Rockstar Consortium US LP et al v. Google Inc

Filing 85

Unopposed MOTION to Seal Joint Motion for Entry of E-Discovery Order by Google Inc. (Perlson, David) (Additional attachment(s) added on 6/18/2014: # 1 Text of Proposed Order) (ch, ).

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
MARSHALL DIVISION
ROCKSTAR CONSORTIUM US LP
AND NETSTAR TECHNOLOGIES
LLC,
Plaintiffs,

Civil Action No. 2:13-cv-893

v.
GOOGLE INC.,

JURY TRIAL DEMANDED

Defendant.

DEFENDANT GOOGLE INC.’S UNOPPOSED MOTION FOR LEAVE TO FILE
UNDER SEAL THE PARTIES’ JOINT MOTION FOR ENTRY OF E-DISCOVERY
ORDER

COME NOW Defendant Google Inc. (“Google”) files this Unopposed Motion for Leave
to File Under Seal the Parties’ Joint Motion for Entry of E-Discovery Order. The parties’ joint
motion is due to be filed on June 17, 2014. Google plans to cite in its portions of the filing
certain materials that are confidential. A protective order has not yet been entered in the present
case. Thus, Google respectfully seeks this Court’s permission pursuant to Local Rule CV5(a)(7) for the parties to file their Joint Motion for Entry of E-Discovery Order under seal.
Google has conferred with Plaintiffs, and this Motion is unopposed.
A Proposed Order is attached.

01980.00010/6068664.1 3141176v1/013149

/s/ David A. Perlson
James Mark Mann
[e-mail]
Andy Tindel
[e-mail]
Gregory Blake Thompson
[e-mail]
Mann Tindel & Thompson
300 W. Main
Henderson, TX 75652
903-657-8540
Charles K. Verhoeven
[e-mail]
David A. Perlson
[e-mail]
Sean Pak
[e-mail]
Quinn Emanuel Urquhart & Sullivan
50 California Street, 22nd Floor
San Francisco, CA 94111
415-875-6600
Robert Wilson
[e-mail]
Quinn Emanuel Urquhart & Sullivan
51 Madison Ave., 22nd Floor
New York, NY 10010
212-849-7145
ATTORNEYS FOR DEFENDANT
GOOGLE INC.

01980.00010/6068664.1

3141176v1/013149

2

CERTIFICATE OF CONFERENCE
I hereby certify that counsel met and conferred on June 17, 2014, in compliance with the
meet and confer requirement in Local Rule CV-7(h) and this Court’s Orders, and that opposing
counsel is not opposed to this motion.

/s/ David A. Perlson
David A. Perlson
[e-mail]
Quinn Emanuel Urquhart & Sullivan
50 California Street, 22nd Floor
San Francisco, CA 94111
415-875-6600

CERTIFICATE OF SERVICE
I hereby certify that all counsel of record are being served via electronic mail with a copy
of this document on June 17, 2014.

/s/ Andrea Pallios Roberts
Andrea Pallios Roberts
[e-mail]
QUINN EMANUEL URQUHART &
SULLIVAN, LLP
555 Twin Dolphin Dr., 5th Floor
Redwood Shores, CA 94065
Telephone: [phone]
Facsimile: [phone]

01980.00010/6068664.1

3141176v1/013149

3

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
MARSHALL DIVISION
ROCKSTAR CONSORTIUM US LP
AND NETSTAR TECHNOLOGIES
LLC,
Civil Action No. 2:13-cv-893

Plaintiffs,
v.

JURY TRIAL DEMANDED

GOOGLE INC.,
Defendant.

ORDER GRANTING DEFENDANT GOOGLE INC.’S UNOPPOSED MOTION FOR
LEAVE TO FILE UNDER SEAL THE PARTIES’ JOINT MOTION FOR ENTRY OF EDISCOVERY ORDER

Before this Court is Defendant Google Inc.’s (“Google’s”) Unopposed Motion for Leave
to File Under Seal the Parties’ Joint Motion for Entry of E-Discovery Order. Having considered
Google’s Motion and the relief sought therein, this Court is of the opinion that it should be
GRANTED.
The parties may file their Joint Motion for Entry of E-Discovery Order under seal. IT IS
SO ORDERED.

01980.00010/6068664.1

3141176v1/013149

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