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

Filing 228

Unopposed MOTION to Seal Document by Exedea INC., HTC America, Inc., HTC Corporation. (Attachments: # 1 Text of Proposed Order)(Craft, Roger)

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

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§ Civil Action No. 6:10-CV-521
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§ JURY TRIAL REQUESTED
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DEFENDANTS HTC CORPORATION, HTC AMERICA, INC., AND EXEDEA, INC.’S
UNOPPOSED MOTION FOR LEAVE TO SEAL EXHIBIT
NOW COME, Defendants HTC Corporation, HTC America, Inc., and Exedea, Inc.
(collectively “HTC”) and hereby file this Unopposed Motion for Leave to Seal Exhibit A to WiLan Inc.’s Unopposed Motion to Compel Production of License Agreements from HTC
Corporation, HTC America, and Exedea Inc. (Dkt. No. 207).
On July 12, 2012, Plaintiff Wi-LAN Inc. filed an Unopposed Motion to Compel
Production of License Agreements from HTC Corporation, HTC America, and Exedea Inc. (Dkt.
No. 207). HTC believes that Exhibit A to Plaintiff’s Motion contains confidential business
information and thus requests that the Court seal Exhibit A. Wi-LAN Inc. is unopposed to this
request.
WHEREFORE, HTC respectfully requests that the Court enter the attached order sealing
Exhibit A to Wi-LAN Inc.’s Unopposed Motion to Compel Production of License Agreements
from HTC Corporation, HTC America, and Exedea Inc. (Dkt. No. 207).

Dated: September 13, 2012

Respectfully submitted,
By: /s/ Brian Craft
Brian Craft
State Bar No. 04972020
Eric H. Findlay
State Bar No. 00789886
Findlay Craft, LLP
6760 Old Jacksonville Hwy., Suite 101
Tyler, TX 75703
903/534-1100
Fax: [phone]
Email: [e-mail]
Stephen S. Korniczky
Daniel N. Yannuzzi
Martin Bader
Sheppard Mullin Richter & Hampton LLP
12275 El Camino Real, Suite 200
San Diego, California 92130
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Defendants
HTC CORPORATION, HTC AMERICA, INC. and
EXEDEA, INC.

CERTIFICATE OF SERVICE
The undersigned certifies that on September 13, 2012, 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(b)(1).

/s/ Brian Craft
Brian Craft

CERTIFICATE OF CONFERENCE
Counsel for Plaintiff and counsel for Defendants participated in a meet and confer via email and discussed the subject motion. Plaintiff is not opposed to this motion.

/s/ Brian Craft
Brian Craft