`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`
`
`C.A. No. 13-919-JLH
`
`
`
`
`
`
`)))))))))
`
`
`
`ARENDI S.A.R.L.,
`
`
`
`
`
`GOOGLE LLC,
`
`
`
`Plaintiff,
`
`
`
`v.
`
`
`
`Defendant.
`
`DECLARATION OF GABE MATTERA IN SUPPORT OF GOOGLE’S MOTION TO
`REDACT TRANSCRIPT AND SEAL CERTAIN EXHIBITS
`
`POTTER ANDERSON & CORROON LLP
`
`David E. Moore (#3983)
`Bindu A. Palapura (#5370)
`Andrew L. Brown (#6766)
`Hercules Plaza, 6th Floor
`1313 N. Market Street
`Wilmington, DE 19801
`Tel: (302) 984-6000
`dmoore@potteranderson.com
`bpalapura@potteranderson.com
`abrown@potteranderson.com
`
`Attorneys for Defendant Google LLC
`
`OF COUNSEL:
`
`Robert W. Unikel
`John Cotiguala
`Matt Lind
`PAUL HASTINGS LLP
`71 South Wacker Drive, Suite 4500
`Chicago, IL 60606
`Tel: (312) 449-6000
`
`Robert R. Laurenzi
`Chad J. Peterman
`PAUL HASTINGS LLP
`200 Park Avenue
`New York, NY 10166
`Tel: (212) 318-6000
`
`Ginger D. Anders
`MUNGER, TOLLES & OLSON LLP
`601 Massachusetts Avenue NW, Suite 500E
`Washington, D.C. 20001
`Tel: (202) 220-1100
`
`Vincent Y. Ling
`MUNGER, TOLLES & OLSON LLP
`350 S. Grand Avenue, 50th Floor
`Los Angeles, CA 90071
`Tel: (213) 683-9100
`
`Dated: May 3, 2023
`10789325 / 12599.00040
`
`
`
`
`
`
`
`
`Case 1:13-cv-00919-JLH Document 536 Filed 05/03/23 Page 2 of 3 PageID #: 53734
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`C.A. No. 13-919-JLH
`
`ARENDIS.A.R.L.,
`
`Plaintiff,
`
`V.
`
`GOOGLE LLC,
`
`Defendant.
`
`Apps from 2011-2018, including Gmail, Docs, Chrome, Drive and Calendar.
`
`Devices & Services. Devices & Services includes Google’s Pixel devices.
`2.
`I am providingthis devant to describe the extraordinarily sensitive and valuable
`
`DECLARATION OF GABE MATTERA IN SUPPORT OF
`
`I, Gabriel Mattera, declare as follows:
`
`Li
`
`Tam a Finance Director at Google, where I have been employed since September4, 2007.
`
`Aspart of my duties at Google, I am responsible for Central Financial Planning & Analysis for
`
`nature of Google’s highly confidential financial information. This declaration is based on my
`
`personal knowledge.
`
`3.
`
`I have revieweda partially redacted copy ofthe trial transcript for the proceedings on
`
`_ May 1, 2023. I also reviewed two exhibits introduced into evidence bythe plaintiff, exhibits 36
`
`and 37. Thetranscript and exhibits contain highly confidential financial information of Google,
`
`including U.S. revenues for Pixel devices from 2017-2018, and U.S. revenues for certain Google
`
`
`
`Case 1:13-cv-00919-JLH Document 536 Filed 05/03/23 Page 3 of 3 PageID #: 53735
`
`While Google makes somefinancial information availableto the publicinits public
`4,
`financial statements, Googledoesnot provide publicly the detailed breakdowns ofUSS. only
`
`product-basedfinancial information asit was discussed duringthis trial.
`Public disclosure of the aforementioned information would severely harm Google
`
`De
`
`becausethe information couldbe usedadversely by Google’s competitors. For example,
`visibility into Google highly confidential dBnsumen revenues, ifcombined with data on unit
`sales, would give competitors an understandingofGoogle’s ee pricing and unit economics,
`and allow them to formulate specific pricing/discounting strategies for their own products. In
`
`Gabriel Mattera
`
`addition, knowledge of Google’s highly confidential financial information for these Pixel and
`
`Appsproducts that is more geographically limited than whatis publicly reported would provide
`
`competitors with detailed information as to the success or failure of those products with
`customersin the U.S., and would give competitors better insights into how they should focus
`their own productstrategies in order to better compete with Google in different geographic
`
`markets.
`
`6.
`
`Only by keeping this highly confidential financial information in the strictest of
`
`confidence can Google protectitself from adverse exploitation ofits highly confidential financial
`
`information by its competitors.
`
`"I declare underpenalty of perjury underthe lawsofthe United States of Americathat the
`
`foregoing is true and correct to the best of my knowledge.
`
`Executed this 2nd day of May, 2023 in Washington, DC.
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
