Opinion
CASE NO. 5:09-CV-03689-EJD
03-13-2013
FREESCALE SEMICONDUCTOR, INC., a corporation, Plaintiff, v. CHIPMOS TECHNOLOGIES, INC., a corporation, Defendant. AND RELATED COUNTERCLAIMS.
COOLEY LLP RONALD S. LEMIEUX VIDYA R. BHAKAR CARRIE J. RICHEY CARRIE J. RICHEY Attorneys for Defendant and Counterclaimant CHIPMOS TECHNOLOGIES, INC. JONES DAY GREG L. LIPPETZ JACQUELINE K. S. LEE JACQUELINE K. S. LEE Attorneys for Plaintiff and Counterclaim Defendant FREESCALE SEMICONDUCTOR, INC.
COOLEY LLP
RONALD S. LEMIEUX (120822)
(rlemieux@cooley.com)
VIDYA R. BHAKAR (220210)
(vbhakar@cooley.com)
CARRIE J. RICHEY (20825)
(crichey@cooley.com)
3000 El Camino Real
Five Palo Alto Square
Palo Alto, CA 94306-2155
Telephone: 650-843-5000
Facsimile: 650-849-7400
Attorneys for Defendant and Counterclaimant
CHIPMOS TECHNOLOGIES, INC.
JONES DAY
GREG L. LIPPETZ (154228)
glippetz@jonesday.com
JACQUELINE K. S. LEE (247705)
jkslee@jonesday.com
1755 Embarcadero Road
Palo Alto, California 94303
Telephone: (650) 739-3939
Facsimile: (650) 739-3900
Attorneys for Plaintiff and
Counterclaim Defendant
FREESCALE SEMICONDUCTOR, INC.
IT IS SO ORDERED
Judge Edward J. Davila
STIPULATION TO PERMIT CHIPMOS TECHNOLOGIES, INC. TO FILE UNDER
SEAL PORTIONS OF ITS MOTION FOR LEAVE TO FILE MOTION FOR
RECONSIDERATION AND MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF
JURY TRIAL DEMANDED
Complaint filed: July 13, 2009
Trial Date: TBD
Judge: Hon. Edward J. Davila
Pursuant to Local Rules 7-11(a) and 79-5(b), (d), Plaintiff Freescale Semiconductor, Inc. ("Freescale") and Defendant ChipMOS Technologies, Inc. ("ChipMOS") jointly submit this Stipulation To Permit ChipMOS Technologies, Inc. To File Under Seal Portions of Its Motion for Leave To File Motion for Reconsideration and Memorandum of Points and Authorities in Support Thereof.
WHEREAS ChipMOS will file on March 12, 2013, its Motion for Leave To File Motion for Reconsideration and Memorandum of Points and Authorities in Support Thereof;
WHEREAS portions of ChipMOS' Motion discuss and quote documents designated by Freescale as Protected Material pursuant to the Protective Order entered in this case (Dkt. No. 48);
WHEREAS ChipMOS has filed an Administrative Motion To File Under Seal Portions of this Motion and accompanying Memorandum of Points and Authorities in Support Thereof; and WHEREAS the requested relief is necessary and narrowly tailored to protect the alleged confidentiality of the materials submitted in support of ChipMOS' Motion for Leave To File Motion for Reconsideration until such time as the Court makes a final ruling as to the confidentiality of the relevant subject matter.
NOW THEREFORE IT IS HEREBY STIPULATED by the Parties, through their respective counsel of record, that ChipMOS is permitted to move for permission to file under seal portions of ChipMOS' Motion for Leave To File Motion for Reconsideration and Memorandum of Points and Authorities in Support Thereof.
While the Parties agree that portions of the concurrently filed ChipMOS' Motion for Leave To File Motion for Reconsideration may be publicly filed, the Parties also agree that the filing shall not be construed as a waiver of any confidentiality designation or other protection with respect to documents, transcripts, or other information referred to in, or that serve as the basis for, the allegations or arguments made in them.
IT IS SO STIPULATED.
Respectfully submitted,
COOLEY LLP
RONALD S. LEMIEUX
VIDYA R. BHAKAR
CARRIE J. RICHEY
By:_________________
CARRIE J. RICHEY
Attorneys for Defendant and Counterclaimant
CHIPMOS TECHNOLOGIES, INC.
In accordance with Civil Local Rule 5-1(i)(3), the above signatory attests that concurrence in the filing of this document has been obtained from the signatory below.
Respectfully submitted,
JONES DAY
GREG L. LIPPETZ
JACQUELINE K. S. LEE
By:_________________
JACQUELINE K. S. LEE
Attorneys for Plaintiff and Counterclaim Defendant
FREESCALE SEMICONDUCTOR, INC.