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Appellate Practice

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Attorney Advertising









Appellate Practice

Quinn Emanuel has an extensive nationwide appellate practice that focuses on briefing and arguing

significant cases before the United States Supreme Court, the federal courts of appeals (particularly

the Second, Ninth and Federal Circuits), as well as intermediate courts of appeal and high courts of

California, New York and other states. Our appellate experience spans all areas of our practice, from

copyright, patent, trademark and trade secret law to arbitration, bankruptcy, business tort, contract,

financial products, real estate and securities law. We have special expertise in appeals involving

criminal law and all aspects of constitutional law.



Our appellate practice is headed by Kathleen M. Sullivan, a professor at and former Dean of

Stanford Law School and one of the nation's most highly regarded appellate advocates. Recognized

by the National Law Journal as one of “The 100 Most Influential Lawyers in America,” by the Daily

Journal as one of “The 100 Most Influential Lawyers in California,” and by the Daily Journal as one

of "The 75 Top Women Litigators in California," Ms. Sullivan has argued numerous high profile

appeals before the United States Supreme Court, including a nationally prominent victory for the

direct shipment of wine from wineries to consumers in other states, as well as numerous federal and

state courts.



Ms. Sullivan's appellate team includes Daniel H. Bromberg, an experienced appellate attorney who

has argued in the U.S. Supreme Court and other federal and state courts of appeals; Susan R. Estrich,

a nationally renowned law professor at the University of Southern California and appellate attorney

who was the first woman president of the Harvard Law Review and clerked for Justice John Paul

Stevens; and Sanford I. Weisburst, who clerked for Justice Clarence Thomas and has briefed and

argued several appellate cases in federal and state court. Quinn Emanuel's lawyers also include

numerous other former U.S. Supreme Court and circuit court law clerks and Assistant U.S.

Attorneys who collectively have argued hundreds of successful federal and state appeals.



RECENT REPRESENTATIONS

SUPREME COURT OF THE UNITED STATES:



 We represented Shell Oil Company in an 8-1 victory in the U.S. Supreme Court in

Burlington Northern & Santé Fe Railway v. United States, which held that Shell

cannot be held liable as an “arranger” under CERCLA for merely shipping useful

chemicals.”



 In Granholm v. Heald, our lawyers obtained a 5-4 victory in the U.S. Supreme Court

on behalf of California vintners and Michigan consumers challenging state laws

imposing discriminatory restrictions on interstate shipments of wine. The Court held

that the Twenty-First Amendment does not give states license to interfere with the

national market in a way that violates the Dormant Commerce Clause.

quinn emanuel urquhart & sullivan, llp



Los Angeles • New York • San Francisco • Silicon Valley • Chicago • Tokyo • London • Mannheim



Prior results do not guarantee a similar outcome.

 We filed an amicus brief on behalf of the New York Stock Exchange and

NASDAQ in Stoneridge Investment Partners, the U.S. Supreme Court decision

rejecting judicially implied private rights of action against third-party vendors under

the securities laws. The brief, which the Court expressly cited in its opinion, argued

that allowing such "participant" liability would weaken the global competitiveness of

the nation's capital markets by raising the cost of doing business with publicly traded

companies.



 Our appellate attorneys, working together with our deeply experienced patent

attorneys, have filed amicus briefs supporting the prevailing position in nearly every

recent patent case before the U.S. Supreme Court, including eBay v. MercExchange,

KSR v. Teleflex, Labcorp v. Metabolite, and Quanta Computer v. L.G. Electronics.

Our clients on these briefs, including Time Warner, AOL, Amazon.com, Viacom,

Nokia, Google, Cisco, Xerox, IAC/Interactive, Infineon, Chevron, Shell, Visa,

and Affymetrix, have thus been able to make sophisticated contributions to the high

court's recent focus on patent law.



LOWER FEDERAL AND STATE APPELLATE COURTS:



ALIEN TORT STATUTE



 We represented The Coca-Cola Company in the Eleventh Circuit, successfully

defending the district court’s dismissal of a complaint asserting claims under the

Alien Tort Statute and Torture Victims Protection Act arising out of violence

committed by Colombian paramilitaries in and around the Colombian plants of The

Coca-Cola Company’s Colombian bottling partners. In a lengthy, published

decision, the Eleventh Circuit held that the plaintiffs had failed, under the Supreme

Court’s decision on pleading standards in Ashcroft v. Iqbal, adequately to allege a

link between the paramilitaries and the Colombian government; such a link is

required to satisfy the state-action element of these statutes.



