Motorola Mobility, Inc. v. Apple, Inc.

Filing 179

NOTICE by Apple, Inc. Apple Inc.'s Response in Support of Motorola Mobility, Inc.'s Motion for Leave to File Document Under Seal (Attachments: # 1 Affidavit Supplemental Declaration of Christine Saunders Haskett, # 2 Text of Proposed Order)(Pace, Christopher)

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
Case No. 1:10cv023580-Civ-UU

MOTOROLA MOBILITY, INC.,
Plaintiff,
vs.
APPLE INC.,

JURY TRIAL DEMANDED
Defendant.

APPLE INC.,
Counterclaim Plaintiff,
vs.
MOTOROLA, INC., and
MOTOROLA MOBILITY, INC.,
Counterclaim Defendants.

SUPPLEMENTAL DECLARATION OF CHRISTINE SAUNDERS HASKETT IN
SUPPORT OF MOTOROLA MOBILITY, INC.’S MOTION FOR LEAVE TO FILE
DOCUMENT UNDER SEAL

I, Christine Saunders Haskett declare:
1.

I am a partner with the law firm of Covington Burling LLP, counsel to Defendant

and Counterclaimant Apple Inc. (“Apple”) in the above-captioned matter.
2.

I make this supplemental declaration in support of Motorola Mobility, Inc.’s

Motion for Leave to File Document Under Seal. I have personal knowledge of the facts set forth
in this declaration, and, if called as a witness, could and would testify thereto.
3.

I understand that on October 28, 2011, Motorola Mobility, Inc. (“Motorola”) filed

its Notice Concerning October 28, 2011 Infringement Contentions and Motion for Deadline For
Final Infringement Contentions and Incorporated Memorandum of Law In Support (“Notice and
Motion”), attached thereto as “Exhibit A.”
3.

I understand that Motorola’s Notice and Motion cite to certain Apple documents,

including:
745Apple11543563
745Apple0783686-786
745Apple4699474-569
745Apple4857865-99
745Apple10360097-98
745Apple5374978-81
745Apple10362501-32
745Apple8563808-27
745Apple5375102-04

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4.

These documents have been designated as containing “APPLE CONFIDENTIAL

BUSINESS INFORMATION” by Apple under the Stipulated Protective Order entered into by
the parties and approved by this Court on March 21, 2011, as confidential and subject to be filed
under seal. D.E. 69.
5.

Among other things, these documents include information relating to Apple’s

iTunes and App Store authentication system, Apple’s MobileMe service, and the antenna of
Apple’s iPhone 4. They include information relating to the architecture, interfaces, design, and
software of Apple products, and other competitively sensitive information that Apple holds in
confidence. It is my understanding that disclosure of this information could harm Apple by
providing its competitors with sensitive information about Apple’s business and products, which
competitors could use to gain an unfair advantage.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct to the best of my knowledge and belief.
Executed on November 7, 2011 at San Francisco, California.

/s/ Christine Saunders Haskett
Christine Saunders Haskett

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CERTIFICATE OF SERVICE

I hereby certify that on November 7, 2011, I filed the foregoing document with the Clerk
of the Court. I also certify that the foregoing document is being served this day on all counsel of
record identified on the attached Service List via email and CM/ECF.
/s/ Christopher R.J. Pace
Christopher R.J. Pace (Fla. Bar No. 0721166)

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SERVICE LIST
Case No. 1:10cv023580-Civ-UU
Edward M. Mullins
Fla. Bar No. 863920
[e-mail]
ASTIGARRAGA DAVIS MULLINS &GROSSMAN, P.A.
701 Brickell Avenue, 16th Floor
Miami, FL 33131
Telephone: [phone]
Facsimile: [phone]
Attorneys for Motorola Mobility, Inc.
Electronically served via CM/ECF and via email
Of Counsel:
Charles K. Verhoeven
David A. Perlson
Anthony Pastor
QUINN EMANUEL URQUHART &SULLIVAN, LLP
50 California Street, 22nd Floor
San Francisco, CA 93111
[phone]
Raymond N. Nimrod
Edward J. DeFranco
QUINN EMANUEL URQUHART &SULLIVAN, LLP
51 Madison Avenue, 22nd Floor
New York, NY 10010
[phone]
David A. Nelson
QUINN EMANUEL URQUHART &SULLIVAN, LLP
500 West Madison Street, Suite 2450
Chicago, IL 60661
[phone]
[e-mail]
Attorneys for Motorola Mobility, Inc.
Electronically served via email

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