Vertical Computer Systems, Inc. v. Interwoven, Inc. et al

Filing 85

Unopposed MOTION to Seal Document 84 SEALED MOTION to Sever and Transfer Claims by LG Electronics Inc, LG Electronics Mobilecomm USA Inc. (Attachments: # 1 Text of Proposed Order)(Healey, David)

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
MARSHALL DIVISION
VERTICAL COMPUTER SYSTEMS, INC.
Plaintiff,
v.
LG ELECTRONICS MOBILECOMM U.S.A.,
INC., LG ELECTRONICS, INC., SAMSUNG
ELECTRONICS CO., LTD., SAMSUNG
ELECTRONICS AMERICA, INC.

CIVIL ACTION NO. 2:10-CV-490

Defendants.
LG ELECTRONICS MOBILECOMM U.S.A., INC. AND LG ELECTRONICS INC.’S
MOTION TO SEAL THEIR MOTION TO SEVER AND TRANSFER CLAIMS
Defendants LG ELECTRONICS MOBILECOMM U.S.A., INC. AND LG
ELECTRONICS INC. (“LGE”) submit this Unopposed Motion for Leave to File Under Seal its
Motion to Sever and Transfer Claims to the United States District Court for the District of New
Jersey or in the Alternative to the Northern District of California.
LGE’s Motion to Sever and Transfer Claims to the United States District Court for the
District of New Jersey or in the Alternative to the Northern District of California contains
confidential information, and as a protective order has not yet been entered, LGE respectfully
moves for leave to file their Motion to Sever and Transfer Claims under seal.
Plaintiff Vertical Computer Systems, Inc. and Defendants Samsung Electronics Co., Ltd.
and Samsung Electronics America, Inc. are not opposed to the relief sought by this motion, and
LGE therefore requests that the Court enter an order allowing LGE to file its Motion to Sever
and Transfer Claims to the United States District Court for the District of New Jersey or in the
Alternative to the Northern District of California under seal.
Page 1

Dated: July 31, 2012

Respectfully submitted,
FISH & RICHARDSON P.C.

By: /s/ David J. Healey
David J. Healey
State Bar No. 09327980
Fish & Richardson P.C.
1221 McKinney, Suite 2800
Houston, TX 77010
713-654-5300 -- Telephone
713-652-0109 -- Facsimile
[e-mail]
OF COUNSEL:
Kevin Su
MA Bar No. 663726
Fish & Richardson P.C.
One Marina Park Drive
Boston, MA 02210-1878
617-542-5070 -- Telephone
617-542-8906 -- Facsimile
[e-mail]
Michael J. McKeon
Fish & Richardson P.C.
1425 K Street, NW, 11th Floor
Washington, DC 20005
202-783-5070 -- Telephone
202-783-2331 -- Facsimile
[e-mail]
Counsel for Defendants
LG ELECTRONICS MOBILECOMM
U.S.A., INC. AND LG ELECTRONICS,
INC.

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CERTIFICATE OF CONFERENCE
The undersigned hereby certify that counsel has complied with the meet and confer
requirement in Local Rule CV-7(h). Counsel for Plaintiff and Samsung have indicated that this
motion is unopposed.
/s/ David J. Healey
David J. Healey
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the above and foregoing
document has been served on July 31, 2012 upon all counsel of record who are deemed to have
consented to electronic service via the Court’s CM/ECF system per Local Rule CV-5(a)(3). Any
other counsel of record will be served by first class mail.

/s/ David J. Healey
David J. Healey

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