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Case 5:19-cv-00036-RWS Document 51 Filed 07/31/19 Page 1 of 3 PageID #: 585
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TEXARKANA DIVISION
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`MAXELL, LTD.,
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`Plaintiff,
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`vs.
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`APPLE INC.,
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`Defendant.
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` Civil Action No. 5:19-cv-00036-RWS
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`JURY TRIAL DEMANDED
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`APPLE INC.’S UNOPPOSED MOTION FOR LEAVE
`TO FILE DOCUMENTS UNDER SEAL
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`
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`Defendant Apple Inc. (“Apple”) respectfully requests leave to file under seal its Motion To
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`Transfer Venue Pursuant to 28 U.S.C. § 1404(a) and its supporting declarations and exhibits.
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`Apple’s Motion, declarations, and exhibits thereto contain sensitive information about Apple’s
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`business operations and contacts. Plaintiff Maxell, Ltd. (“Maxell”) has informed Apple that
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`Maxell does not oppose its Motion for Leave to File Documents Under Seal.
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`

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`Case 5:19-cv-00036-RWS Document 51 Filed 07/31/19 Page 2 of 3 PageID #: 586
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`July 31, 2019
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`/s/ Luann L. Simmons
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`
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`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.
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`

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`Case 5:19-cv-00036-RWS Document 51 Filed 07/31/19 Page 3 of 3 PageID #: 587
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that all counsel of record who are deemed to have
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`consented to electronic service are being served with a copy of this document via the Court's
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`CM/ECF system per Local Rule CV-5(a)(3) on July 31, 2019.
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` /s/ Melissa R. Smith
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