Public Engines v. Reportsee

Filing 43

Joint MOTION to Unseal Document 40 Sealed Document filed by Public Engines filed by Plaintiff Public Engines. (Attachments: # 1 Text of Proposed Order Granting Joint Motion to LIft Seal of Plaintiff's "Reply Memorandum in Support of Plaitniff's Motion for Preliminary Injunction") Motions referred to Samuel Alba.(Haws, J.)

Alan L. Sullivan (3152) Todd M. Shaughnessy (6651) J. Elizabeth Haws (11667) Snell & Wilmer L.L.P. 15 West South Temple, Suite 1200 Beneficial Tower Salt Lake City, Utah 84101-1004 Telephone: [phone] Facsimile: [phone] Mark Lambert (Cal. Bar No. 197410) Mark Weinstein (Cal Bar No. 193043) Cooley Godward Kronish, LLP Five Palo Alto Square Palo Alto, California 94306-2109 Telephone: [phone] Attorneys for Plaintiff IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF UTAH, CENTRAL DIVISION PUBLIC ENGINES, INC., a Delaware Corporation, Plaintiff, vs. REPORTSEE, INC., a Delaware Corporation, Defendant.

JOINT MOTION TO LIFT SEAL OF PLAINTIFF'S "REPLY MEMORANDUM IN SUPPORT OF PLAINTIFF'S MOTION FOR PRELIMINARY INJUNCTION" Case No. 2:10-cv-317 Honorable Tena Campbell

Pursuant to DUCivR 5-2(e), Plaintiff Public Engines, Inc. ("Public Engines") and Defendant ReportSee, Inc. ("ReportSee") hereby jointly move the Court to lift the seal on Plaintiff's Reply Memorandum in Support of Plaintiff's Motion for Preliminary Injunction, Dkt.

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No. 40, (hereinafter "Reply Memorandum"). The Reply Memorandum was filed on May 25, 2010, under seal pursuant to this Court's May 4, 2010 Protective Order. Plaintiff initially filed the Reply Memorandum under seal because it summarized and referenced excerpts from a confidential deposition of ReportSee's CEO. After reviewing the Reply Memorandum, ReportSee has agreed that the Reply Memorandum can be re-designated non-confidential and filed publically. Accordingly, the parties jointly move this Court to lift the seal on the Reply Memorandum so that it can be publically accessed. A proposed form of Order granting this motion is attached hereto. Dated this 1st day of June, 2010. Snell & Wilmer L.L.P.

/s/ J. Elizabeth Haws Alan L. Sullivan Todd M. Shaughnessy J. Elizabeth Haws Attorneys for Plaintiff Bowie & Jensen, LLC

/s/ Josh A. Glikin (signed with permission) Joshua A. Glikin Attorney for Defendant

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