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In Re: Qualcomm Antitrust Litigation, 5:17-md-02773, No. 876 (N.D.Cal. Sep. 29, 2021)
Nonetheless, we also vacate the 23(b)(2) class so that on remand the district court can reconsider certification of the entire class given this court’s FTC v. Qualcomm decision, particularly in light of the threshold requirements of Rule ...
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In Re: Qualcomm Antitrust Litigation, 5:17-md-02773, No. 876 (N.D.Cal. Sep. 29, 2021)
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In Re: Qualcomm Antitrust Litigation, 3:17-md-02773, No. 928 (N.D.Cal. Mar. 6, 2023)
Answer
To the extent a response is required, Qualcomm states that it without knowledge or information sufficient to form a belief as to the truth of the allegations of the first sentence of paragraph 20 of the SAC, and denies it on that basis.
To the extent a response is required, Qualcomm admits that cellular SSOs have IPR policies with provisions that establish the procedures for disclosure of patents that are potentially essential, and denies the remaining allegations set forth in paragraph 45 of the SAC.
all of Qualcomm’s product and services business, including QCT and QCTAP, to supply baseband processor chipsets; Qualcomm denies the remaining allegations set forth in paragraph 54 of the SAC.
Qualcomm states that it is without knowledge or information sufficient to form a belief as to the truth of the remaining allegations set forth in the sixth sentence of paragraph 182 of the SAC, and on that basis denies them.
Qualcomm states that the Motorola internal document speaks for itself, and that it is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph 204 of the SAC, and on that basis denies them.
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In Re: Qualcomm Antitrust Litigation, 3:17-md-02773, No. 928 (N.D.Cal. Mar. 6, 2023)
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In Re: Qualcomm Antitrust Litigation, 3:17-md-02773, No. 906 (N.D.Cal. Oct. 17, 2022)
Motion to Dismiss (Demurrer)
In an effort to create daylight where none exists, Plaintiffs rely heavily on a single California Supreme Court case, In re Cipro Cases I & II, 61 Cal.
None of that is relevant here because Plaintiffs aren’t trying to prove any antitrust conspiracy.
Searching for a difference where none exists, Plaintiffs link their “NLNC Tying” allegation to supposed “exclusive deals” with OEMs other than Apple.
None of that made the agreement injurious to competition.
None of Plaintiffs’ cited cases is to the contrary.
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In Re: Qualcomm Antitrust Litigation, 3:17-md-02773, No. 906 (N.D.Cal. Oct. 17, 2022)
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In Re: Qualcomm Antitrust Litigation, 3:17-md-02773, No. 899 (N.D.Cal. Sep. 2, 2022)
Complaint
... Apple’s exclusivity agreement with Qualcomm did not reward Apple for its exclusivity with prices that were discounted from the prices paid by other customers, but rather threatened Apple with prices above those paid by nonexclusive ...
Nonetheless, throughout that time period, Qualcomm continued to collect cellular SEP royalties based on a standard 5% of the total price of finished devices.
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In Re: Qualcomm Antitrust Litigation, 3:17-md-02773, No. 899 (N.D.Cal. Sep. 2, 2022)
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In Re: Qualcomm Antitrust Litigation, 3:17-md-02773, No. 943 (N.D.Cal. Apr. 28, 2023)
Apple nonetheless requests that, in accordance with Civil Local Rule 79-5(f), the parties provide clear notice to nonparties like Apple of information they have designated confidential that the parties intend to file, and to coordinate with ...
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In Re: Qualcomm Antitrust Litigation, 3:17-md-02773, No. 943 (N.D.Cal. Apr. 28, 2023)
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In Re: Qualcomm Antitrust Litigation, 3:17-md-02773, No. 942 (N.D.Cal. Apr. 27, 2023)
Civil Local Rule 79-5, Third Party Motorola Mobility LLC (“Motorola”) hereby submits this Statement supporting why its confidential information contained in Exhibits 1 and 2 to the Harris Declaration (Docket Entries (“DE”) 936-2 & 936-3; also at DE 937-2 & 937-3-1 & 900-2, and DE 901-2 & 901-3) should be filed under seal (the “Statement”).
Feb. 18, 2011) (citing Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1178 (9th Cir. 2006) “Thus, a showing of good cause will suffice to justify sealing material attached to non-dispositive motions.” Id.
Good cause exists to retain the confidential status of Motorola’s financial, proprietary, and other business information found in Exhibits 1 (the “Expert Report”) and 2 (the “Reply Report”) to the Harris Declaration (the “Exhibits”).
This would cause Motorola significant financial harm with respect to its ability to compete with its competitors, as well as its relationships with current and prospective business partners.
