Traxcell Technologies, LLC v. Huawei Technologies USA Inc.

MOTION to Seal Documents in Support of its Opposition to Motion to Compel

E.D. Tex.February 26, 2019

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS MARSHALL DIVISION TRAXCELL TECHNOLOGIES, LLC, Plaintiff, v. NOKIA SOLUTIONS AND NETWORKS US LLC and NOKIA SOLUTIONS AND NETWORKS OY, Defendants. Civil Action No.: 2:17-cv-000042-RWS-RSP (Consolidated Lead Case) Civil Action No.: 2:17-cv-00044-RWS-RSP DEFENDANTS NOKIA SOLUTIONS AND NETWORKS OY AND NOKIA SOLUTIONS AND NETWORKS US LLC’S MOTION REQUESTING LEAVE TO FILE DOCUMENTS UNDER SEAL Defendants Nokia Solutions and Networks Oy and Nokia Solutions and Networks US LLC (“Nokia”) file this Motion for Leave to File an Opposition to Traxcell’s Motion to Compel, the declaration of Murali Ranganathan, Exhibit 9 and Exhibit 10 in support of its Opposition under seal. These documents contain Nokia’s confidential business information that, if disclosed, would cause harm to Nokia via-a-vis its competitors. Specifically, these documents disclose the identity of Nokia’s customers and how much they have paid for certain proprietary products and services. Accordingly, Nokia respectfully requests that the Court allow Nokia to file an Opposition to Traxcell’s Motion to Compel, the declaration of Murali Ranganathan, Exhibit 9 and Exhibit 10 in support of its Opposition under seal. Case 2:17-cv-00042-RWS-RSP Document 283 Filed 02/26/19 Page 1 of 2 PageID #: 38246 - 2 - DATED: February 26, 2019 Respectfully submitted, QUINN EMANUEL URQUHART & SULLIVAN By: /s/ Nathan Hamstra Nathan Hamstra Attorney for Defendants Nokia Solutions and Networks OY and Nokia Solutions and Networks US LLC Case 2:17-cv-00042-RWS-RSP Document 283 Filed 02/26/19 Page 2 of 2 PageID #: 38247