Free Declaration in Support - District Court of California - California

Case 3:07-cv-02769-JL Document 55 Filed 06/30/2007 Page 1 of 2 A
1 Jonathan M. Cohen (SBN: 168207)
Martin Sabelli (SBN: 164772)
2 Robyn T. Callahan (SBN: 225472)
WINSTON & STRAWN LLP
3 101 California Street
San Francisco, CA 9411 1-5894 ‘
4 t Telephone: 4.15-591-1000 . . I.;
Facsimile: 415-591-1400
5 Email: [email protected]
[email protected]
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Attorneys for Plaintiff
7 FRANK NEMIROFSKY
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN FRANCISCO DIVISION
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ca § FRANK NEMIROFSKY, ) Case N0. 3:07-CV-02769 - JL
E1 § j 12 ) Hon. Magistrate James Larson
E g gi Plaintiff, )
E .a < 13 ) DECLARATION OF ROBYN T.
5 § Q vs. ) CALLAHAN RE SEALING DOUCMENTS
°8 § 14 ) PURSUANT TO CIV. L.R. 79-5(B), (C) AND
§ Q E SEOK KI KIM; STV ASIA, LTD. a British ) (D)
_§ 2 E 15 Virgin Islands corporation; and DOES 1 )
B g through 20, inclusive, )
Defendants. )
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28 DECLARATION OF ROBYN T. CALLAHAN RE SEALING DOCUMENTS
CASE NO. 3:07-CV—02769 JL

Case 3:07-cv-02769-JL Document 55 Filed 06/30/2007 Page 2 of 2
l I, Robyn T. Callahan, declare as follows:
2 1. I am an attorney at law, admitted to practice in this Court for this matter. I am an
3 associate with the law firm of Winston & Strawn, LLP, counsel of record for Plaintiff Nemirofsky,
4 yy and am authorized to make this Declaration in that capacity. y
5 2. I submit this Declaration under Local Rule 79-5(b), (c), and (d) in support of the
6 sealing of portions of certain documents that have been previously designated "confidential."
7 3. The items sought to be filed under seal by Plaintiff contain information regarding the
g confidential settlement agreement that arose out of the PRN litigation. Distribution of such
9 information by Plaintiff would put Plaintiff in a position whereby he would be in violation of the
11) confidentiality agreement reached as part of the settlement. Furthermore, the information as to the
Q 11 value of the settlement would be useful to potential competitors and infringers who would learn
E E 12 Plaintiff, STD, PRN and/or Best Buy's position concerning the value of the patented technology.
I; il 13 4. It is my understanding that the information in the doctunents sought to be filed under
§ E 14 seal has been kept confidential and was not intended to be viewed by the general public.
2 g 15 Accordingly, it my understanding that any disclosure of these documents would be harmful to the
B 5 16 parties and would violate the PRN litigation settlement agreement.
17 I declare under penalty of perjury under the laws of the United States of America that the
18 foregoing is true and correct.
19 Executed in San Francisco, California this 29th day of June, 2007.
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ROBYN . CALLAHAN
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CASE NO. 3:07-CV-02769 JL

Case 3:07-cv-02769-JL

Document 55

Filed 06/30/2007

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Case 3:07-cv-02769-JL

Document 55

Filed 06/30/2007

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