Connectu, Inc. v. Facebook, Inc. et al

Filing 175

MOTION to Seal or file under Seal: (I) Plaintiffs' Notice of Motion and Memorandum of Law to File Supplemental Authority in Opposition to Defendants' Motion for Summary Judgment; and (II) Renewed Rule 56(F) Motion by Connectu, Inc..(Tighe, Daniel)

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS CONNECTU, INC., CAMERON WINKLEVOSS, TYLER WINKLEVOSS, AND DIVYA NARENDRA, Plaintiffs, v. FACEBOOK, INC., MARK ZUCKERBERG, EDUARDO SAVERIN, DUSTIN MOSKOVITZ, ANDREW MCCOLLUM, AND THEFACEBOOK LLC, Defendants. District Judge Douglas P. Woodlock Magistrate Judge Robert B. Collings

1:07-CV-10593 (DPW) Related Action: Civil Action No. 04-CV11923 (DPW)

MOTION FOR LEAVE TO FILE UNDER SEAL: (I) PLAINTIFFS' NOTICE OF, MOTION AND MEMORANDUM OF LAW TO FILE SUPPLEMENTAL AUTHORITY IN OPPOSITION TO DEFENDANTS' MOTION FOR SUMMARY JUDGMENT; AND (II) RENEWED RULE 56(F) MOTION Pursuant to Local Rule 7.2(d), plaintiffs ConnectU, Inc., Cameron Winklevoss, Tyler Winklevoss and Divya Narendra ("Plaintiffs") hereby move for leave to file under seal their Notice of and Motion to File Supplemental authority in opposition to Defendants' Motion for Summary Judgment and Renewed Rule 56(F) Motion, and the accompanying Declaration of Adam B. Wolfson ("Wolfson Decl."). As grounds for this motion, the Plaintiffs state that the documents which they seek to file include information that the defendants' have designated as "confidential" under the Second Stipulated Protective Order in place in this case.

CERTIFICATION PURSUANT TO LOCAL RULE 7.1(A)(2) Counsel for Plaintiffs certifies that pursuant to Local Rule 7.1(a)(2) they met and conferred with counsel for Defendants regarding this motion via telephone conference on February 4, 2008, and via email conference on February 8, 2008.

DATED: February 8, 2008

/s/ Daniel P. Tighe__________ Daniel P. Tighe (BBO # 556583) Scott McConchie (BBO # 634127) GRIESINGER, TIGHE, & MAFFEI, L.L.P. 176 Federal Street Boston, MA 02110 T: [phone] F: [phone] Peter Calamari (pro hac vice) Richard I. Werder, Jr. (pro hac vice) David E. Azar (pro hac vice) Adam B. Wolfson (pro hac vice) QUINN EMANUEL URQUHART OLIVER & HEDGES, LLP 51 Madison Avenue New York, New York 10010-1601 T: [phone] F: [phone] Attorneys for Plaintiffs ConnectU, Inc., Cameron Winklevoss, Tyler Winklevoss and Divya Narendra

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CERTIFICATE OF SERVICE I hereby certify that this document filed through the ECF system will be sent electronically to the registered participants as identified on the Notice of Electronic Filing (NEF) and paper copies will be sent to those indicated as non registered participants on February 11, 2008. /s/ Daniel P. Tighe Daniel P. Tighe

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