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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`C.A. No. 13-919-JLH
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`))))))))))
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`ARENDI S.A.R.L.,
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`Plaintiff,
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`v.
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`GOOGLE LLC,
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`Defendant.
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`DECLARATION OF HANNAH L. CANNOM IN SUPPORT OF
`NON-PARTY APPLE INC.’S MOTION FOR SANCTIONS
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`I, Hannah L. Cannom, declare as follows:
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`1.
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`I am over the age of 18, a member in good standing of the bar of the State of
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`California, and a partner at Walker Stevens Cannom LLP. I make this declaration in support of the
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`Motion of Non-Party Apple Inc. for Sanctions. My knowledge of these matters stated within this
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`declaration is either personal or has been developed and confirmed through discussions with other
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`Apple employees. If compelled to testify as a witness, I would testify competently to the facts set
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`forth herein.
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`2.
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`On April 4, 2023, Plaintiff indicated to Apple that it intended to use the Apple
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`Agreement at trial in this case, but that “the courtroom will be sealed during discussion of its terms
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`other than the total payment amount.” I promptly responded on behalf of Apple and proposed
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`solutions that allowed Plaintiff to not seal the courtroom while also protecting Apple’s confidential
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`information, including the amount of consideration Apple paid to Plaintiff in the Apple Agreement.
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`3.
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`After several calls, I was unable to reach a resolution with Plaintiff’s counsel. I
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`therefore informed Plaintiff’s counsel that if Plaintiff intended to disclose the terms of the Apple
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`Agreement in open court, I would raise it with the Court on the first day of trial.
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`Case 1:13-cv-00919-JLH Document 539 Filed 05/03/23 Page 2 of 2 PageID #: 55561
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`4.
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`I attended all of trial to monitor the use of Apple’s confidential information at trial.
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`On behalf of Apple, at no point did I ever agree to de-designate or downgrade the confidentiality
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`designation on the Apple Agreement, nor did Apple ever consent to publicly disclosing the
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`monetary terms of the Apple Agreement.
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`5.
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`As a non-party to this litigation, I was outside of the courtroom when sealed
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`information was presented to the jury. I returned to the courtroom when it was unsealed shortly
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`before Mr. Weinstein disclosed Apple’s confidential information in open court. As such, I did not
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`have the ability to anticipate that Plaintiff and Mr. Weinstein would publicly disclose Apple
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`confidential information.
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`6.
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`During the break shortly after Mr. Weinstein disclosed this information, I
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`approached Mr. Ard and Ms. Srinivasan to discuss the corrective measures they would take
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`because of the improper disclosure of Apple confidential information in the unsealed courtroom.
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`Mr. Ard interrupted me and told me he would “deal with this later.”
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`I declare under penalty of perjury under the laws of the United States of America and the
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`State of Delaware that the foregoing is true and correct.
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`Executed this 3rd day of May, 2023 in Los Angeles, California.
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`_______________________________________
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`Hannah L. Cannom
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`2
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