The opinion of the court was delivered by: Honorable Susan Illston United States District Judge
STIPULATION AND [PROPOSED] ORDER PERMITTING PROTECTED MATERIAL TO BE FILED UNDER SEAL [Civil L.R. 7-12]
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 Digital Imaging Co., Ltd. (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, Exhibits 2, 4, 5, 10, 11, 12, 17, 19, 20, 22, 27, 31, 36, 37, 40, 43 and 44 to the Declaration of Aaron R. Fahrenkrog in Support of Plaintiffs' Opposition to Samsung's Motion for Summary Judgment of Non-Infringement of U.S. Patent No. 6,784,879 ("Fahrenkrog Declaration") have been designated Highly Confidential - Outside Counsel's Eyes Only at Samsung's request;
WHEREAS, the Declaration of Andrew Wolfe, Ph.D in Support of Plaintiffs' Opposition to Samsung's Motion for Summary Judgment of Non-Infringement of U.S. Patent No. 6,784,879 ("Wolfe Declaration") contains a discussion of information that Samsung has requested be designated Highly Confidential - Outside Counsel's Eyes Only; 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, confidential portions of the Wolfe Declaration and exhibits to the Fahrenkrog Declaration shall be filed under seal.
DATED: April 16, 2010 ROBINS, KAPLAN, MILLER & CIRESI L.L.P. Aaron R. Fahrenkrog William H. Manning Brad P. Engdahl Aaron R. Fahrenkrog ATTORNEYS FOR ADVANCED MICRO DEVICES, INC. AND ATI TECHNOLOGIES,
DATED: April 16, 2010 COVINGTON & BURLING LLP Samuel F. Ernst Robert T. Haslam Christine Saunders Haskett Samuel F. Ernst ATTORNEYS FOR SAMSUNG ELECTRONICS CO., LTD.; SAMSUNG SEMICONDUCTOR, INC.; SAMSUNG AUSTIN SEMICONDUCTOR, LLC; SAMSUNG ELECTRONICS AMERICA, INC.; SAMSUNG TELECOMMUNICATIONS AMERICA, LLC; SAMSUNG DIGITAL IMAGING CO., LTD.
PURSUANT TO STIPULATION, IT IS SO ORDERED.
I, Aaron R. Fahrenkrog, am the ECF User whose identification and password are being used to file this Stipulation regarding the filing of Protected Material under seal In compliance with General Order 45.X.B, I hereby attest that Samuel F. Ernst has concurred in this filing.
DATED: April 16, 2010 ROBINS, KAPLAN, MILLER & CIRESI, LLP AARON R. FAHRENKROG Attorneys for Plaintiffs Advanced Micro Devices, Inc. and ATI Technologies, ULC
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