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    (Additional Counsel Listed On Signature Page.) : SBN SBN SBN SBN

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    Hynix filed a motion requesting permission to file an exhibit under seal. The exhibit contains confidential business and financial information about Hynix's sales revenues and Rambus's license agreements. Hynix argues the motion should be granted because the exhibit was designated confidential by both parties under the protective orders in the case. The motion requests sealing only the portions of the exhibit containing such confidential information.

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    (Additional Counsel Listed On Signature Page.) : SBN SBN SBN SBN

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    sabatino123
    67 views3 pages
    Hynix filed a motion requesting permission to file an exhibit under seal. The exhibit contains confidential business and financial information about Hynix's sales revenues and Rambus's license agreements. Hynix argues the motion should be granted because the exhibit was designated confidential by both parties under the protective orders in the case. The motion requests sealing only the portions of the exhibit containing such confidential information.

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    Hynix filed a motion requesting permission to file an exhibit under seal. The exhibit contains confidential business and financial information about Hynix's sales revenues and Rambus's license agreements. Hynix argues the motion should be granted because the exhibit was designated confidential by both parties under the protective orders in the case. The motion requests sealing only the portions of the exhibit containing such confidential information.

    Copyright:

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    Download as PDF, TXT or read online from Scribd
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    67 views3 pages

    (Additional Counsel Listed On Signature Page.) : SBN SBN SBN SBN

    Uploaded by

    sabatino123
    Hynix filed a motion requesting permission to file an exhibit under seal. The exhibit contains confidential business and financial information about Hynix's sales revenues and Rambus's license agreements. Hynix argues the motion should be granted because the exhibit was designated confidential by both parties under the protective orders in the case. The motion requests sealing only the portions of the exhibit containing such confidential information.

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    of 3

    Case5:00-cv-20905-RMW Document4191 Filed11/20/12 Page1 of 3

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    KENNETH L. NISSLY (SBN 77589) knissly@omm.com SUSAN VAN KEULEN (SBN 136060) svankeulen@omm.com SUSAN ROEDER (SBN 160897) sroeder@omm.com MISHIMA ALAM (SBN 271621) malam@omm.com OMELVENY & MYERS LLP 2765 Sand Hill Road Menlo Park, California 94025 Telephone: (650) 473-2600 Facsimile: (650) 473-2601 KENNETH OROURKE (SBN 120144) korourke@omm.com OMELVENY & MYERS LLP 400 South Hope Street Los Angeles, California 90071-2899 Telephone: (213) 430-6000 Facsimile: (213) 430-6407 [Additional counsel listed on signature page.]

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    SK HYNIXS ADMIN. MOTION FOR LEAVE TO FILE UNDER SEAL CV 00-20905 RMW

    Attorneys for Plaintiffs HYNIX SEMICONDUCTOR INC., HYNIX SEMICONDUCTOR AMERICA INC., HYNIX SEMICONDUCTOR U.K. LTD., and HYNIX SEMICONDUCTOR DEUTSCHLAND GmbH UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION

    HYNIX SEMICONDUCTOR INC., HYNIX SEMICONDUCTOR AMERICA INC., HYNIX SEMICONDUCTOR U.K. LTD., and HYNIX SEMICONDUCTOR DEUTSCHLAND GmbH, Plaintiffs, v. RAMBUS INC., Defendant.

    Case No. CV 00-20905 RMW SK HYNIXS ADMINISTRATIVE MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL PURSUANT TO L.R. 7-11 AND 79-5(d) AND GENERAL ORDER NO. 62

    Case5:00-cv-20905-RMW Document4191 Filed11/20/12 Page2 of 3

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    Pursuant to Civil L.R. 79-5 and 7-11, and General Order No. 62, plaintiffs SK hynix Inc., SK hynix America Inc., SK hynix U.K. Ltd., and SK hynix Deutschland GmbH (collectively, Hynix)1 hereby bring this administrative motion for permission to file under seal Exhibit A to SK hynixs Administrative Motion for Leave to File Reply to Rambuss Brief regarding the Courts Determination of a RAND Rate Pursuant to its September 21, 2012 Order (Administrative Motion). ARGUMENT Exhibit A to the Administrative Motion contains and/or describes information that Hynix and Rambus have designated as Confidential, Special Confidential, Outside Counsel Only, and/or SKh Outside Counsel + Listed Experts Only - For use only in Hynix v. Rambus CV 0020905 under the terms of the protective orders in this case. See D.E. 119 and 4172; see also Declaration of Susan Roeder in Support of Hynixs Administrative Motion to File Under Seal, 3-4. Hynix seeks to file Exhibit A under seal because it contains business and financial information, including information about Hynixs sales revenues and Rambuss license agreements, that the parties have designated confidential. Id. This request is narrowly tailored to seal only those portions of the document that contain such confidential information. /// /// /// /// /// /// /// /// ///

    On October 5, 2012, the parties formerly collectively referred to as Hynix filed an Administrative Motion informing the Court of changes to the parties names. As of the date of filing this motion, the Administrative Motion had not been granted. For ease of reference here, the parties shall continue to be referred to as Hynix.
    SK HYNIXS ADMIN. MOTION FOR LEAVE TO FILE UNDER SEAL CV 00-20905 RMW

    Case5:00-cv-20905-RMW Document4191 Filed11/20/12 Page3 of 3

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    Accordingly, Hynix respectfully requests that the Court Grant its Administrative Motion for Leave to File Document Under Seal.

    Dated: November 20, 2012

    Respectfully submitted, OMELVENY & MYERS LLP By: /s/ Susan Roeder Susan Roeder KENNETH L. NISSLY SUSAN van KEULEN SUSAN ROEDER MISHIMA ALAM OMELVENY & MYERS LLP KENNETH R. OROURKE OMELVENY & MYERS LLP THEODORE G. BROWN III KILPATRICK TOWNSEND & STOCKTON LLP Attorneys for Plaintiffs HYNIX SEMICONDUCTOR INC., HYNIX SEMICONDUCTOR AMERICA INC., HYNIX SEMICONDUCTOR U.K. LTD., and HYNIX SEMICONDUCTOR DEUTSCHLAND GmbH

    7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -2OMM_US:71137291.1

    SK HYNIXS ADMIN. MOTION FOR LEAVE TO FILE UNDER SEAL CV 00-20905 RMW

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