`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`ARENDI S.A.R.L.,
`
` Plaintiff,
`
`v.
`
`GOOGLE LLC,
`
`
`
`
`
`Case No. 13-919 (JLH)
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
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` Defendant.
`
`
`STIPULATION AND [PROPOSED] ORDER ALLOWING NON-PARTIES SAMSUNG
`ELECTRONICS CO., LTD. AND SAMSUNG ELECTRONICS AMERICA, INC. TO
`ACCESS TRIAL TRANSCRIPTS
`
`
`
`
`
`
`WHEREAS, a jury trial was held in this matter from April 24 to May 2, 2023;
`
`WHEREAS, non-parties Samsung Electronics Co., Ltd. and Samsung Electronics
`
`America, Inc. (collectively “Samsung”) were advised that certain agreements between Arendi
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`S.A.R.L. (“Arendi”) and Samsung were used as exhibits and discussed in a sealed courtroom
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`during the jury trial;
`
`
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`WHEREAS, Samsung filed a Notice of Intent to Redact and/or Seal Limited Portions of
`
`the Trial Transcripts and Exhibits on June 8, 2023 (D.I. 564);
`
`
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`WHEREAS, under the relevant Third Circuit standard, which requires a party to show that
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`disclosure of the material sought to be protected would cause a “clearly defined and serious injury,”
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`In re Avandia Marketing, 924 F.3d 662, 672 (3d Cir. 2019), Samsung will need access to the trial
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`transcripts to make an informed decision regarding the proper scope of the requested redactions;
`
`
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`WHEREAS, Samsung has agreed to accept copies of the transcript that have third party
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`confidential information redacted, provided that Samsung will have full access to portions of the
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`transcript that mention Samsung or its agreements, and provided that Samsung’s confidential
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`information likewise will be redacted in any transcripts provided to any third party;
`
`
`
`Case 1:13-cv-00919-JLH Document 572 Filed 06/20/23 Page 2 of 3 PageID #: 56919
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`
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`IT IS HEREBY STIPULATED AND AGREED, by and through the undersigned counsel
`
`for Plaintiff Arendi, Defendant Google LLC, and non-parties Samsung, subject to the approval of
`
`the Court, that Samsung’s outside counsel shall be permitted to access the transcripts from the jury
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`trial held from April 24, 2023 to May 2, 2023, which a party may redact to remove third party
`
`confidential information unrelated to Samsung or Samsung’s agreements with Arendi.
`
`POTTER ANDERSON & CORROON LLP
`
`/s/ Bindu A. Palapura
`David E. Moore (#3983)
`Bindu A. Palapura (#5370)
`Andrew L. Brown (#6766)
`Hercules Plaza, 6th Floor
`1313 N. Market Street
`Wilmington, DE 19801
`(302) 984-6000
`dmoore@potteranderson.com
`bpalapura@potteranderson.com
`abrown@potteranderson.com
`
`Attorneys for Defendant Google LLC
`
`
`
`SMITH, KATZENSTEIN & JENKINS LLP
`
`/s/ Neal C. Belgam
`Neal C. Belgam (No. 2721)
`Daniel Taylor (No. 6934)
`1000 West Street, Suite 1501
`Wilmington, DE 19801
`(302) 652-8400
`nbelgam@skjlaw.com
`dtaylor@skjlaw.com
`
`Attorneys for Plaintiff Arendi S.A.R.L.
`
`
`
`
`YOUNG CONAWAY STARGATT &
` TAYLOR, LLP
`
`/s/ Adam W. Poff
`Adam W. Poff (No. 3990)
`Samantha G. Wilson (No. 5816)
`1000 North King Street
`Wilmington, DE 19801
`(302) 571-6600
`apoff@ycst.com
`swilson@ycst.com
`
`Attorneys for Non-Parties Samsung Electronics
`Co., Ltd. and Samsung Electronics America,
`Inc.
`
`
`
`
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`2
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`
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`Case 1:13-cv-00919-JLH Document 572 Filed 06/20/23 Page 3 of 3 PageID #: 56920
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`
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`SO ORDERED this ______ day of _____________, 2023
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`
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`_______________________________________
`The Honorable Jennifer L. Hall
`United States Magistrate Judge
`
`3
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