STIPULATION AND [PROPOSED] ORDER PERMITTING PROTECTED MATERIAL TO BE FILED UNDER SEAL
Advanced Micro Devices, Inc. and ATI Technologies, ULC (collectively, "AMD"), and Samsung Electronics Co., Ltd.; Samsung Semiconductor, Inc.; Samsung Austin Semiconductor, LLC; Samsung Electronics America, Inc.; Samsung Telecommunications America, LLC; Samsung Techwin Co., Ltd.; and Samsung Opto-Electronics America, Inc. (collectively, "Samsung") jointly submit this Stipulation regarding the filing of Protected Material under seal.
WHEREAS, The Joint Stipulated Protective Order states that "a Party may not file in the public record in this action any Protected Material or document summarizing, discussing or otherwise referencing Protected Material." Dkt. No. 60 at 12.
WHEREAS, Defendants and Counterclaimants' Opening Claim Construction Brief contains Highly Confidential AMD Protected Material.
WHEREAS, the parties acknowledge that AMD does not waive any right to later challenge the inclusion of AMD Protected Material in Defendants and Counterlaimants' Opening Claim Construction Brief.
Pursuant to Civil Local Rule 7-12, IT IS HEREBY STIPULATED AND AGREED, by and between AMD and Samsung that, subject to the Court's approval, the unredacted version of Defendants and Counterclaimants' Opening Claim Construction Brief filed on March 16, 2009 shall be filed under seal, and the redacted version of this document shall be publicly filed with the Court.
I, Christine Saunders Haskett, am the ECF User whose identification and password are 3 being used to file this Stipulation regarding the the filing of Protected Material under seal In 4 compliance with General Order 45.X.B, I hereby attest that William H. Manning has concurred 5 in this filing.
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