 We also represented The Coca-Cola Company in the Second Circuit, successfully

defending the district court’s dismissal of a complaint asserting ATS and other

claims under the forum non conveniens doctrine. The complaint concerned police

action against union members that occurred in Istanbul, Turkey, allegedly at the

behest of The Coca-Cola Company’s Turkish bottling partner. The Second Circuit

affirmed the district court’s dismissal because, among other things, virtually all of

the relevant evidence and witnesses were to be found in Turkey, and it would

therefore be more convenient to litigate the case there.



 We represent Pfizer Inc. in the Supreme Court of the United States, where it is

seeking review by certiorari petition of an adverse Second Circuit decision that

sustained ATS claims against Pfizer arising out of a clinical drug trial that Pfizer

conducted in Nigeria. The petition argues, among other things, that the Supreme

Court should clarify confusion among the lower courts as to the sort of link that is

required to satisfy the state-action element of an ATS claim. We successfully





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persuaded the Second Circuit to grant a stay of its mandate (thus staying further

proceedings in the trial court) until the Supreme Court disposes of the case.



BUSINESS TORTS, CONTRACTS, AND SECURITIES



 We represent AIG in appeals on behalf of its reinsurance companies in both the

Second and the Ninth Circuits, in one appeal challenging a $443 million arbitration

award granted after an unusual secret hearing and one appeal challenging a verdict

after bench trial concerning disputed reinsurance obligations.



 We represented Allegheny Energy before the Second Circuit, succeeding in

overturning a $158 million judgment after bench trial for Merrill Lynch and

reinstating $350 million in counterclaims by Allegheny in a complex commercial

contract dispute involving acquisition of an energy trading business. On remand, we

took over as trial counsel for Allegheny and secured a favorable settlement.



 We represented Mexico's Grupo Televisa, the largest media company in the

Spanish-speaking world, in a case against Florida-based Telemundo for tortious

interference with Televisa's exclusive agreement with one of Spanish-language

television's biggest stars. In 2005, the U.S. District Court for the Southern District of

Florida had granted summary judgment to Telemundo, holding that Televisa's claims

were governed by Mexican law, which does not recognize the interference tort. We

convinced an Eleventh Circuit panel to reverse unanimously in a decision with broad

ramifications for the many Latin American companies that do business in Florida.



 We represented 212 Investment Partnership in a suit against an attorney who

fraudulently preferred personal transactions above those of the partnership he

represented. The trial court had dismissed claims against the attorney on statute of

limitations grounds, and we convinced the New York Appellate Division to reverse

and reinstate the claims.



 We represented AOL Time Warner in the Homestore.com securities litigation,

successfully arguing at the district court, on appeal to the Ninth Circuit, and again on

remand that Section 10(b) and Rule 10b-5 of the securities laws do not permit third-

party "participant" liability--anticipating the successful outcome of the Stoneridge

Investment Partners decision in the U.S. Supreme Court.



 We were asked by the Second Circuit to brief and present oral argument as amicus

curiae on behalf of individual pro se debtors in a case involving an issue of first

impression under the Bankruptcy Abuse Prevention and Consumer Protection Act of

2005, providing the court with a counterweight to the analysis of the United States

Trustee.



 We represent a pioneer in the Internet industry in the Ninth Circuit in a challenge to

an arbitration award imposing $20 million punitive damages award in an action

concerning breach of fiduciary duty and conversion.





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COPYRIGHT



 We successfully defended Time Warner Entertainment and HBO against a $56

million copyright infringement action alleging theft of the ideas for the television

show "Six Feet Under." After we won summary judgment on the ground that any

similarities to the plaintiff's screenplay were too abstract to be copyrightable, the

Ninth Circuit affirmed in a published opinion that is now the leading articulation of

the proper procedure for evaluating such claims in a television or motion picture

context.



CONSTITUTIONAL AND CIVIL RIGHTS



 We represented the Kamehameha Schools, the world's largest private K-12

educational trust, obtaining a major en banc victory in the Ninth Circuit by a vote of

8-7. The Schools, left by one of Hawaii's last monarchs for the benefit of Native

Hawaiian schoolchildren, were sued by a non-native Hawaiian applicant challenging

the Schools' admission policy as “race discrimination in contracting” in violation of

the nation's oldest civil rights act, 42 U.S.C. § 1981.



 We represented a pro se plaintiff whose complaint alleging race discrimination under

the Fair Housing Act had been dismissed, and persuaded the Second Circuit that no

heightened pleading requirement exists for civil rights complaints alleging racial

discrimination.



