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

Filing 92

MOTION to Seal Portions of Google's Reply in Support of its Motion to Compel Plaintiff to Provide Conception, Reduction-to-Practice, and Priority Date Information, and Exhibits L, M, N and P to the Declaration of Margaret Kammerud in Support Thereof by Google 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 GOOGLE’S REPLY IN SUPPORT OF ITS
MOTION TO COMPEL PLAINTIFF TO PROVIDE CONCEPTION, REDUCTION-TOPRACTICE, AND PRIORITY DATE INFORMATION, AND EXHIBITS L, M, N AND P
TO THE DECLARATION OF MARGARET KAMMERUD IN SUPPORT THEREOF
Pursuant to Local Rule 5 and the Agreed Protective Order entered by the Court [Dkt. No.
85], Defendant Google Inc. (“Google”), respectfully moves this Court for entry of the attached
Order permitting Google to file under seal portions of Google’s Reply in Support of its Motion to
Compel Plaintiff to Provide Conception, Reduction-to-Practice, and Priority Date Information
for the Patents-in-Suit (“Portions of Google’s Reply”) and Exhibits L, M, N and P to the
Declaration of Margaret Kammerud in Support of Google’s Reply in Support of its Motion to
compel Plaintiff to Provide Conception, Reduction-to-Practice, and Priority Date Information for
the Patents-in-Suit (“Certain Exhibits to Kammerud Declaration”). Grounds and authorities for
this Motion are set forth in Google’s Memorandum in Support of Motion to Seal. In compliance
with Local Rule 5, Google attaches a Proposed Agreed Order as Exhibit 1 and is filing
separately a Public Notice of Google’s Motion to Seal. Google requests that the Court retain
sealed materials until forty-five (45) days after a final order is entered and requests that, unless

the case is appealed, any sealed materials be returned to counsel for the filing parties. The
parties have agreed that confidential materials should be filed under seal.

DATED: March 5, 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.

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CERTIFICATE OF SERVICE
I hereby certify that on March 5, 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., 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]

11581889_1.DOC

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