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

Filing 163

NOTICE by Google Inc., IAC Search & Media, Inc. re 106 Declaration,, 161 Order to Show Cause,,, 105 Memorandum in Support of Filing of Certain Unredacted and Further Redacted Materials in Response to Order to Show Cause (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit K, # 4 Exhibit L, # 5 Exhibit M, # 6 Exhibit N)(Noona, Stephen) Modified on 5/18/2012 to indicate that Exhibit 2 was previously removed on 5/11/12 by clerk due to personal identifiers contained therein) (ecav, ).

Exhibit 1

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Norfolk Division
I/P ENGINE, INC.,
Plaintiff,
v.

Civil Action No. 2:11-cv-512

AOL INC., et al.,
Defendants.

[PROPOSED] ORDER TO MAINTAIN PORTIONS OF DOCUMENTS UNDER SEAL
On this day came Defendants Google, Inc. ("Google") and IAC Search & Media, Inc. ("IAC
Search"), by counsel, upon the Notice of Filing of Certain Unredacted and Further Redacted
Materials in Response to Order to Show Cause (“Response to Show Cause”), and, upon
consideration of the arguments set forth in the Notice, and for good cause shown, it is
ORDERED that the unredacted versions of Exhibits K and L to the Declaration of Emily C.
O’Brien (Dkt. No. 106) in Support of Defendants’ Brief in Support of its Motion to Compel Plaintiff
to Supplement its Infringement Contentions (“Brief in Support of Motion to Compel”) and the
unredacted version of the Brief in Support of the Motion to Compel attached to the Defendants’
Response to Show Cause shall be filed; and it is further
ORDERED that portions of the following documents be maintained under seal in connection
with the pending motions they support:
ECF No. 106-13 – Exhibit M to the Declaration of Emily O'Brien in Support of Defendant
Google Inc.'s and IAC Search & Media, Inc.'s Motion to Compel Plaintiff to Supplement its
Infringement Contentions
ECF No. 106-14 – Exhibit N to the Declaration of Emily O'Brien in Support of Defendant
Google Inc.'s and IAC Search & Media, Inc.'s Motion to Compel Plaintiff to Supplement its
Infringement Contentions

The further redacted versions of Exhibit M and Exhibit N attached to Google’s and IAC
Search’s Response to Show Cause shall be filed. The defendants have redacted these materials to
seal only a narrow portion of information that should be protected. The Court finds that appropriate
notice has been given and that these further redacted versions of Exhibits M and N contain sensitive
information that: (1) has not been made public; (2) has economic value; and (3) if disclosed, could
cause competitive harm. The Court further finds that there are no less drastic alternatives to sealing
these further redacted materials in accordance with Ashcraft v. Conoco, Inc., 218 F.3d 282 (4th Cir.
2000).
Dated: May ____, 2012

Entered:

_____/_____/_____

______________________________
United States District Court
Eastern District of Virginia
11697128_1.DOC