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Freescale Semiconductor, Inc. v. ChipMOS Techs., Inc.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION
Mar 13, 2013
CASE NO. 5:09-CV-03689-EJD (N.D. Cal. Mar. 13, 2013)

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.


Summaries of

Freescale Semiconductor, Inc. v. ChipMOS Techs., Inc.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION
Mar 13, 2013
CASE NO. 5:09-CV-03689-EJD (N.D. Cal. Mar. 13, 2013)
Case details for

Freescale Semiconductor, Inc. v. ChipMOS Techs., Inc.

Case Details

Full title:FREESCALE SEMICONDUCTOR, INC., a corporation, Plaintiff, v. CHIPMOS…

Court:UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION

Date published: Mar 13, 2013

Citations

CASE NO. 5:09-CV-03689-EJD (N.D. Cal. Mar. 13, 2013)