Skyhook Wireless, Inc. v. GOOGLE, INC.

Filing 31

MOTION for Protective Order by Skyhook Wireless, Inc..(Maffei, Thomas)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS
SKYHOOK WIRELESS, INC.,
Plaintiff and
Counterclaim-Defendant,
v.
GOOGLE INC.,
Defendant and
Counterclaimant.

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Case No. 1:10-cv-11571-RWZ
PLAINTIFF SKYHOOK WIRELESS,
INC.'S MOTION FOR ENTRY OF
PROTECTIVE ORDER

Pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, plaintiff Skyhook
Wireless, Inc. ("Skyhook") respectfully moves this Court to enter Skyhook’s First Proposed
Protective Order excluding reexamination and non-broadening reissue proceedings from the
prosecution bar. (Ex. 1.1) In the alternative, Skyhook respectfully moves this Court to enter
Skyhook's Second Proposed Protective Order excluding from the prosecution bar only
reexamination proceedings challenging a patent initiated by or at the behest of one of the parties
to this action. (Ex. 2.)
In support of this motion, Skyhook relies on the Memorandum in Support of Skyhook's
Motion for Entry of Protective Order, the Affidavit of Lina F. Somait and exhibits thereto, the
complete records and files of this action, and such additional argument and evidence as may be
presented to the Court.
WHEREFORE, Skyhook respectfully requests that the Court grant Skyhook's motion (1)
to enter Skyhook’s First Proposed Protective Order excluding reexamination and non-broadening
1

All citations in the form of "Ex. __" are to the exhibits to the Somait Affidavit in
support of Skyhook's Motion for Entry of Protective Order.

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reissue proceedings from the prosecution bar; or (2) in the alternative, to enter Skyhook’s Second
Proposed Protective Order excluding from the prosecution bar only reexamination proceedings
challenging a patent initiated by or at the behest of one of the parties to this action.

Respectfully submitted,
Skyhook Wireless, Inc.
By their attorneys
/s/ Thomas F. Maffei________________
Thomas F. Maffei (BBO 313220)
Douglas R. Tillberg (BBO 661573)
GRIESINGER, TIGHE & MAFFEI, LLP
176 Federal Street
Boston, Massachusetts 02110
[phone]
[e-mail]
[e-mail]
Of counsel:
Morgan Chu (pro hac vice)
John C. Hueston (pro hac vice)
Samuel K. Lu (pro hac vice)
Glenn K. Vanzura (pro hac vice)
Lina F. Somait (pro hac vice)
Linda C. Klein (pro hac vice)
IRELL & MANELLA LLP
1800 Avenue of the Stars, Suite 900
Los Angeles, California 90067-4276
[phone]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Dated: May 25, 2011

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Certificate of Compliance With Local Rule 37.1
The parties conferred in good faith in an attempt to resolve this dispute, as evidenced by the
exhibits attached to Ms. Somait's affidavit. The parties have not, however, been able to resolve
this dispute.

/s/ Thomas F. Maffei
Thomas F. Maffei
Certificate of Service
I, Thomas F. Maffei, 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)
on May 25, 2011.

/s/ Thomas F. Maffei
Thomas F. Maffei

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