I/P Engine, Inc. v. AOL, Inc. et al

Filing 136

MOTION to Seal Portions of Reply Brief in Support of Motion to Compel and Exhibits AA and BB to the Declaration of Emily C. O'Brien in Support of the Reply by Google Inc., IAC Search & Media, Inc.. (Attachments: # 1 Exhibit 1)(Noona, Stephen)

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF VIRGINIA
NORFOLK DIVISION

I/P ENGINE, INC.
Plaintiff,
v.

Civil Action No. 2:11-cv-512

AOL, INC., et al.,
Defendants.

MOTION TO SEAL PORTIONS OF REPLY BRIEF IN SUPPORT OF MOTION TO
COMPEL AND EXHIBITS AA AND BB TO THE DECLARATION OF EMILY C.
O’BRIEN IN SUPPORT OF THE REPLY
Pursuant to Local Rule 5 and the Agreed Protective Order entered by the Court [Dkt. No.
85], Defendants Google, Inc. and IAC Search & Media, Inc. (collectively, “Defendants”),
respectfully move this Court for entry of the attached Order permitting Defendants to file under
seal Portions of Defendants’ Reply Brief in Support of Motion to Compel (“Portions of
Defendants’ Reply Brief”) and Exhibits AA and BB to the Declaration of Emily C. O’Brien in
Support of the Reply (“Certain Exhibits to O’Brien Declaration”). Grounds and authorities for
this Motion are set forth in Defendants’ Memorandum in Support of Motion to Seal.

In

compliance with Local Rule 5, Defendants attach a Proposed Order as Exhibit 1 and are filing
separately a Public Notice of Defendants’ Motion to Seal. Defendants request that the Court
retain sealed materials until forty-five (45) days after a final order is entered and request that,
unless the case is appealed, any sealed materials be returned to counsel for the filing parties.

DATED: April 19, 2012

/s/ Stephen E. Noona
Stephen E. Noona
Virginia State Bar No. 25367
KAUFMAN & CANOLES, P.C.
150 West Main Street, Suite 2100
Norfolk, VA 23510
Telephone: [phone]
Facsimile: [phone]
[e-mail]
David Bilsker
David A. Perlson
QUINN EMANUEL URQUHART &
SULLIVAN, LLP
50 California Street, 22nd Floor
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Attorneys for Google Inc., Target Corporation,
IAC Search & Media, Inc., and Gannet Co., Inc.

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CERTIFICATE OF SERVICE
I hereby certify that on April 19, 2012, I will electronically file the foregoing with the
Clerk of Court using the CM/ECF system, which will send a notification of such filing (NEF) to
the following:
Jeffrey K. Sherwood
Kenneth W. Brothers
DICKSTEIN SHAPIRO LLP
1825 Eye Street NW
Washington, DC 20006
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Donald C. Schultz
W. Ryan Snow
Steven Stancliff
CRENSHAW, WARE & MARTIN, P.L.C.
150 West Main Street, Suite 1500
Norfolk, VA 23510
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
Counsel for Plaintiff, I/P Engine, Inc.

Stephen E. Noona
Virginia State Bar No. 25367
KAUFMAN & CANOLES, P.C.
150 West Main Street, Suite 2100
Norfolk, VA 23510
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Counsel for Google Inc.,
Target Corporation,
IAC Search & Media, Inc., AOL Inc. and
Gannet Co., Inc.

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/s/ Stephen E. Noona
Stephen E. Noona
Virginia State Bar No. 25367
KAUFMAN & CANOLES, P.C.
150 West Main Street, Suite 2100
Norfolk, VA 23510
Telephone: [phone]
Facsimile: [phone]
[e-mail]

11659941_1.DOC

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