Games Workshop Limited v. Chapterhouse Studios LLC

MOTION

N.D. Ill.November 9, 2012

1 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION GAMES WORKSHOP LIMITED, ) ) Plaintiff, ) ) Case No. 1:10-cv-08103 v. ) ) CHAPTERHOUSE STUDIOS LLC and ) JON PAULSON d/b/a PAULSON GAMES, ) Judge Matthew F. Kennelly ) Defendants. ) MOTION FOR LEAVE TO FILE UNDER SEAL Pursuant to Fed. R. Civ. P. 26.2, in accordance with the Agreed Protective Order entered July 12, 2011 (Dkt. No. 71), Defendant Chapterhouse Studios LLC (“Chapterhouse”), by and through its attorneys, moves this Honorable Court for leave to file under seal Exhibits D and E to the Declaration of Jennifer A. Golinveaux in support of Chapterhouse’s Motion in Limine, filed November 6, 2012. In support of this motion, Chapterhouse states as follows: 1. Exhibit D is a true and correct copy of a sales summary spreadsheet attached by Games Workshop as Exhibit 145 to its summary judgment papers, which it now seeks to introduce as proposed Games Workshop Trial Exhibit 216, “GW Sales Summary.” Certain portions of this document contain information that has been designated as “Highly Confidential - Attorneys’ Eyes Only” by Games Workshop pursuant to the Agreed Protective Order. 2. Exhibit E is a true and correct copy of a printout of sales data produced by GW at GW0011031, which it seeks to introduce as proposed GW Trial Exhibit 371, “Black Library Sales Data - 2007-08.” Certain portions of this document contain information that has been designated as “Highly Confidential - Attorneys’ Eyes Only” by Games Workshop pursuant to the Agreed Protective Order. 3. Exhibits A-C and F-H to the November 6, 2012 Golinveaux Declaration will remain publicly filed. Case: 1:10-cv-08103 Document #: 254 Filed: 11/09/12 Page 1 of 3 PageID #:14854 2 Based on the foregoing, Chapterhouse respectfully requests leave of this Court to file under seal Exhibits D and E to the Declaration of Jennifer A. Golinveaux in support of Chapterhouse’s Motion in Limine, filed November 6, 2012. Dated: November 9, 2012 Respectfully submitted, /s/ Bryce Cooper Jennifer Golinveaux (CA Bar No. 203056) Dean A. Morehous (CA Bar No. 111841) K. Joon Oh (CA Bar No. 246142) Thomas J. Kearney (CA Bar No. 267087) WINSTON & STRAWN LLP 101 California Street San Francisco, CA 94111-5802 Phone: (415) 591-1000 Fax: (415) 591-1400 jgolinveaux@winston.com dmorehous@winston.com koh@winston.com tkearney@winston.com Bryce A. Cooper (IL Bar No. 6296129) WINSTON & STRAWN LLP 35 West Wacker Drive Chicago, IL 60601-1695 Phone: (312) 558-5600 Fax: (312) 558-5700 bcooper@winston.com Case: 1:10-cv-08103 Document #: 254 Filed: 11/09/12 Page 2 of 3 PageID #:14855 3 CERTIFICATE OF SERVICE I, Bryce A. Cooper, an attorney, hereby certify that on November 9, 2012, I caused to be filed electronically the foregoing MOTION FOR LEAVE TO FILE UNDER SEAL with the Clerk of the Court using the CM/ECF system, which will send an electronic copy of the foregoing to counsel of record and constitutes service under Federal Rule of Civil Procedure 5(b)(2)(D) pursuant to Local Rule 5.9 of the Northern District of Illinois. ____/s/ Bryce A. Cooper____________________ Case: 1:10-cv-08103 Document #: 254 Filed: 11/09/12 Page 3 of 3 PageID #:14856