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`YAR R. CHAIKOVSKY (SB# 175421)
`yarchaikovsky@paulhastings.com
`PHILIP OU (SB# 259896)
`philipou@paulhastings.com
`JOSEPH J. RUMPLER, II (SB# 296941)
`josephrumpler@paulhastings.com
`DAVID OKANO (SB# 278485)
`davidokano@paulhastings.com
`ANDY LEGOLVAN (SB# 292520)
`andylegolvan@paulhastings.com
`BORIS LUBARSKY (SB# 324896)
`borislubarsky@paulhastings.com
`PAUL HASTINGS LLP
`1117 S. California Avenue
`Palo Alto, California 94304-1106
`Telephone: 1(650) 320-1800
`Facsimile: 1(650) 320-1900
`
`MATTHIAS KAMBER (SB#232147)
`matthiaskamber@paulhastings.com
`PAUL HASTINGS LLP
`101 California Street, 48th Floor
`San Francisco, California 94111
`Telephone: 1(415) 856-7000
`Facsimile: 1(415) 856-7100
`
`Attorneys for Plaintiff
`APPLIED MATERIALS, INC.
`
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`
`APPLIED MATERIALS, INC.,
`Plaintiff,
`
`vs.
`DEMARAY LLC,
`Defendant.
`
`CASE NO. 5:20-cv-09341-EJD
`DECLARATION OF BORIS
`LUBARSKY IN SUPPORT OF
`APPLIED MATERIALS, INC.’S
`ADMINISTRATIVE MOTION TO
`FILE UNDER SEAL
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`LUBARSKY DECL. IN SUPPORT
`OF APPLIED’S ADMINISTRATIVE
`MOTION TO FILE UNDER SEAL
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`Case 5:20-cv-09341-EJD Document 141-1 Filed 03/23/22 Page 2 of 3
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`I, Boris Lubarsky, hereby declare as follows:
`1. I am an associate with the law firm Paul Hastings LLP, counsel for the Plaintiff Applied
`Materials, Inc. (“Applied”). I have personal knowledge of the facts contained in the declaration
`and, if called upon to do so, I could and would testify competently to the matters set forth herein.
`2. I submit this declaration in support of Applied’s Administrative Motion for Leave to File
`under Seal Applied’s Opposition to Demaray LLC’s (“Demaray”) Motion to Amend its Complaint
`and documents in support thereof as they contain highly confidential business information relating
`to Applied, Samsung Electronics America, Inc., Samsung Electronics Co., Ltd, Samsung
`Semiconductor, Inc., and Samsung Austin Semiconductor, LLC (collectively “Samsung”), and
`Intel Corporation (“Intel”). This request is narrowly tailored to protect highly confidential business
`information.
`3. Exhibits D–G, L to the Declaration of Boris Lubarsky in Support of Applied’s Opposition
`to Demaray’s Motion to Amend its Complaint. (“Lubarsky Decl.”) include technical specifications,
`a PVD chamber manual, and Applied’s corporate representative’s testimony, and contain highly
`confidential Applied business information including details of proprietary reactor technology.
`4. Exhibits A–C, J, K to Lubarsky Decl. are supplemental infringement contentions brought
`by Demaray in the customer suits in the Western District of Texas and contain highly confidential
`Intel, Samsung, and Applied business information including details of proprietary reactor
`technology. Demaray has also designated these exhibits as Highly Confidential under the
`respective protective orders in the customer suits in the Western District of Texas.
`5. Applied has invested significant financial and technical resources in developing its
`proprietary reactor technology and public dissemination of the information could cause Applied,
`Intel, and Samsung competitive and financial harm by revealing proprietary and confidential
`information specific to Applied’s, Intel’s, and Samsung’s trade secrets and intellectual property.
`I declare under penalty of perjury that the foregoing is true and correct.
`
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`- 1 -
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`LUBARSKY DECL. IN SUPPORT
`OF APPLIED’S ADMINISTRATIVE
`MOTION TO FILE UNDER SEAL
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`Case 5:20-cv-09341-EJD Document 141-1 Filed 03/23/22 Page 3 of 3
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`DATED: March 23, 2022
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`By: /s/ Boris Lubarsky
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`Boris Lubarsky
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`- 2 -
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`LUBARSKY DECL. IN SUPPORT
`OF APPLIED’S ADMINISTRATIVE
`MOTION TO FILE UNDER SEAL
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`
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