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`Case 5:15-cv-02008-EJD Document 84-2 Filed 04/13/16 Page 1 of 2
`
`
`
`GEORGE A. RILEY (S.B. #118304)
`griley@omm.com
`LUANN L. SIMMONS (S.B. #203526)
`lsimmons@omm.com
`MELODY DRUMMOND HANSEN (S.B. #278786)
`mdrummondhansen@omm.com
`O’MELVENY & MYERS LLP
`Two Embarcadero Center, 28th Floor
`San Francisco, California 94111-3823
`Telephone:
`(415) 984-8700
`Facsimile:
`(415) 984-8701
`
`RYAN K. YAGURA (S.B. #197619)
`ryagura@omm.com
`XIN-YI ZHOU (S.B. #251969)
`vzhou@omm.com
`BRIAN M. COOK (S.B. #266181)
`bcook@omm.com
`KEVIN MURRAY (S.B. #275186)
`kmurray2@omm.com
`O’MELVENY & MYERS LLP
`400 South Hope Street
`Los Angeles, California 90071-2899
`Telephone:
`(213) 430-6000
`Facsimile:
`(213) 430-6407
`Attorneys for Defendant Apple, Inc.
`
`
`UNITED STATES DISTRICT COURT
`
`NORTHERN DISTRICT OF CALIFORNIA
`
`SAN JOSE
`
`OpenTV, Inc., Nagravision, SA, and Nagra
`France S.A.S.,
`
`Plaintiffs,
`
`Defendant.
`
`v.
`
`Apple Inc.,
`
`
`
`
`
`Case No. 5:15-CV-02008-EJD
`
`DECLARATION OF MELODY
`DRUMMOND HANSEN IN SUPPORT
`OF APPLE, INC.’S ADMINISTRATIVE
`MOTION TO FILE UNDER SEAL
`DEFENDANT’S MOTION TO
`PRECLUDE AND CERTAIN
`SUPPORTING EXHIBITS
`
`i
`
`DECLARATION OF MELODY
`DRUMMOND HANSEN
`5:15-CV-02008-EJD
`
`
`
`Case 5:15-cv-02008-EJD Document 84-2 Filed 04/13/16 Page 2 of 2
`
`
`
`I am an attorney admitted to practice in the Northern District of California. I represent
`
`Defendant Apple, Inc. in the above captioned matter. This declaration is accurate to the best of
`
`my knowledge. I have personal knowledge of the facts stated below. I am of sound mind and
`
`capable of testifying to the facts below.
`
`“Defendant’s Motion to Preclude Reliance on Certain Invention Dates and to Strike
`
`Certain Allegations” (“Motion to Preclude”), as well as supporting Exhibits 2, 7, and 8 attached
`
`to that motion, are hereby requested sealed only because they contain information that Plaintiffs
`
`have designated “Highly Confidential - Attorneys’ Eyes Only” pursuant to the Protective Order in
`
`force in this action. See Dkt. 66. Exhibits 2, 7, and 8 are so designated in their entirety. The
`
`Motion to Preclude is only requested sealed in part, as indicated by the blue highlighting in the
`
`unredacted version attached to the administrative motion to file under seal, because it contains
`
`By: /s/ Melody Drummond Hansen
`Melody Drummond Hansen
`State Bar No. 278786
`
` Attorney for Defendant Apple Inc.
`
`
`
`1
`
`DECLARATION OF MELODY
`DRUMMOND HANSEN
`5:15-CV-02008-EJD
`
`information from Exhibits 2, 7, or 8.
`
`
`
`
`Dated: April 13, 2016
`
`
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