`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`GENENTECH, INC. and CITY OF HOPE,
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`Plaintiffs,
`
`v.
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`AMGEN INC.,
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`Defendant.
`
`
`C.A. No. ___________
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`
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`PLAINTIFFS’ MOTION TO SEAL COMPLAINT
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`
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`Plaintiffs Genentech, Inc. and City of Hope (“Plaintiffs”), by and through their
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`undersigned counsel, respectfully move pursuant to Federal Rule of Civil Procedure 5.2 and the
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`Local Rules of Civil Practice and Procedure of the United States District Court for the District of
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`Delaware, for an Order sealing their Complaint against Amgen Inc. (“Defendant”) filed on June
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`21, 2018 (D.I. 740 in C.A. No. 99-9999). The bases for this Motion are set forth below.
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`1.
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`2.
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`The Complaint alleges claims of patent infringement against Defendant.
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`Shortly after Plaintiffs filed the Complaint publicly on June 21, 2018, Defendant
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`expressed concern that the Complaint contains confidential information.
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`3.
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`As such, Plaintiffs believe that it is necessary and appropriate to seal the
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`Complaint.
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`4.
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`If the Complaint is sealed, counsel for Plaintiffs will work with counsel for
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`Defendant to prepare and file a redacted, public version of the Complaint within seven days of
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`the Order granting this motion.
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`
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`ME1 27434714v.2
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`1
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`
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`Case 1:18-cv-00924-CFC-SRF Document 1 Filed 06/21/18 Page 2 of 2 PageID #: 2
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`WHEREFORE, Plaintiffs respectfully request that their June 21, 2018 Complaint against
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`Defendant be sealed and that the Court enter the proposed order submitted herewith.
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`Respectfully submitted,
`
`
`/s/ Daniel M. Silver
`Michael P. Kelly (#2295)
`Daniel M. Silver (#4758)
`MCCARTER & ENGLISH, LLP
`Renaissance Centre
`405 North King Street, 8th Floor
`Wilmington, DE 19801
`(302) 984-6300
`mkelly@mccarter.com
`dsilver@mccarter.com
`
`Counsel for Plaintiffs Genentech, Inc. and
`City of Hope
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`
`
`DATED: June 22, 2018
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`
`
`Of Counsel:
`
`William F. Lee
`Lisa J. Pirozzolo
`Emily R. Whelan
`Kevin S. Prussia
`Andrew J. Danford
`WILMER CUTLER PICKERING
`HALE AND DORR LLP
`60 State Street
`Boston, MA 02109
`william.lee@wilmerhale.com
`lisa.pirozzolo@wilmerhale.com
`emily.whelan@wilmerhale.com
`kevin.prussia@wilmerhale.com
`andrew.danford@wilmerhale.com
`
`Robert J. Gunther Jr.
`WILMER CUTLER PICKERING
`HALE AND DORR LLP
`7 World Trade Center
`250 Greenwich Street
`New York, NY 10007
`robert.gunther@wilmerhale.com
`
`Daralyn J. Durie
`Adam R. Brausa
`DURIE TANGRI LLP
`217 Leidesdorff St.
`San Francisco, CA 94111
`ddurie@durietangri.com
`abrausa@durietangri.com
`
`
`
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`ME1 27434714v.2
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`2
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