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

Filing 173

Unopposed MOTION to Seal Document 171 SEALED MOTION PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT by WI-LAN Inc.. (Attachments: # 1 Text of Proposed Order)(Fedock, John)

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 UNOPPOSED MOTION FOR LEAVE
TO FILE MOTION FOR PARTIAL SUMMARY JUDGMENT UNDER SEAL
In accordance with Local Rule CV-5(a)(7) and the Court’s Standing Orders, Plaintiff WiLAN Inc. (“Wi-LAN”) seeks an order permitting Wi-LAN to file under seal its Motion for
Partial Summary Judgment filed under Dkt. 171, regarding Defendants Telefonaktiebolaget LM
Ericsson’s (“LME”), Ericsson Inc.’s (“EUS”), Sony Mobile Communications AB’s, (“SAB”),
and Sony Mobile Communications (USA) Inc.’s (“SUS”) (collectively, the “Ericsson
Defendants”) respective affirmative defenses of covenant not to sue and counterclaims for breach
of contract.
Because the Motion for Partial Summary Judgment contains highly confidential
information belonging to Wi-LAN and the Ericsson Defendants, Wi-LAN requests leave to file
this motion under seal.

Counsel for Wi-LAN has conferred with counsel for Ericsson

Defendants, and they do not oppose this motion. Public disclosure of this information would be
harmful to the parties involved.

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Dated: March 30, 2012

Respectfully submitted,
By:

/s/ John A. Fedock
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
Michael A. Valek
Texas State Bar No. 24044028
John A. Fedock
Texas State Bar No. 24059737
Jeffrey T. Han
Texas State Bar No. 24069870
Syed K. Fareed
Texas State Bar No. 24065216
Seth A. Lindner
Texas State Bar No. 24078862
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]
Charles P. Ebertin
VINSON & ELKINS LLP
525 University Avenue, Suite 410
Palo Alto, CA 94301-1918
Tel: [phone]

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[e-mail]
Attorneys for Plaintiff, Wi-LAN Inc.

CERTIFICATE OF CONFERENCE
Pursuant to Local Rule CV-7(h), movant has contacted opposing counsel and no party
opposes the relief requested herein.
/s/ John A. Fedock
John A. Fedock

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 30th day of March 2012.

/s/ John A. Fedock
John A. Fedock
US 1331607v.1

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