Free Declaration in Support - District Court of California - California

Case 3:07-cv-02769-JL Document 35 Filed 06/22/2007 Page 1 of 2
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 Telephone: 415-591-1000
Facsimile: 415-591-1400
5 Email: [email protected]
[email protected]
6
Attorneys for Plaintiff
7 FRANK NEMIROFSKY
8
UNITED STATES DISTRICT COURT
9
NORTHERN DISTRICT OF CALIFORNIA
10
SAN FRANCISCO DIVISION
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ra. 6% FRANK NEMIROFSKY, ) Case N0. 3:07-CV-02769 — JL
5 § j 12 ) Hon. Magistrate James Larson
§ g QF Plaintiff, )
E ss 2 13 ) DECLARATION OF JONATHAN M.
5 § Q vs. ) COHEN RE SEALING DOUCMENTS
°U §) 14 ) PURSUANT TO CIV. L.R. 79—5(B), (C) AND
5 3 E SEOK KI KIM; STV ASIA, LTD. a British ) (D)
_'§ 2 E 15 Virgin Islands corporation; and DOES 1 )
B g through 20, inclusive, )
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Defendants. )
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28 DECLARATION OF JONATHAN M. COHEN RE SEALING DOCUMENTS
CASE NO. 3:07-CV-02769 JL

Case 3:07-cv-02769-JL Document 35 Filed 06/22/2007 Page 2 of 2
l I, Jonathan M. Cohen, declare as follows:
2 l. I am an attomey at law, admitted to practice in this Court for this matter. I am a
3 capital partner with the law firm of Winston & Strawn, LLP, counsel of record for Plaintiff
4 Nemirofsky, and am authorized to make this Declaration in that capacity.
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 Nemirofsky contain the confidential
3 settlement agreement that arose out of the PRN litigation as well as confidential information related
9 to the same. Distribution of such information by Nemirofsky would put Nemirofsky in a position
IQ whereby he would be in violation of the confidentiality agreement reached as part of the settlement.
Q 11 Furthermore, the information as to the value of the settlement would be useful to potential
E 12 competitors and infringers who would learn Nemirofsky, STD, PRN and/or Best Buy's position
E i` 13 concerning the value of the patented technology.
§ E 14 4. It is my Lmderstanding that the information in the documents sought to be filed under
T; E 15 seal has been kept confidential and was not intended to be viewed by the general public.
B 5 16 Accordingly, it my understanding that any disclosure of these documents would be harmful to the
17 parties and would violate the PRN litigation settlement agreement. 3
18 I declare under penalty of perjury under the laws of the United States of America that the
19 foregoing is true and correct.
20 Executed in San Francisco, California this 22nd day of June, 2007.
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JON AN M. COHEN ·
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CASE.NO. 3:07-CV—02769 IL

Case 3:07-cv-02769-JL

Document 35

Filed 06/22/2007

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Case 3:07-cv-02769-JL

Document 35

Filed 06/22/2007

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