Case 3:20-cv-06754-WHA Document 849 Filed 07/28/23 Page 1 of 3
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`QUINN EMANUEL URQUHART & SULLIVAN, LLP
` Sean Pak (Bar No. 219032)
` seanpak@quinnemanuel.com
` Melissa Baily (Bar No. 237649)
` melissabaily@quinnemanuel.com
` James Judah (Bar No. 257112)
` jamesjudah@quinnemanuel.com
` Lindsay Cooper (Bar No. 287125)
` lindsaycooper@quinnemanuel.com
` Iman Lordgooei (Bar No. 251320)
` imanlordgooei@quinnemanuel.com
`50 California Street, 22nd Floor
`San Francisco, California 94111-4788
`Telephone:
`(415) 875-6600
`Facsimile:
`(415) 875-6700
`
` Marc Kaplan (pro hac vice)
` marckaplan@quinnemanuel.com
`191 N. Wacker Drive, Ste 2700
`Chicago, Illinois 60606
`Telephone:
`(312) 705-7400
`Facsimile:
`(312) 705-7401
`
`Attorneys for GOOGLE LLC
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`UNITED STATES DISTRICT COURT
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`NORTHERN DISTRICT OF CALIFORNIA
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`SAN FRANCISCO DIVISION
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`SONOS, INC.,
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`Plaintiff and Counter-
`Defendant,
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`vs.
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`Case No. 3:20-cv-06754-WHA
`Consolidated with Case No. 3:21-cv-07559-
`WHA
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`GOOGLE LLC’S UNOPPOSED
`ADMINISTRATIVE MOTION TO
`EXTEND DEADLINES FOR NEW
`MOTION TO SEAL AND PUBLIC
`REFILINGS PURSUANT TO DKT. 846
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`GOOGLE LLC,
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`Defendant and Counter-
`Claimant.
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`Case No. 3:20-cv-06754-WHA
`-1-
`GOOGLE’S UNOPPOSED ADMINISTRATIVE MOTION TO EXTEND DEADLINES FOR NEW MOTION
`TO SEAL AND PUBLIC REFILINGS PURSUANT TO DKT. 846
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`Case 3:20-cv-06754-WHA Document 849 Filed 07/28/23 Page 2 of 3
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`Pursuant to L.R. 6-3, Google LLC respectfully moves for an order extending the deadlines
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`for Google’s new omnibus motion to seal and the parties’ refilings of all material they no longer to
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`seek to seal. On July 19, 2023, the Court instructed Google to “file any new omnibus motion that
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`justifies sealing information that may still deserve secrecy from the public, with the requested
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`declaration, by July 31, 2023, at Noon” and directed that “[a]ll material that the parties no longer
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`seek to seal shall now be publicly refiled no later than August 14, 2023, at Noon.” Dkt. 846
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`(“Order”) at 3. Since receiving the Court’s order, Google and Google’s counsel have worked
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`diligently to ensure that the revised sealing requests are as narrowly tailored as possible. Declaration
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`of Jocelyn Ma (“Ma Decl.”) ¶ 3.
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`However, given the breadth of the documents and information at issue, Google requests
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`additional time to prepare its revised sealing requests. Specifically, Google requests an extension
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`in order to: (1) undertake the necessary preparations for the public disclosure of business
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`information in light of the fact that documents Google previously sought to seal include detailed
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`technical specifications, identification of source code information, and Google’s business plans
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`regarding the relevant products, (2) determine the impact of disclosure and level of confidentiality
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`attributed to each portion of these and other categories of documents, and (3) provide detailed
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`information for the bases for each request to seal such that they “speak to specific information in
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`specific passages” and describe any narrowing from the original request and any revised request.
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`Id. Dkt. 843 at 3; see Ma Decl. ¶ 4. In addition, Google seeks an extension to allow its lead counsel
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`to “vet[] each and every request to seal, as to each and every argument, as to each and every passage
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`that Google seeks to seal.” Dkt. 843 at 3.
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`Allowing Google additional time to narrow its sealing requests will thus facilitate the “hard
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`look at the documents that Google moved to seal” directed by the Court’s Order and minimize the
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`volume of materials for the Court’s review. Id. In addition, without an extension, Google will be
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`substantially harmed by being unable to thoroughly analyze each previous passage that it sought to
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`seal and determine whether such information needs to remain under seal—potentially resulting in
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`the disclosure of highly sensitive and confidential information and/or the submission of a revised
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`request to seal that is inadvertently deficient with respect to the requirements of the Court’s order.
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`Case No. 3:20-cv-06754-WHA
`-1-
`GOOGLE’S OPPOSED ADMINISTRATIVE MOTION TO EXTEND DEADLINES FOR NEW MOTION
`TO SEAL AND PUBLIC REFILINGS PURSUANT TO DKT. 846
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`

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`Case 3:20-cv-06754-WHA Document 849 Filed 07/28/23 Page 3 of 3
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`Ma Decl. ¶ 5.
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`Accordingly, Google requests that the Court extend the deadline for Google to file a new
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`omnibus sealing motion to August 14, 2023 at noon and the deadline for the Parties to publicly refile
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`any material they no longer seek to seal to September 5, 2023 at noon. This proposed schedule
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`would not affect the parties’ ability to comply with the other deadlines set forth in this case. Id.
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`¶ 7. Google requested that Sonos, Inc. (“Sonos”) stipulate to this extension; Sonos refused to do so
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`but indicated that it would not oppose Google’s motion to extend. Id. ¶ 6.
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`DATED: July 28, 2023
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`QUINN EMANUEL URQUHART & SULLIVAN,
`LLP
`
`By
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`/s/ Sean Pak
`Sean Pak
`Melissa Baily
`James D. Judah
`Lindsay Cooper
`Marc Kaplan
`Iman Lordgooei
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`Attorneys for GOOGLE LLC
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`Case No. 3:20-cv-06754-WHA
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`GOOGLE’S OPPOSED ADMINISTRATIVE MOTION TO EXTEND DEADLINES FOR NEW MOTION
`TO SEAL AND PUBLIC REFILINGS PURSUANT TO DKT. 846
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