confidential and proprietary nature
of the methods underlying Facebook’s operation, beyond just the specific code that runs the
website. Indeed the transcript contains discussion of the structure of the Facebook source code
and method of preservation of that code, the means by which engineers relate and share
information about the code, as well as references to specific projects related to the website. See,
e.g. Transcript of Hearing of March 12, 2010 at 52:15-53:3. Accordingly, this information
should be redacted in the transcript of the hearing.
IV.

CONCLUSION
For all the reasons stated above, Facebook respectfully requests that the Court grant its

motion for redaction of the electronic transcript of the hearing held on March 12, 2010.

Dated: January 7, 2011
OF COUNSEL:
Heidi L. Keefe (pro hac vice)
Mark R. Weinstein (pro hac vice)
Jeffrey Norberg (pro hac vice)
Melissa H. Keyes (pro hac vice)
Elizabeth L. Stameshkin (pro hac vice
COOLEY GODWARD KRONISH LLP
3000 El Camino Real
5 Palo Alto Square, 4th Floor
Palo Alto, CA 94306

By: Steven L. Caponi
Steven L. Caponi (DE Bar #3484)
BLANK ROME LLP
1201 N. Market Street, Suite 800
Wilmington, DE 19801
302-425-6400
Fax: [phone]
Attorneys for Defendant-Counterclaimant
Facebook, Inc.

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