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

Filing 192

Assented to MOTION to Seal Document by Connectu, Inc.. (Attachments: #1 Text of Proposed Order)(Hornick, John)

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

Doc. 192

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS CONNECTU, INC., ) ) Plaintiff, ) ) v. ) ) FACEBOOK, INC., MARK ZUCKERBERG, ) EDUARDO SAVERIN, DUSTIN ) MOSKOVITZ, ANDREW MCCOLLUM, ) CHRISTOPHER HUGHES, AND ) THEFACEBOOK LLC, ) ) Defendants. )

CIVIL ACTION NO. 1:07-cv-10593 (DPW) Related Action 1:04-cv-11923 (DPW)

ASSENTED-TO MOTION TO SEAL DOCUMENT Pursuant to the Stipulated Protective Order entered between the parties in the previous related case, ConnectU v. Zuckerberg et al., Case No. 1:04-cv-11923-DPW, Plaintiff ConnectU, Inc. ("ConnectU") hereby moves to file under seal the following documents: · ConnectU's Emergency Motion For Expedited Hearing And In Camera Examination Of Documents And Of The Expert Parmet, In Regard To September 13, 2007 Order; · Declaration Of Meredith H. Schoenfeld In Support Of ConnectU's Emergency Motion For Expedited Hearing And In Camera Examination Of Documents And Of The Expert Parmet, In Regard To September 13, 2007 Order And Attached Exhibits 1-10; · Declaration Of John F. Hornick In Support Of ConnectU's Emergency Motion For Expedited Hearing And In Camera Examination Of Documents And Of The Expert Parmet, In Regard To September 13, 2007 Order.

Dockets.Justia.com

The documents and exhibits identified above discuss sensitive information that Facebook, Inc. would consider confidential, including documents that were filed confidentially in The Facebook, Inc. and v. ConnectU, Inc., Case No. 5:07-cv-01389 (JW), currently pending in the U.S. District Court for the Northern District of California. The parties have agreed to keep this information confidential, consistent with the provisions of the Stipulated Protective Order and this Court's September 13, 2007 Order for Discovery of Computer Memory Devices (the "Protocol," Dkt. 103). Thus, this motion is necessary to comply with those Orders. CERTIFICATION PURSUANT TO LOCAL RULE 7.1 Counsel for ConnectU certifies that pursuant to Local Rule 7.1, the parties have conferred regarding motions to seal, and counsel for Facebook Defendants consent to such motions.

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Respectfully submitted, DATED: May 20, 2008 /s/ John F. Hornick _____________ John F. Hornick (pro hac vice) Margaret A. Esquenet (pro hac vice) Meredith H. Schoenfeld (pro hac vice) FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER, L.L.P. 901 New York Avenue N.W. Washington, DC 20001 Telephone: [phone] Facsimile: [phone] Daniel P. Tighe (BBO# 556583) Scott McConchie (BBO# 634127) GREISINGER, TIGHE, and MAFFEI, L.L.P. 176 Federal St. Boston, MA 02110 Telephone: [phone] Facsimile: [phone] [e-mail] [e-mail] Attorneys for Plaintiff ConnectU

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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 May 20, 2008. /s/ John F. Hornick John F. Hornick

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