For the foregoing reasons, Third Party Motorola respectfully requests the Court keep sealed its confidential information found in the following: as to Exhibits 1 (the “Expert Report”) and 2 (the “Reply Report”) to the Harris Declaration (the “Exhibits”).
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In Re: Qualcomm Antitrust Litigation, 3:17-md-02773, No. 942 (N.D.Cal. Apr. 27, 2023)
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In Re: Qualcomm Antitrust Litigation, 3:17-md-02773, No. 941 (N.D.Cal. Apr. 17, 2023)
While Samsung has no way of confirming that it has received all of the relevant material referencing its confidential information in the two Elhauge reports at issue here, Samsung nonetheless respectfully seeks to seal a small portion of ...
“None of the confidential terms of the contemplated joint venture – including the amount or proportion of Samsung’s contemplated investment in the venture, or the value of such investment as a proportion of the total venture – were ...
None of the confidential terms of the contemplated joint venture – including the amount or proportion of Samsung’s contemplated investment in the venture, or the value of such investment as a proportion of the total venture – were ...
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In Re: Qualcomm Antitrust Litigation, 3:17-md-02773, No. 941 (N.D.Cal. Apr. 17, 2023)
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In Re: Qualcomm Antitrust Litigation, 3:17-md-02773, No. 939 (N.D.Cal. Apr. 12, 2023)
In September, Plaintiffs filed an Administrative Motion to Consider Whether Another Party’s Material Should be Sealed (Dkt. 900) regarding two expert reports, which were submitted as exhibits to Plaintiffs’ Opposition to Qualcomm’s Motion to Dismiss Plaintiff’s Second Amended Complaint (Dkt. 901).
On April 7, Qualcomm filed a motion for summary judgment (Dkt. 936), which included the same two expert reports submitted as exhibits to Plaintiffs’ Opposition to Qualcomm’s Motion to Dismiss Plaintiff’s Second Amended Complaint.
Plaintiffs wish to coordinate with third parties so that confidential information can be sealed consistently in the two expert reports that are the subject of both motions.
In order to permit non-parties sufficient time to coordinate consistent motions to seal and statements in support thereof, Plaintiffs request, and Qualcomm stipulates to, an order extending the deadline for third parties to submit statements in support of their Administrative Motions to Consider Whether Another Party’s Material Should be Sealed until April 28, 2023.
Pursuant to Civil Local Rule 5-1(h)(3) regarding signatures, I attest that concurrence in the filing of this document has been obtained from the other signatories.
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In Re: Qualcomm Antitrust Litigation, 3:17-md-02773, No. 939 (N.D.Cal. Apr. 12, 2023)
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In Re: Qualcomm Antitrust Litigation, 3:17-md-02773, No. 895 (N.D.Cal. Aug. 1, 2022)
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In Re: Qualcomm Antitrust Litigation, 3:17-md-02773, No. 895 (N.D.Cal. Aug. 1, 2022)
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In Re: Qualcomm Antitrust Litigation, 3:17-md-02773, No. 937 (N.D.Cal. Apr. 7, 2023)
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In Re: Qualcomm Antitrust Litigation, 3:17-md-02773, No. 937 (N.D.Cal. Apr. 7, 2023)
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In Re: Qualcomm Antitrust Litigation, 3:17-md-02773, No. 935 (N.D.Cal. Apr. 7, 2023)
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In Re: Qualcomm Antitrust Litigation, 3:17-md-02773, No. 935 (N.D.Cal. Apr. 7, 2023)
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In Re: Qualcomm Antitrust Litigation, 3:17-md-02773, No. 938 (N.D.Cal. Apr. 7, 2023)
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In Re: Qualcomm Antitrust Litigation, 3:17-md-02773, No. 938 (N.D.Cal. Apr. 7, 2023)
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In Re: Qualcomm Antitrust Litigation, 3:17-md-02773, No. 933 (N.D.Cal. Mar. 27, 2023)
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In Re: Qualcomm Antitrust Litigation, 3:17-md-02773, No. 933 (N.D.Cal. Mar. 27, 2023)
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In Re: Qualcomm Antitrust Litigation, 3:17-md-02773, No. 934 (N.D.Cal. Mar. 27, 2023)
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In Re: Qualcomm Antitrust Litigation, 3:17-md-02773, No. 934 (N.D.Cal. Mar. 27, 2023)
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In Re: Qualcomm Antitrust Litigation, 3:17-md-02773, No. 931 (N.D.Cal. Mar. 17, 2023)
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In Re: Qualcomm Antitrust Litigation, 3:17-md-02773, No. 931 (N.D.Cal. Mar. 17, 2023)
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