The Facebook, Inc. v. Connectu, LLC et al - 94 by justia

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									The Facebook, Inc. v. Connectu, LLC et al                                                                                       Doc. 94
                    Case 5:07-cv-01389-RS                Document 94   Filed 06/25/2007     Page 1 of 3



               1    G. HOPKINS GUY, III (State Bar No. 124811)
                       hopguy@orrick.com
               2    I. NEEL CHATTERJEE (State Bar No. 173985)
                       nchatterjee@orrick.com
               3    MONTE COOPER (State Bar No. 196746)
                       mcooper@orrick.com
               4    THERESA A. SUTTON (State Bar No. 211857)
                       tsutton@orrick.com
               5    YVONNE P. GREER (State Bar No. 214072)
                       ygreer@orrick.com
               6    ORRICK, HERRINGTON & SUTCLIFFE LLP
                    1000 Marsh Road
               7    Menlo Park, CA 94025
                    Telephone:     650-614-7400
               8    Facsimile:     650-614-7401

               9    Attorneys for Plaintiffs
                    FACEBOOK, INC. and MARK ZUCKERBERG
              10

              11                                         UNITED STATES DISTRICT COURT

              12                                   NORTHERN DISTRICT OF CALIFORNIA

              13                                              SAN JOSE DIVISION

              14

              15    FACEBOOK, INC. and MARK                              Case No. 5:07-CV-01389-RS
                    ZUCKERBERG,
              16                                                         DECLARATION OF MICHAEL W.
                                           Plaintiffs,                   TRINH IN SUPPORT OF
              17                                                         PLAINTIFFS' MISCELLANEOUS
                             v.                                          ADMINISTRATIVE REQUEST TO
              18                                                         FILE PORTIONS OF PLAINTIFFS’
                    CONNECTU, INC. (formerly known as                    OPPOSITION TO DEFENDANTS'
              19    CONNECTU, LLC), CAMERON                              MOTION AND RELATED EXHIBITS
                    WINKLEVOSS, TYLER WINKLEVOSS,                        UNDER SEAL
              20    DIVYA NARENDRA, PACIFIC
                    NORTHWEST SOFTWARE, INC.,                            Judge:     Honorable Richard Seeborg
              21    WINSTON WILLIAMS, WAYNE CHANG,
                    and DAVID GUCWA AND DOES 1-25,
              22
                                           Defendants.
              23

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                                                                                                        TRINH DECLARATION ISO
                    OHS West:260257723.1                                                  PLAINTIFFS ' MAR TO FILE UNDER SEAL
                                                                                                             5:07-CV-01389-RS


                                                                                                              Dockets.Justia.com
     Case 5:07-cv-01389-RS            Document 94        Filed 06/25/2007        Page 2 of 3



 1            I, MICHAEL W. TRINH, hereby declare the following:

 2            1.       I am an attorney admitted to practice before the Supreme Court of California and

 3   this Court. I am an associate with the law firm of Orrick, Herrington & Sutcliffe LLP, counsel for

 4   Plaintiffs Facebook, Inc. and Mark Zuckerberg. I make this Declaration in support of Plaintiffs'

 5   Miscellaneous Administrative Request To File Portions of Plaintiffs' Opposition To Defendants'

 6   Motion To Dismiss For Lack of Personal Jurisdiction And Related Exhibits Under Seal. The

 7   matters contained in this declaration are of my own personal knowledge and, if called as a

 8   witness, I could and would testify competently to the matters set forth herein.

 9            2.       Portions of the Plaintiffs' Opposition To Defendants Pacific Northwest Software

10   and Winston Williams' Motion To Dismiss For Lack Of Personal Jurisdiction ("Opposition")

11   refer to or contain information that is confidential and proprietary to Plaintiffs or third parties,

12   such as confidential business information regarding Facebook, Inc. and personally identifiable

13   information about third-party individuals.

14            3.       Other redacted portions of the Opposition refer to or contain information that has

15   been designated by Defendants pursuant to the Stipulated Protective Order in this case.

16            4.       Exhibits 1 and 2 of the Declaration of Monte M.F. Cooper In Support of

17   Plaintiff's Opposition to Defendants Pacific Northwest Software and Winston William's Motion

18   To Dismiss for Lack of Personal Jurisdiction ("Cooper Decl.") refer to or contain information that

19   is confidential and proprietary to Plaintiffs or third parties, such as confidential business

20   information regarding Facebook, Inc. and personally identifiable information about third-party
21   individuals.

22            5.       Exhibits 7, 9, 11, 12, 13, 14, 16, 17, 19, 21, and 26 of the Cooper Declaration

23   refer to or contain information that has been designated by Defendants pursuant to the Stipulated

24   Protective Order in this case.

25   ///

26   ///

27   ///

28   ///
                                                                                             TRINH DECLARATION ISO
     OHS West:260257723.1                                                      PLAINTIFFS ' MAR TO FILE UNDER SEAL
                                                                                                  5:07-CV-01389-RS
     Case 5:07-cv-01389-RS          Document 94         Filed 06/25/2007      Page 3 of 3



 1            I declare under penalty of perjury under the laws of the United States of America that the

 2   foregoing is true and correct. Executed this 25th day of June 2007, in Menlo Park, California.

 3

 4                                                         /s/ Michael W. Trinh /s/
                                                           Michael W. Trinh
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                                                                                          TRINH DECLARATION ISO
     OHS West:260257723.1                           -2-                     PLAINTIFFS ' MAR TO FILE UNDER SEAL
                                                                                               5:07-CV-01389-RS

								
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