Northeastern University et al v. Google, Inc.,

Filing 212

AFFIDAVIT in Support re 210 Unopposed MOTION to Seal Document 127 Notice of Discovery Disclosure, 160 Notice (Other) : MOTION TO SEAL D.I. 127-2 AND 160-2 (CORRECTED) filed by Google, Inc.,. (Duarte, Enrique)

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
MARSHALL DIVISION

NORTHEASTERN UNIVERSITY and JARG
CORPORATION,
Plaintiffs,
v.

Civil Action No. 2:07-CV-486-CE
Jury Trial Demand

GOOGLE INC.,

Oral Argument Requested
Defendant.

CORRECTED DECLARATION OF ENRIQUE D. DUARTE IN SUPPORT OF
GOOGLE’S UNOPPOSED MOTION TO SEAL D.I. 127-2 AND 160-2

I, Enrique D. Duarte, hereby declare and state the following to be true:
1. I am an attorney licensed to practice law in the State of California and admitted pro
hac vice to the Eastern District of Texas for purposes of above-captioned matter. I am an
attorney with the law firm of Fish & Richardson P.C., counsel of record in this action for
Defendant Google Inc. (“Google”), and I am one of the attorneys responsible for Google’s
defense in this litigation. I have personal knowledge of the matters stated in this declaration and
would testify competently to them under oath if called to do so.
2. The document filed as D.I. 127-2 discloses information concerning Google’s source
code, which is highly confidential.
3. The document filed as D.I. 160-2 discloses information concerning Google’s source
code, which is highly confidential.
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CORRECTED DECL. OF ENRIQUE D. DUARTE IN SUPP. OF
UNOPPOSED MOTION TO SEAL DI 127-2 AND 160-2 - Page 1

I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct.
Executed this 27th day of June, 2011, at Redwood City, California.

__/s/ Enrique D. Duarte_____________
Enrique D. Duarte

CORRECTED DECL. OF ENRIQUE D. DUARTE IN SUPP. OF
UNOPPOSED MOTION TO SEAL DI 127-2 AND 160-2 - Page 2

CERTIFICATE OF SERVICE
The undersigned hereby certifies that on June 27, 2011, a true and correct copy of the
above and foregoing document was served on all counsel of record who are deemed to have
consented to electronic service via the Court’s CM/ECF system pursuant to Local Rule
CV-5(a)(3). Any other counsel of record not deemed to have consented to electronic service
were served by email and/or U.S. Mail on June 27, 2011.

/s/ Enrique D. Duarte
Enrique D. Duarte

CORRECTED DECL. OF ENRIQUE D. DUARTE IN SUPP. OF
UNOPPOSED MOTION TO SEAL DI 127-2 AND 160-2 - Page 3