Kim v. Coach, Inc, et al

Filing 36

REPLY, filed by Counter Claimant Coach, Inc., Defendant Coach, Inc., TO RESPONSE to 22 MOTION to Seal (Keehnel, Stellman)

Gina Kim vs. Coach, Inc., et al.

Doc. 36

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 v. GINA KIM, on behalf of a class consisting of herself and all other persons similarly situated, Plaintiffs, and as to Ms. Kim, counterclaim defendant,

THE HONORABLE RICARDO S. MARTINEZ

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE NO. 2:11-cv-00214-RSM COACH, INC.'S REPLY IN SUPPORT OF MOTION TO SEAL

COACH, INC., a Maryland corporation, and COACH SERVICES, INC., a Maryland corporation, Defendants, and, as to Coach, Inc., counterclaim plaintiff.

NOTED FOR CONSIDERATION: APRIL 8, 2011

Coach, Inc. ("Coach") hereby submits its reply in support of motion to seal (Dkt. No. 22). Coach has been working with plaintiff's counsel on proposed redactions of Coach, Inc's Opposition to Special Motion to Strike (the "Opposition") and of the Declaration of John Macaluso in Support of Defendant Coach, Inc's Opposition to Special Motion to Strike (the "Macaluso Declaration"). On or before April 12, 2011, Coach will file redacted versions of the Opposition and the Macaluso Declaration, which documents will be accessible to the public. Proposed redactions will be strictly limited to portions of the Opposition and the Macaluso Declaration that contain highly confidential business information concerning how
COACH, INC.'S REPLY IN SUPPORT OF MOTION TO SEAL ­ 1 NO. 2:11-cv-00214-RSM DLA Piper LLP (US) 701 Fifth Avenue, Suite 7000 Seattle, WA 98104-7044 Tel: [phone]

Dockets.Justia.com

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Coach identifies counterfeit products, the public disclosure of which would enable counterfeiters to evade detection and which would harm Coach's business. See Omax Corp. v. Flow Intern. Corp., No. C04-2334RSL, 2007 WL 3232540, *1 (W.D. Wash., Oct. 31, 2007) (sealing certain documents relating to businesses' "long-term strategic plans, proprietary software, control methodology and cutting models, and/or customer and competitor research," where "disclosure . . . would put [parties] at a competitive disadvantage"). For these reasons and for reasons set forth in Coach's opening brief, the Court should grant the motion and permit Coach to file the Opposition and Macaluso Declaration under seal. Dated this 8th day of April, 2011. DLA Piper LLP (US) By: /s/ Stellman Keehnel Stellman Keehnel, WSBA No. 9309 R. Omar Riojas, WSBA No. 35400 Patrick Eagan, WSBA No. 42679 DLA Piper LLP (US) 701 Fifth Avenue, Suite 7000 Seattle, WA 98104 Tel: [phone] Fax: [phone] E-mail: [e-mail] E-mail: [e-mail] E-mail: [e-mail] Attorneys for defendant and counterclaim plaintiff Coach, Inc.

COACH, INC.'S REPLY IN SUPPORT OF MOTION TO SEAL ­ 2 NO. 2:11-cv-00214-RSM

DLA Piper LLP (US) 701 Fifth Avenue, Suite 7000 Seattle, WA 98104-7044 Tel: [phone]

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WEST\223352841.2

CERTIFICATE OF SERVICE I hereby certify that on April 8, 2011, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system which will send notification of such filing to all counsel of record. Dated this 8th day of April, 2011. /s/ Stellman Keehnel Stellman Keehnel, WSBA No. 9309

COACH, INC.'S REPLY IN SUPPORT OF MOTION TO SEAL ­ 3 NO. 2:11-cv-00214-RSM

DLA Piper LLP (US) 701 Fifth Avenue, Suite 7000 Seattle, WA 98104-7044 Tel: [phone]