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