Uniloc USA, Inc. et al v. NATIONAL INSTRUMENTS CORP. et al

Filing 161

Unopposed MOTION to Seal Document Motion to Strike and Supporting Documents by CA, Inc.. (Attachments: # 1 Text of Proposed Order)(Krumholz, Joshua) (Additional attachment(s) added on 6/29/2011: # 2 Text of Proposed Order) (kls, ).

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

UNILOC USA, INC. and
UNILOC SINGAPORE PRIVATE LIMITED,
Civ. Action No. 6:10-CV-472
Plaintiffs,
JURY TRIAL DEMANDED

v.
(1) NATIONAL INSTRUMENTS CORP.;
(2) PERVASIVE SOFTWARE, INC.;
(3) ADOBE SYSTEMS INC.;
(4) FILEMAKER, INC.;
(5) SAFENET, INC.;
(6) CA, INC.;
(7) PINNACLE SYSTEMS, INC.;
(8) SONIC SOLUTIONS;
(9) ONYX GRAPHICS, INC.
(10) SYMANTEC CORP.;
(11) ALADDIN KNOWLEDGE SYSTEMS,
INC. and
(12) ALADDIN KNOWLEDGE SYSTEMS
LTD.
Defendants.

UNOPPOSED MOTION FOR LEAVE TO FILE UNDER SEAL DEFENDANT CA,
INC.’S MOTION TO STRIKE EXHIBIT B TO PLAINTIFFS’ PRELIMINARY PATENT
INFRINGEMENT CONTENTIONS AND SUPPORTING MEMORANDUM OF LAW
AND ACCOMPANYING DECLARATIONS
COMES NOW, CA, Inc. (“CA”), and files this Motion for Leave to File Under Seal and,
in support thereof, would respectfully show the Court as follows:
CA’s Motion to Strike Exhibit B to Plaintiffs’ Preliminary Patent Infringement
Contentions and supporting Memorandum of Law (the “Motion to Strike”) and accompanying

declarations of Joshua C. Krumholz, Pricilla Sanginario and Anthony Piergallini contain
information that CA considers to be highly confidential. Accordingly, CA requests that it be
permitted to file its Motion and accompanying declarations under seal. Plaintiffs are not
opposed to the relief requested in this Motion.
For the reasons stated above, CA requests that it be granted leave to file its Motion to
Strike and accompanying declarations under seal, and for such other and further relief to which it
may be justly entitled. A proposed order is attached hereto as Exhibit A.

DATED: June 28, 2011

Respectfully submitted,

/s/ Joshua C. Krumholz
S. Calvin Capshaw
Texas State Bar No. 03783900
[e-mail]
Elizabeth L. DeRieux
Texas State Bar No. 05770585
[e-mail]
D. Jeffrey Rambin
Texas State Bar No. 0079147
[e-mail]
CAPSHAW DERIEUX, LLP
114 East Commerce Avenue
Telephone: [phone]
Facsimile: [phone]
Joshua C. Krumholz (pro hac vice)
[e-mail]
Benjamin M. Stern (pro hac vice)
[e-mail]
J. Mitchell Herbert, Jr. (pro hac vice)
[e-mail]
HOLLAND & KNIGHT LLP
10 St. James Avenue
Boston, Massachusetts 02116
Telephone: [phone]
Facsimile: [phone]
Counsel for CA, Inc.
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CERTIFICATE OF SERVICE
I hereby certify that the all counsel of record who are deemed to have consented to
electronic service are being served this 28th day of June, 2011, with a copy of this document via
the Court’s CM/ECF system per Local Rule CV-5(a)(3). Any other counsel of record will be
served by electronic mail, facsimile transmission and/or first class mail on this same date.

/s/ Benjamin M. Stern
Benjamin M. Stern

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