Lodsys, LLC v. Combay, Inc. et al

Filing 5

MOTION to Seal Document Exhibit A to Sanders Declaration in Support of Apple Inc.'s Motion to Intervene by Apple, Inc.. (Attachments: # 1 Text of Proposed Order)(Findlay, Eric)

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

LODSYS, LLC,

CIVIL ACTION NO. 2:11-cv-272-TJW
Plaintiff,

v.
COMBAY, INC.;
ICONFACTORY, INC.;
ILLUSION LABS AB;
MICHAEL G. KARR D/B/A
SHOVELMATE;
QUICKOFFICE, INC.;
RICHARD SHINDERMAN;
WULVEN GAME STUDIOS,
Defendants.

APPLE INC.’S MOTION FOR LEAVE TO FILE UNDER SEAL
EXHIBIT A TO THE DECLARATION OF JONATHAN C. SANDERS IN SUPPORT OF
APPLE INC.’S MOTION TO INTERVENE
Apple Inc. (“Apple”) submits this motion for leave to file under seal (the
“Motion”) Exhibit A to the Declaration of Jonathan C. Sanders in Support of Apple’s Motion to
Intervene (“Exhibit A”). Apple has met and conferred with Plaintiff Lodsys, LLC (“Lodsys”),
and, as of the filing of this document, Lodsys has not agreed to the Motion.
Exhibit A contains confidential information regarding an Apple license
agreement. Because a protective order has not yet been entered in this case, Apple respectfully
moves for leave to file Exhibit A under seal. Apple respectfully requests that the Court enter the
attached order allowing Apple to file Exhibit A under seal.

Dated: June 9, 2011

Respectfully submitted,

By _/s/ Eric H. Findlay_______________
Eric H. Findlay
State Bar No. 00789886
FINDLAY CRAFT, LLP
6760 Old Jacksonville Hwy
Suite 101
Tyler, TX 75703
903/534-1100
903/534-1137 Facsimile
[e-mail]
George M. Newcombe (pro hac pending)
Jonathan C. Sanders (pro hac pending)
SIMPSON THACHER & BARTLETT, LLP
2550 Hanover Street
Palo Alto, CA 94304
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
Counsel for Intervenor Defendant and
Counterclaim Plaintiff Apple Inc.

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CERTIFICATE OF SERVICE
I hereby certify that all counsel of record who have consented to electronic
service are being served with a copy of this document via the Court’s CM/ECF system per Local
Rule CV-5(a)(3) on this the 9th of June, 2011.
/s/ Eric H. Findlay
Eric H. Findlay
CERTIFICATE OF CONFERENCE
This is to certify that, on June 9, 2011, Jonathan C. Sanders, counsel for Apple
Inc., and Michael Goldfarb, counsel for Plaintiff, conducted the personal conference required by
Civil Rule 7(h), and that, as of the filing of this document, Plaintiff has not agreed to this Motion
for Leave to File Under Seal.
/s/ Eric H. Findlay
Eric H. Findlay

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