WI-LAN Inc. v. Alcatel-Lucent USA Inc. et al

Filing 136

***DOCUMENT FILED IN ERROR. PLEASE DISREGARD.***Opposed MOTION to Seal Document File Under Seal Letter Briefs by WI-LAN Inc.. (Attachments: # 1 Text of Proposed Order)(Weaver, David) Modified on 11/18/2011 (mjc, ).

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
TYLER DIVISION
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WI-LAN INC.,
Plaintiff,
v.
ALCATEL-LUCENT USA INC., et al.
Defendants.

Civil Action No. 6:10-cv-521-LED
JURY TRIAL DEMANDED

PLAINTIFF Wi-LAN INC.’S MOTION FOR LEAVE
TO FILE LETTER BRIEFS UNDER SEAL

In accordance with the Court’s Standing Orders, Plaintiff Wi-LAN Inc.(“Wi-LAN”)
seeks an order permitting Wi-LAN to file under seal responses to the letter briefs filed by
Defendants Telefonaktiebolaget LM Ericsson and Ericsson Inc. (collectively, “Ericsson”) and
Sony Ericsson Mobile Communications AB and Sony Ericsson Mobile Communications (USA)
Inc. (collectively, “Sony Ericsson”) (Dkt. Nos. 132 and 133).
Because the letter briefs contain highly confidential information concerning the parties,
Wi-LAN requests leave to file these responsive letter briefs under seal. Counsel for Wi-LAN has
conferred with counsel for Ericsson and Sony Ericsson, and they do not oppose this motion.
Public disclosure of this information would be harmful to the parties involved.

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Dated: November 18, 2011

Respectfully submitted,
By:

/s/ David B. Weaver
Johnny Ward
Texas State Bar No. 00794818
Wesley Hill
Texas State Bar No. 24032294
WARD & SMITH LAW FIRM
111 W. Tyler Street
Longview, TX 75601
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
David B. Weaver – LEAD ATTORNEY
Texas State Bar No. 00798576
Juliet M. Dirba
Texas State Bar No. 24051063
Jeffrey T. Han
Texas State Bar No. 24069870
John A. Fedock
Texas State Bar No. 24059737
Syed K. Fareed
Texas State Bar No. 24065216
Avelyn M. Ross
Texas State Bar No. 24027817
VINSON & ELKINS LLP
2801 Via Fortuna, Suite 100
Austin, TX 78746
Tel: [phone]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Charles P. Ebertin
VINSON & ELKINS LLP
525 University Avenue, Suite 410
Palo Alto, CA 94301-1918
Tel: [phone]
[e-mail]
Attorneys for Plaintiff, Wi-LAN Inc.

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CERTIFICATE OF CONFERENCE
I hereby certify that I conferred with counsel for Ericsson and Sony Ericsson regarding
the merits of this motion, and counsel informed me that they do not oppose the motion.

/s/ David B. Weaver
David B. Weaver

CERTIFICATE OF SERVICE
The undersigned certifies that the foregoing document was filed electronically in
compliance with Local Rule CV-5(a). As such, this document was served on all counsel who are
deemed to have consented to electronic service. Local Rule CV-5(a)(3)(A). All other counsel
of record not deemed to have consented to electronic service were served with a true and correct
copy of the foregoing by email and/or fax, on this the 18th day of November 2011.

/s/ David B. Weaver
David B. Weaver

US 1156430v.1

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