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Message: e.Digital Corporation v. Research in Motion - Update
A redacted version of the 2009 Patent Cross License and Settlement Agreement (“Settlement Agreement”) between e.Digital and Samsung was obtained from e.Digital and Samsung pursuant to subpoena on June 19, 2013 which is Exhibit 1 to the Request for Judicial Notice. Samsung and e.Digital counsel both agreed on June 27, 2013 to having the redacted agreement to be designated as “CONFIDENTIAL.” The document to be sealed contains confidential, settlement and business information that if disclosed to the public will cause irreparable harm to Samsung and e.Digital, therefore it is critical that these materials remain confidential and not be placed in the public file.
3. The Reply to Motion to Dismiss references and incorporates text from the Settlement Agreement and portions of the Declaration of Kent W. Serratt, a BlackBerry employee, in support of the Reply to Motion to Dismiss regarding the identity of which companies that BlackBerry purchases components from should also be designated “CONFIDENTIAL.”
4. The documents to be sealed described in paragraph 3 contains confidential, business information that if disclosed to the public will cause irreparable harm to BlackBerry. Therefore, it is critical that these materials remain confidential and not be placed in the public file.

Case 3:13-cv-00781-DMS-WVG Document 53-1 Filed 07/26/13 Page 2
McDERMOTT WILL & EMERY LLP
By: /s/ Judith S.H. Hom
FABIO E. MARINO
JUDITH S.H. HOM
MANDY H. KIM
Attorneys for Defendants
RESEARCH IN MOTION LIMITED DBA BLACKBERRY; RESEARCH IN MOTION CORPORATION DBA BLACKBERRY
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