PATENTS



 We won affirmance of summary judgment of non-infringement for Google in a

patent infringement litigation in which plaintiff sought in excess of $150 million in

past damages and a royalty on future revenue in the billions. The litigation

concerned the AdWords auction system used by Google to sell advertisement space

on search results pages for Google.com and partner sites. AdWords is by far the

major source of revenue for Google, so this case went to the heart of its business.



 We represent Genentech, Inc. in an ongoing patent infringement suit initially

brought by Sanofi-Aventis Deutschland in the Eastern District of Texas. After the

district court denied Genentech’s motion to transfer, we successfully petitioned the

Federal Circuit for a writ of mandamus to direct the Texas court to transfer the case

to the Northern District of California.



 We represented Nike in its defense of a $40 million design patent and trade dress

action brought by a rival shoe company over the translucent heel piece on Nike’s Air

Jordan XVII basketball shoe. After our consumer survey persuaded the plaintiff to

dismiss its trade dress claim, the court adopted our proposed patent claim

construction on the design of the heel piece and granted summary judgment of non-

infringement to Nike. We then represented Nike on appeal. Following a nearly







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hour-long argument centered on the use of broken lines to signify boundaries in

design patents, the Federal Circuit affirmed the judgment in our client’s favor.



 We represented Brøderbund Software and Intuit Inc., two of the largest U.S.

consumer software publishers, in Interactive Gift Express, Inc. v. CompuServe Inc.,

widely recognized as the test case concerning business method patents and claims of

ownership to Internet commerce. Apart from prevailing sufficiently to obtain

summary judgment on remand, the case also established numerous appellate

standards for the Federal Circuit, including those governing judicial estoppel and

waiver in appeals from a district court's claims construction.



 We represented GameTech International in Planet Bingo LLC v. GameTech

International, Inc., where the Federal Circuit established a new standard for

determining infringement under the doctrine of equivalents that focused the analysis

on the foreseeability of the asserted equivalent, before affirming a pre-trial judgment

in favor of Gametech on both non-infringement and invalidity grounds.



 We represented Bancorp Services in a case where the Federal Circuit reversed a

trial court’s finding of invalidity of our client’s patent. In obtaining reversal, our

lawyers faced an opposing appellate team that included two former Solicitors

General of the United States.



 We represented Nokia in a case brought by Qualcomm claiming infringement of

patents covering basic telecommunications technology used in cellular telephones.

In an appeal to the Federal Circuit, we obtained a ruling that the arbitrability of

certain licensing issues was for the arbitrator to decide and set the standard for

review for such issues.



 We represented Epson in the Federal Circuit's per curiam affirmance of the

exclusion and cease-and-desist orders issued by the International Trade Commission

finding that certain printer ink cartridges manufactured in China and elsewhere

infringe upon Epson's patents and prohibiting their importation into the United

States.



 Just one day after oral argument, the Federal Circuit affirmed our defense jury

verdict of patent invalidity and non-infringement for RealNetworks in a five-week

trial in which the plaintiff had sought in excess of $200 million in damages.



 We represented cellular telephone companies Motorola, Inc., BenQ America

Corp., and Hon Hai Precision Industry Co., Ltd., and Chi Mei Communication

Systems, Inc. in Board of Regents of the University of Texas System v. BenQ

America Corp., Inc., 533 F.3d 1362 (Fed. Cir. 2008). After briefing and argument,

the Federal Circuit affirmed the district court's claim constructions and award of

summary judgment of non-infringement in favor of our clients. The opinion limited

patentee's ability to rely on the open-ended transitional phrase "comprising" to

obtain a judgment of infringement where the accused device practices additional,





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unclaimed steps. The Court relied on our argument that the prosecution history and

the narrow language employed in the claim prohibited the patentee from relying on

the word "comprising" to broaden the scope of the claims.



 We represented Netscape Communications Corp and AOL in a declaratory

judgment action seeking to invalidate a patent that effectively claimed the internet

itself. The district court granted the declaratory judgment plaintiffs' motion for

summary judgment under the on sale bar and public use doctrines. The patentee

appealed. After briefing and argument, we obtained a complete affirmance from the

Federal Circuit.



 We represented Bancorp Services, L.L.C. in the appeal of an adverse summary

judgment of non-infringement. We persuaded the Federal Circuit that the district

court's claims construction was improper, and that the district court had erroneously

credited the opposing expert over our client's own on summary judgment. The

Federal Circuit vacated the summary judgment and remanded the case.



