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

Filing 184

Unopposed MOTION to Seal Document Plaintiff's Opposition to Defendant CA, Inc.'s Motion to Strike Exhibit B to Plaintiffs' Preliminary Patent Infringement Contentions and Accompanying Declarations by Uniloc Singapore Private Limited, Uniloc USA, Inc.. (Attachments: # 1 Text of Proposed Order)(Nelson, Edward)

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF TEXAS
TYLER DIVISION
UNILOC USA, INC., et al.
Plaintiffs,

Civil Action No. 6:10-cv-00472

v.
NATIONAL INSTRUMENTS CORP., et al.

JURY TRIAL DEMANDED

Defendants.

UNOPPOSED MOTION FOR LEAVE TO FILE UNDER SEAL PLAINTIFFS’
OPPOSITION TO DEFENDANT CA, INC.’S MOTION TO STRIKE EXHIBIT B TO
PLAINTIFFS’ PRELIMINARY PATENT INFRINGEMENT CONTENTIONS AND
ACCOMPANYING DECLARATIONS
Plaintiffs Uniloc USA, Inc. and Uniloc (Singapore) Private Limited (collectively,
“Uniloc”) file this Motion for Leave to File Under Seal. Defendant CA, Inc. filed its Motion to
Strike and accompanying declarations under seal, explaining that the Motion, memorandum, and
declarations contain information CA considers to be highly confidential. Because Uniloc’s
Opposition and accompanying declarations are directly responsive to the documents CA filed
under seal, Uniloc’s Opposition and accompanying declarations also contain highly confidential
information and should also be filed under seal. CA is not opposed to the request.
Therefore, Uniloc requests that it be granted leave to file its Opposition and
accompanying declarations under seal. A proposed order is attached.

Dated: July 22, 2011.

Respectfully Submitted,
/s/ Edward R. Nelson, III
Edward R. Nelson, III
Texas State Bar No. 00797142
Barry J. Bumgardner

Texas State Bar No. 24041918
Steven W. Hartsell
Texas State Bar No. 24040199
S. Brannon Latimer
Texas State Bar No. 24060137
Jaime K. Olin
Texas State Bar No. 24070363
NELSON BUMGARDNER CASTO, P.C.
3131 West 7th Street, Suite 300
Fort Worth, Texas 76107
[phone]
[phone] (fax)
[e-mail]
[e-mail]
[e-mail]
T. John Ward, Jr.
Texas State Bar No. 00794818
J. Wesley Hill
Texas State Bar No. 24032294
WARD & SMITH LAW FIRM
111 West Tyler St.
Longview, Texas 75601
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]

Certificate of Conference
The undersigned confirms that counsel for Plaintiffs has conferred with counsel for CA,
Inc., Joshua Krumholz, and CA does not oppose Uniloc filing under seal.
/s/ Jaime Olin
Jaime Olin
NELSON BUMGARDNER CASTO, P.C.

2

Certificate of Service
The undersigned certifies that on July 22, 2011, the foregoing document was filed
electronically in compliance with Local Rule CV-5(a). As such, this motion was served on all
counsel who have consented to electronic service. Local Rule CV-5(a)(3)(A).
/s/ Edward R. Nelson, III
Edward R. Nelson, III

3