`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF GEORGIA
`ATLANTA DIVISION
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`EMERSON ELECTRIC CO., FISHER-
`ROSEMOUNT SYSTEMS, INC., and
`ROSEMOUNT INC.,
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`Plaintiffs,
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`v.
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`SIPCO, LLC, and
`IP CO, LLC (d/b/a INTUS IQ),
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`Defendants.
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`SIPCO, LLC, and IP CO, LLC
`(d/b/a INTUS IQ),
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`Plaintiffs,
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`v.
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`Civil Action
`File No. 1:15-cv-00319-AT
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`Civil Action
`File No. 1:16-cv-02690-AT
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`EMERSON ELECTRIC CO., EMERSON
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`PROCESS MANAGEMENT LLLP,
`FISHER-ROSEMOUNT SYSTEMS, INC., )
`ROSEMOUNT INC., BP p.l.c., BP
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`AMERICA, INC., and BP AMERICA
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`PRODUCTION COMPANY,
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`Defendants.
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`SIPCO, LLC AND IP CO, LLC’S MOTION FOR LEAVE TO FILE
`THEIR MOTION TO TRANSFER VENUE AND SUPPORTING
`MEMORANDUM PARTIALLY UNDER SEAL
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`
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`Case 1:16-cv-02690-AT Document 118 Filed 08/03/16 Page 2 of 5
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`SIPCO, LLC and IP CO, LLC (collectively, “SIPCO”) respectfully seek
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`leave to file their Motion to Transfer Venue to the Eastern District of Texas
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`(“Motion”) and Memorandum in Support of Their Motion to Transfer Venue to the
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`Eastern District of Texas (“Memorandum”) partially under seal. Portions of
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`SIPCO’s Memorandum and supporting exhibits recite information disclosed to
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`SIPCO through documents produced by the Emerson parties in this litigation.
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`Those documents were produced by Emerson with CONFIDENTIAL or
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`ATTORNEYS EYES ONLY designations pursuant to the Protective Order entered
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`by this Court and the Protective Order entered by the Eastern District of Texas
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`court in the above-captioned actions. Out of respect for Emerson’s request to keep
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`this information confidential and in order to comply with the Protective Orders
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`entered in the above-captioned actions, SIPCO seeks to file publicly through ECF a
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`redacted copy of its Memorandum and supporting exhibits.
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`For the foregoing reasons, SIPCO requests that this Court grant leave to file
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`partially under seal SIPCO’s Motion, Memorandum, and supporting exhibits. The
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`redacted copy is submitted with this motion as Attachment 1.
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`2
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`Case 1:16-cv-02690-AT Document 118 Filed 08/03/16 Page 3 of 5
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`This 2nd day of August, 2016.
`
`/s/ J. Christopher Fox, II
`J. Christopher Fox, II
`Georgia Bar No. 272527
`Michael Coleman
`Georgia Bar No. 177635
`Thompson Hine LLP
`Two Alliance Center, Suite 1600
`3560 Lenox Road
`Atlanta, Georgia 30326
`Telephone: 404-541-2900
`Facsimile: 404-541-2905
`Chris.Fox@ThompsonHine.com
`Michael.Coleman@ThompsonHine.com
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`Paul J. Cronin, Pro hac vice
`James C. Hall, Pro hac vice
`Timothy J. Reppucci, Pro hac vice
`Nutter, McClennen & Fish LLP
`155 Seaport Boulevard
`Boston, Massachusetts 02210-2604
`Telephone: 617-439-2000
`Facsimile: 617-310-9000
`pcronin@nutter.com
`jhall@nutter.com
`treppucci@nutter.com
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`Counsel for SIPCO, LLC and IP CO, LLC
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`3
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`Case 1:16-cv-02690-AT Document 118 Filed 08/03/16 Page 4 of 5
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`CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1
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`The undersigned hereby certifies that this filing was prepared using one of
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`the font and point selections approved by this Court in Local Rule 5.1C.
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`Specifically, Times New Roman font was used in 14 point.
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`/s/ J. Christopher Fox, II
`J. Christopher Fox, II
`Georgia Bar No. 272527
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`4
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`Case 1:16-cv-02690-AT Document 118 Filed 08/03/16 Page 5 of 5
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`CERTIFICATE OF SERVICE
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`This is to certify that I have this day served all counsel of record with a
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`copy of the within and foregoing SIPCO, LLC and IP CO, LLC’s MOTION FOR
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`LEAVE TO FILE THEIR MOTION TO TRANSFER VENUE AND SUPPORTING
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`MEMORANDUM PARTIALLY UNDER SEAL using the Court’s ECF filing
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`system, which will automatically send a copy to all counsel of record
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`registered to receive service thereby, and also by U.S. Mail, postage prepaid,
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`upon the following:
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`Donald L. Jackson
`James D. Berquist
`J. Scott Davidson
`Davidson Berquist Jackson & Gowdey, LLP
`8300 Greensboro Drive, Suite 500
`McLean, Virginia 22102
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`William V. Custer
`Damon J. Whitaker
`Bryan Cave, LLP
`One Atlantic Center, Fourteenth Floor
`1201 W. Peachtree St., N.W.
`Atlanta, Georgia 30309
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`Ryan T. Pumpian
`Bloom Sugarman LLP
`977 Ponce de Leon Ave., NE
`Atlanta, Georgia 30306
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`J. Christopher Fox, II
`J. Christopher Fox, II
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`5
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