TRADEMARKS



 We represent Payless ShoeSource, Inc. in the Ninth Circuit in an appeal of a $66

million judgment in favor of adidas America, Inc. and adidas AG for trademark and

trade dress infringement. After a jury trial, Payless was found liable for selling two-

and four-striped shoes that adidas contended infringed its trademark rights in three-

stripe athletic shoes and trade-dress rights in one of its athletic-shoe designs. Our

appeal, which is fully briefed and awaiting argument, challenges the jury's finding

of liability, the damages award, and the scope of the district court's injunction.



 We represented George V and Creative Designs, owners of the world-famous (and

federally-registered) BUDDHA-BAR trademark and proprietary restaurant concept

in a case they brought against their former licensee for trademark infringement and

dilution regarding their unauthorized use of the BUDDHA BAR trademark and

concept in connection with a Manhattan restaurant. The Appellate Division of the

Supreme Court, First Department, reversed the trial court's denial of our

clients' motion for preliminary injunction and held that the small disclaimer placed

on defendant's website was not sufficient to dispel likely consumer confusion.



 We won an appeal in the Third Circuit on behalf of LendingTree arising in the

context of a trademark and false advertising suit filed in New Jersey federal court by

a competitor to shut down LendingTree's marketing of an innovative online real

estate broker network. Presenting an issue of first impression in the Third Circuit,

we persuaded the court to adopt a modified version of the doctrine of "nominative

use" as a defense to trademark infringement, resulting in the vacatur of a preliminary

injunction issued by the district court.









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 We represent a major foreign government agency in the Second Circuit in a dispute

concerning the ownership of a well known liquor trademark worth more than $1

billion.



 We represent The Walt Disney Company and Pixar Animation before the Ninth

Circuit in connection with an appeal from the dismissal of a copyright and unfair

competition action relating to the hit movie "Finding Nemo."



 We represent the Washington Redskins in the long running challenge by six Native

American petitioners alleging disparagement to the Redskins' federal trademark

registrations. In a little used "de novo" appeal to the D.C. District Court, we

succeeded in overturning an adverse decision by the Trademark Trial and Appeal

Board. We are presently briefing the D.C. Circuit on the issue of whether claims

brought by one of the petitioners were barred by laches. We previously prevailed on

this issue before the District Court.



 We represent the Academy of Television Arts & Sciences in the New York

appellate courts in connection with an expedited appeal taken by the National

Academy of Television Arts & Sciences from the lower court's dismissal of its

petition to vacate an arbitral award prohibiting the unauthorized proliferation of new

EMMY award categories for broadband programming and programming created for

new distribution platforms such as iPhones and Blackberries.



OTHER NOTABLE CASES:



 Quinn Emanuel represented Shell Offshore Inc. and Shell Gulf of Mexico Inc.

(Shell) in expedited proceedings in the Ninth Circuit where environmental NGOs

challenged the Mineral Management Service’s (MMS) approval of Shell’s plans for

exploratory drilling for oil and natural gas in the Alaskan Arctic in Summer 2010.

Shell turned to Quinn Emanuel to defend MMS’s approval of its 2010 plan after the

company had received an adverse decision from the Ninth Circuit regarding its

2007-2009 plan for exploratory drilling. In a unanimous memorandum opinion,

issued just one week after oral argument, the Ninth Circuit granted MMS and Shell a

complete victory by denying in full the petitions for review challenging Shell’s 2010

plan. The Court agreed with our arguments that MMS had reached reasonable

findings of no significant impact under the National Environmental Policy Act

(NEPA) and had complied with the Outer Continental Shelf Lands Act (OCSLA).



 We represented New York Governor David Paterson and Lieutenant Governor

Richard Ravitch in a 4-3 victory before the New York Court of Appeals in Skelos

v. Paterson, which held that the Governor has statutory and constitutional authority

to appoint a lieutenant governor to fill a vacancy in that office—an issue of first

impression under New York constitutional law that the firm litigated from start

to finish in just over two months.









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 We represented the Alliance of Automobile Manufacturers in the Second Circuit

and the Ninth Circuit, arguing that federal fuel economy laws preempt state to

regulate greenhouse gas emissions. Seeking to overturn district court judgments

in Vermont and California, we argued that federal law commits the task of

balancing fuel conservation against the economic impact on the auto industry

to the federal government, not the states. The appeals were ultimately settled by

new federal legislation under President Obama.



 We represent insurer CNA in an appeal before the Nevada Supreme Court from a

$43 million product liability award, the largest in that state's history.



 We represented Avery Dennison Corp. in the Ninth Circuit in an appeal arising

from a petition for discovery under the Hague Convention. The Ninth Circuit

affirmed the denial of a competitor's request for production of documents and, in a

published opinion, further defined the scope of the statute providing for assistance to

foreign and international cases.









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