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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 27 Case5:11-cv-01846-LHK Document2851 Filed12/05/13 Page1 of 3 1 HAROLD J. MCELHINNY (CA SBN 66781) WILLIAM F. LEE [email protected] [email protected] 2 MICHAEL A. JACOBS (CA SBN 111664) WILMER CUTLER PICKERING [email protected] HALE AND DORR LLP 3 RACHEL KREVANS (CA SBN 116421) 60 State Street [email protected] Boston, MA 02109 4 ERIK J. OLSON (CA SBN 175815) Telephone: (617) 526-6000 [email protected] Facsimile: (617) 526-5000 5 MORRISON & FOERSTER LLP 425 Market Street 6 San Francisco, California 94105-2482 MARK D. SELWYN (SBN 244180) Telephone: (415) 268-7000 [email protected] 7 Facsimile: (415) 268-7522 WILMER CUTLER PICKERING HALE AND DORR LLP 8 950 Page Mill Road Palo Alto, California 94304 9 Attorneys for Plaintiff and Telephone: (650) 858-6000 Counterclaim-Defendant APPLE INC. Facsimile: (650) 858-6100 10 11 UNITED STATES DISTRICT COURT 12 NORTHERN DISTRICT OF CALIFORNIA 13 SAN JOSE DIVISION 14 APPLE INC., a California corporation, Case No. 11-cv-01846-LHK (PSG) 15 Plaintiff, APPLE’S ADMINISTRATIVE MOTION TO 16 FILE UNDER SEAL APPLE’S MOTION v. FOR ATTORNEYS’ FEES 17 SAMSUNG ELECTRONICS CO., LTD., a 18 Korean corporation; SAMSUNG ELECTRONICS AMERICA, INC., a New 19 York corporation; and SAMSUNG TELECOMMUNICATIONS AMERICA, 20 LLC, a Delaware limited liability company, 21 Defendants. 22 23 24 25 26 27 28 APPLE’S ADMIN. MOT. TO FILE UNDER SEAL MOT. FOR ATTORNEYS’ FEES CASE NO. 11-cv-01846-LHK (PSG) sf-3361324 Case5:11-cv-01846-LHK Document2851 Filed12/05/13 Page2 of 3 1 In accordance with Civil Local Rules 7-11 and 79-5, Apple Inc. (“Apple”) submits this 2 motion for an order to seal its Motion for Attorneys’ Fees and Exhibit A to the Declaration of 3 Michael A. Jacobs in Support of Apple’s Motion for Attorneys’ Fees (“Jacobs Declaration”). 4 Exhibit A to the Jacobs Declaration contains information that is confidential and 5 competitively sensitive as set out in the Declaration of Ruth Borenstein in Support of Apple’s 6 Administrative Motion to File Under Seal (“Borenstein Declaration”), filed herewith. As detailed 7 in the Borenstein Declaration, Exhibit A contains extensive competitively sensitive and 8 confidential information regarding the negotiated billing rates of Apple’s counsel in this action, 9 Morrison & Foerster LLP. (Borenstein Decl. ¶ 2.) The billing rates of Morrison & Foerster 10 timekeepers are confidential, and are not generally revealed to the public. (Id.) Exhibit A 11 contains the rates for 91 timekeepers. The breadth of the information revealed in Exhibit A could 12 provide insight into Morrison & Foerster’s firm-wide billing structure and reflects Morrison & 13 Foerster’s confidential financial relationship (including negotiated discounts) with Apple. 14 Apple’s Motion for Attorneys’ Fees refers to one specific timekeeper rate that is not publicly 15 known. This information is competitively sensitive and confidential and could be used by 16 Morrison & Foerster’s competitors to its disadvantage, as disclosure of the information would 17 reveal the firm’s billing structure and confidential pricing strategy, as well as its negotiated 18 financial relationship with Apple. (Id.) 19 Numerous courts in the Ninth Circuit have held that, “In trademark/dress matters, attorney 20 billing rates which are not publicly known and are ‘competitively sensitive,’ warrant sealing.” 21 E&J Gallo Winery v. Proximo Spirits, Inc., No. CV-00411, 2012 U.S. Dist. LEXIS 94581, at *2 22 (E.D. Cal. July 9, 2012) (citing China Int’l Travel Servs. (USA) v. China & Asia Travel Serv., 23 No. 08-cv-01293, 2008 U.S. Dist. LEXIS 106622, at *29 (N.D. Cal. Dec. 18, 2008) (noting that 24 counterclaim plaintiff would “request its attorneys’ fees by way of a declaration, submitted for 25 filing under seal, . because the attorneys’ hourly rates are competitively sensitive and not 26 publicly known.”); Mine O’Mine, Inc. v. Calmese, No. 10-CV-00043, 2012 U.S. Dist. LEXIS 27 53077, at *10 (D. Nev. Apr. 16, 2012) (sealing negotiated billing rates)); Gen’l Elec. Co. v. 28 Wilkins, No. 10-CV-00674, 2012 U.S. Dist. LEXIS 97647, at *6 (E.D. Cal. July 13, 2012) APPLE’S ADMIN. MOT. TO FILE UNDER SEAL MOT. FOR ATTORNEYS’ FEES 1 CASE NO. 11-CV-01846-LHK sf-3361324 Case5:11-cv-01846-LHK Document2851 Filed12/05/13 Page3 of 3 1 (same); Herb Reed Enters., Inc. v. Monroe Powell’s Platters, LLC, No. 11-cv-02010, 2013 U.S. 2 Dist. LEXIS 96948, at *2 (D. Nev. July 11, 2013) (same). The E&J Gallo court also found that a 3 law firm’s confidential billing rate, “if [it] became known, would likely impact the law firm’s 4 competitiveness.” E & J Gallo Winery v. Proximo Spirits, Inc., No. 10-cv-00411, 2012 U.S. Dist. 5 LEXIS 64525, at *5-6 (E.D. Cal. May 8, 2012).1 The relief requested in this motion is necessary 6 and is narrowly tailored to protect only the billing rates of counsel. 