Skyhook Wireless, Inc. v. GOOGLE, INC.

Filing 25

Assented to MOTION to Seal by GOOGLE, INC..(Manning, Susan) (Main Document 25 replaced on 4/25/2011) (Anderson, Jennifer). (Additional attachment(s) added on 4/25/2011: # 1 Text of Proposed Order) (Anderson, Jennifer).

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS

SKYHOOK WIRELESS, INC.,
Plaintiff,
CIVIL ACTION
NO. 1:10-cv-11571-RWZ

v.
GOOGLE INC.,
Defendant.

GOOGLE INC.,
Counterclaim-Plaintiff,
v.
SKYHOOK WIRELESS, INC.,

GOOGLE INC.'S
ASSENTED TO MOTION
TO SEAL

Counterclaim-Defendant.

GOOGLE INC.’S ASSENTED TO MOTION TO SEAL
Pursuant to Local Rule 7.2, Defendant Google Inc. (“Google”) respectfully moves for an
Order permitting it to file under seal Google’s Preliminary Non-Infringement Contentions. This
document contains Google’s confidential business information including operation of its
products. Due to the confidential and proprietary nature of the document Google requests that
the Preliminary Non-Infringement Contentions be impounded until thirty days following the
entry of final judgment, then returned to counsel for Google.
Defendants conferred with counsel for plaintiff, Sam Lu, Esq., by e-mail, who stated that
the plaintiff does not oppose this motion.
Attached for the Court’s consideration is a proposed form of Order.
WHEREFORE, Defendants respectfully request that the Court allow its Motion to File
Under Seal.

A/74156089.1

Respectfully Submitted,
GOOGLE, INC.
By its attorneys,
/s/ Susan Baker Manning

.

Jonathan M. Albano, BBO # 013850
[e-mail]
BINGHAM McCUTCHEN LLP
One Federal Street
Boston, MA 02110-1726, U.S.A.
617.951.8000
William F. Abrams
[e-mail]
BINGHAM McCUTCHEN LLP
1900 University Avenue
East Palo Alto, CA 94303-2223
650.849.4400
Robert C. Bertin
[e-mail]
Susan Baker Manning
[e-mail]
BINGHAM McCUTCHEN LLP
2020 K Street, NW
Washington, DC 20006-1806
202.373.6000
Dated: April 15, 2011

A/74156089.1

2

LOCAL RULE 7.1 CERTIFICATION
I hereby certify that counsel to the plaintiff and counsel to the defendant conferred with
respect to this motion and that counsel to the plaintiff stated that the plaintiff does not oppose
this motion.

/s/ Susan Baker Manning
Susan Baker Manning

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, by federal express,
on April 15, 2011.

/s/ Susan Baker Manning
Susan Baker Manning

A/74156089.1

3

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS

SKYHOOK WIRELESS, INC.,
Plaintiff,
CIVIL ACTION
NO. 1:10-cv-11571-RWZ

v.
GOOGLE INC.,
Defendant.

GOOGLE INC.,
Counterclaim-Plaintiff,
v.
SKYHOOK WIRELESS, INC.,
Counterclaim-Defendant.

ORDER
On April 15, 2011, Defendant Google Inc filed an Assented To Motion To Seal Google’s
Preliminary Non-Infringement Contentions (the “Motion”).
The Court, having considered the Motion, finds good cause for allowing Defendant to file
the Google’s Preliminary Non-Infringement Contentions under seal.
It is so Ordered.
This ____________ day of _________, 2011
___________________________________
Honorable Rya W. Zobel
United States District Judge

A/74156089.1