TimesLines, Inc v. Facebook, Inc.

Filing 82

MOTION by Counter Claimant Facebook, Inc., Defendant Facebook, Inc. for leave to file a Document Under Seal (Hughes, Brendan)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
TIMELINES, INC.
Plaintiff,
v.
FACEBOOK, INC.
Defendant.

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Civil Action No.: 11 CV 6867
HONORABLE JOHN W. DARRAH

DEFENDANT FACEBOOK, INC.’S MOTION FOR LEAVE TO FILE UNDER SEAL AN
EXCERPT FROM THE RULE 30(b)(6) DEPOSITION OF FACEBOOK, INC. &
PLAINTIFF’S FINANCIAL DOCUMENT

Pursuant to Local Rule 26.2, Defendant Facebook, Inc. (“Facebook”) hereby moves this
Court for leave to file under seal an excerpt from the Rule 30(b)(6) deposition transcript of
Facebook (86:17-87:2) and a financial document (Bates Nos. T0000001-08) produced by
Plaintiff Timelines, Inc. Facebook has included both documents as exhibits in support of its
simultaneously-filed summary judgment motion.
Pursuant to the Protective Order entered in this case, proprietary or confidential
information, designated as “Confidential” or “Highly Confidential – Outside Counsel Only,”
may be filed under seal. See Dkt. No. 5 at ¶¶ 4, 5. Both the deposition excerpt and the financial
document contain sensitive information that should not be disclosed publicly.

The parties

designated both documents accordingly. Facebook respectfully requests that this Court grant
Facebook’s motion for leave to file under seal the two documents in support of its summary
judgment motion.

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Dated: January 31, 2013

Respectfully submitted,

COOLEY LLP
By:

/s/ Brendan J. Hughes
Peter J. Willsey (pro hac vice)
Brendan Hughes (pro hac vice)
1229 Pennsylvania Ave., NW, Suite 700
Washington, DC 20004
Tel: [phone]
Fax: [phone]
Email: [e-mail]
[e-mail]
Michael G. Rhodes (pro hac vice)
101 California Street, 5th Floor
San Francisco, CA 94111-5800
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Steven D. McCormick (#1824260)
KIRKLAND & ELLIS LLP
300 North LaSalle
Chicago, IL 60654-3406
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Counsel for Facebook, Inc.

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CERTIFICATE OF SERVICE
The undersigned, an attorney, hereby certifies that he served the foregoing
DEFENDANT FACEBOOK, INC.’S MOTION FOR LEAVE TO FILE UNDER SEAL AN
EXCERPT FROM THE RULE 30(b)(6) DEPOSITION OF FACEBOOK, INC. &
PLAINTIFF’S FINANCIAL DOCUMENT by means of the Court’s CM/ECF System, which
causes a true and correct copy of the same to be served electronically on all CM/ECF registered
counsel of record, on January 31, 2013.
Dated: January 31, 2013
/s/ Brendan J. Hughes
Brendan J. Hughes (pro hac vice)
COOLEY LLP
1229 Pennsylvania Ave., NW, Suite 700
Washington, DC 20004
Tel: [phone]
Fax: [phone]
Email: [e-mail]

1095712/HN

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