7 Pursuant to Civil Local Rule 79-5(d), Apple files herewith Exhibit A to the Jacobs 8 Declaration entirely under seal; a public redacted version of its Motion for Attorneys’ Fees; and, 9 under seal, an unredacted version of its Motion for Attorneys’ Fees indicating with highlighting 10 the specific number Apple requests to seal. 11 12 Dated: December 5, 2013 MORRISON & FOERSTER LLP 13 14 By: /s/ Rachel Krevans Rachel Krevans 15 Attorney for Plaintiff 16 APPLE INC. 17 18 19 20 21 22 23 24 25 1 This Court recently denied a request to seal attorney billing records that included hourly rates. See Ferrington v. McAfee, Inc., No. 10-CV-01455, 2013 U.S. Dist. LEXIS 103038, at *4-6 (N.D. 26 Cal. July 22, 2013). That case is distinguishable, however, as the moving party argued only that the records were covered by attorney-client privilege. Id. at *4-6. There was no argument that 27 the rates were confidential and competitively sensitive. To the contrary, the Court noted that the hourly rates were reflected in the very declarations that attached the billing records at issue, and 28 that the moving party was not seeking to seal those declarations. Id. at *5. APPLE’S ADMIN. MOT. TO FILE UNDER SEAL MOT. FOR ATTORNEYS’ FEES 2 CASE NO. 11-CV-01846-LHK sf-3361324 Case5:11-cv-01846-LHK Document2851-1 Filed12/05/13 Page1 of 3 1 HAROLD J. MCELHINNY (CA SBN 66781) WILLIAM F. LEE [email protected] [email protected] 2 MICHAEL A. JACOBS (CA SBN 111664) WILMER CUTLER PICKERING [email protected] HALE AND DORR LLP 3 RACHEL KREVANS (CA SBN 116421) 60 State Street [email protected] Boston, MA 02109 4 ERIK J. OLSON (CA SBN 175815) Telephone: (617) 526-6000 [email protected] Facsimile: (617) 526-5000 5 MORRISON & FOERSTER LLP 425 Market Street 6 San Francisco, California 94105-2482 MARK D. SELWYN (SBN 244180) Telephone: (415) 268-7000 [email protected] 7 Facsimile: (415) 268-7522 WILMER CUTLER PICKERING HALE AND DORR LLP 8 950 Page Mill Road Palo Alto, California 94304 9 Attorneys for Plaintiff and Telephone: (650) 858-6000 Counterclaim-Defendant APPLE INC. Facsimile: (650) 858-6100 10 11 UNITED STATES DISTRICT COURT 12 NORTHERN DISTRICT OF CALIFORNIA 13 SAN JOSE DIVISION 14 APPLE INC., a California corporation, Case No. 11-cv-01846-LHK (PSG) 15 Plaintiff, DECLARATION OF RUTH N. 16 BORENSTEIN IN SUPPORT OF APPLE’S v. 17 ADMINISTRATIVE MOTION TO FILE SAMSUNG ELECTRONICS CO., LTD., a UNDER SEAL 18 Korean corporation; SAMSUNG ELECTRONICS AMERICA, INC., a New 19 York corporation; and SAMSUNG TELECOMMUNICATIONS AMERICA, 20 LLC, a Delaware limited liability company, 21 Defendants. 22 23 24 25 26 27 28 DECLARATION OF RUTH BORENSTEIN ISO MOTION TO FILE UNDER SEAL CASE NO. 11-cv-01846-LHK (PSG) sf-3361361 Case5:11-cv-01846-LHK Document2851-1 Filed12/05/13 Page2 of 3 1 I, RUTH N. BORENSTEIN, do hereby declare as follows: 2 1. I am a partner at Morrison & Foerster LLP, counsel of record for Apple Inc. in the 3 above-captioned action. I submit this declaration in support of Apple’s Administrative Motion to 4 File Under Seal Apple’s Motion for Attorneys’ Fees. I have personal knowledge of the matters 5 set forth below. If called as a witness I could and would competently testify as follows. 6 2. Apple’s Motion for Attorneys’ Fees and Exhibit A to the Declaration of 7 Michael A. Jacobs in Support of Apple’s Motion for Attorneys’ Fees (“Jacobs Declaration”) 8 contain confidential and competitively sensitive information regarding Morrison & Foerster’s 9 negotiated billing rates. Specifically, Exhibit A contains the rates for 91 timekeepers. The billing 10 rates of Morrison & Foerster timekeepers are confidential, and are not generally revealed to the 11 public. The breadth of the information revealed in Exhibit A could provide insight into 12 Morrison & Foerster’s firm-wide billing structure and reflects Morrison & Foerster’s confidential 13 financial relationship (including negotiated discounts) with Apple. Apple’s Motion for 14 Attorneys’ Fees refers to one timekeeper’s rate that is not publicly known. This information is 15 competitively sensitive and confidential and could be used by Morrison & Foerster’s competitors 16 to its disadvantage. Publishing this data would reveal the firm’s confidential pricing strategy and 17 its negotiated financial relationship with Apple and would cause harm to Morrison & Foerster and 18 its relationship with Apple. 19 3. Exhibit A to the Jacobs Declaration should remain under seal in full, for the 20 reasons articulated above.
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