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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`C.A. No. 16-290-MN
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`JURY TRIAL DEMANDED
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`)))))))))
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`GODO KAISHA IP BRIDGE 1,
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`Plaintiff,
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`v.
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`OMNIVISION TECHNOLOGIES, INC.,
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`Defendant.
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`DECLARATION OF LISA D. ZANG IN SUPPORT OF
`DEFENDANT OMNIVISION TECHNOLOGIES, INC.’S MOTION FOR REDACTION
`OF TRANSCRIPT OF DECEMBER 7, 2018 DISCOVERY TELECONFERENCE
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`I, Lisa D. Zang, declare as follows:
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`1.
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`I am an attorney at the law firm of Wilson Sonsini Goodrich & Rosati, P.C.,
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`counsel for Defendant OmniVision Technologies, Inc. (“Defendant” or “OmniVision”) in the
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`above-referenced action. I submit this declaration in support of OmniVision’s Motion for
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`Redaction of the Transcript of the December 7, 2018 Discovery Teleconference. The matters set
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`forth herein are based upon my personal knowledge.
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`2.
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`The deposition of OmniVision’s Senior Vice President of System Technologies,
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`John Li, was taken in this case on October 17, 2018. I specified at this deposition that the entire
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`transcript was to be treated “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY.”
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`Counsel for Plaintiff Godo Kaisha IP Bridge 1 (“Godo”) never objected to or challenged this
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`confidentiality designation.
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`3.
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`Counsel for OmniVision and Godo met and conferred regarding this motion on
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`December 28, 2018. During the meet and confer, counsel for Godo stated that Godo opposes
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`this motion.
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`Case 1:16-cv-00290-MN Document 156 Filed 01/02/19 Page 2 of 2 PageID #: 5062
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`4.
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`Godo’s only professed reason for opposing this motion is that there is a
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`presumption of public access to judicial proceedings and records, and that the confidential
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`information regarding OmniVision’s business practices must be made available to the public
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`because it was allegedly taken into account by the Court in ordering the production of summary
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`foreign sales data.
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`5.
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`Counsel for Godo also claimed during the meet and confer that the business
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`information that OmniVision seeks to redact is not confidential. However, counsel for Godo was
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`unable to provide even a single reason for Godo’s claim that the information is not confidential
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`to OmniVision or identify any public sources that this information could be independently
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`derived from.
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`I declare under penalty of perjury under the laws of the United States of America that the
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`foregoing is true and correct.
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`Executed at Los Angeles, California on January 2, 2019.
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`/s/ Lisa D. Zang
`Lisa D. Zang
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`6038506 / 43303
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`2
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