`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TEXARKANA DIVISION
`
`MAXELL, LTD.,
`
`
`
`Plaintiff
`
`Civil Action No. 5:19-cv-00036-RWS
`
`v.
`
`APPLE INC.,
`
`
`
`Defendant.
`
`JURY TRIAL DEMANDED
`
`
`
`APPLE INC.’S UNOPPOSED MOTION TO REDACT THE
`SEPTEMBER 17, 2019 MOTIONS HEARING TRANSCRIPT
`
`Defendant Apple Inc. (“Apple”) requests that the Court redact a limited portion of the
`
`transcript from the September 17, 2019 motions hearing, which involved discussions of
`
`confidential (1) statements that revealed explicit details regarding Apple’s patent-licensing
`
`agreements with third parties. Each of these agreements is subject to a Non-Disclosure Agreement
`
`that requires Apple to maintain the confidentiality of information related thereto; and (2) the public
`
`disclosure of confidential details regarding Apple’s patent-licensing agreements with third-parties
`
`would harm the ability of Apple and said third-parties to protect the confidential nature of the
`
`agreements.
`
`Apple respectfully requests that the Court redact the transcript as outlined below:
`
`Page(s):Line(s)
`
`Description of portions to be filed under seal
`
`71:25
`
`77:3-4
`
`
`
`Reference to information derived from confidential patent license
`agreement with third-parties which is information protected under
`protective order.
`
`Reference to information derived from confidential patent license
`agreement with third-parties which is information protected under
`protective order.
`
`
`
`Case 5:19-cv-00036-RWS Document 131 Filed 11/16/19 Page 2 of 3 PageID #: 5549
`
`
`
`Plaintiff has represented that they do not oppose this motion. A redacted version of the
`
`hearing transcript is attached as Exhibit A.
`
`
`
`November 16, 2019
`
`
`/s/ Melissa R. Smith
`
`
`
`Luann L. Simmons (Pro Hac Vice)
`lsimmons@omm.com
`O’MELVENY & MYERS LLP
`Two Embarcadero Center
`28th Floor
`San Francisco, CA 94111
`Telephone: 415-984-8700
`Facsimile: 415-984-8701
`
`Xin-Yi Zhou (Pro Hac Vice)
`vzhou@omm.com
`Anthony G. Beasley (TX #24093882)
`tbeasley@omm.com
`O’MELVENY & MYERS LLP
`400 S. Hope Street
`Los Angeles, CA 90071
`Telephone: 213-430-6000
`Facsimile: 213-430-6407
`
`Laura Bayne Gore (Pro Hac Vice)
`lbayne@omm.com
`O’MELVENY & MYERS LLP
`Times Square Tower, 7 Times Square
`New York, NY 10036
`Telephone: 212-326-2000
`Facsimile: 212-326-2061
`
`Melissa R. Smith (TX #24001351)
`melissa@gilliamsmithlaw.com
`GILLIAM & SMITH, LLP
`303 South Washington Avenue
`Marshall, Texas 75670
`Telephone: (903) 934-8450
`Facsimile: (903) 934-9257
`
`Attorneys for Defendant Apple Inc.
`
`2
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`Case 5:19-cv-00036-RWS Document 131 Filed 11/16/19 Page 3 of 3 PageID #: 5550
`
`
`
`CERTIFICATE OF SERVICE
`
`
`
`The undersigned hereby certifies that all counsel of record who are deemed to have
`
`consented to electronic service are being served with a copy of this document via the Court's
`
`CM/ECF system per Local Rule CV-5(a)(3) on November 16, 2019.
`
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`
`
`/s/ Melissa R. Smith
`Melissa R. Smith
`
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