Case No. 5:17-CV-00220-LHK Syrett Declaration ISO Non-Party Intel’s

Administrative Motion to Seal Confidential 

Information Pursuant to L.R. 7-11 & 79-5

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Mark D. Selwyn (SBN: 244180) 

WILMER CUTLER PICKERING

HALE AND DORR LLP 

950 Page Mill Road 

Palo Alto, California 94304 

Telephone: (650) 858-6000 

Facsimile: (650) 858-6100 

William F. Lee (pro hac vice) 

Joseph J. Mueller (pro hac vice) 

Mark A. Ford (pro hac vice) 

Timothy Syrett (pro hac vice) 

WILMER CUTLER PICKERING

HALE AND DORR LLP 

60 State Street 

Boston, MA 02109 

Telephone: (617) 526-6000 

Facsimile: (617) 526-5000 

Attorneys for Non-Party Intel Corporation

FEDERAL TRADE COMMISSION, 

Plaintiff,

 v. 

QUALCOMM INCORPORATED, a 

Delaware corporation,

Defendant.

Case No. 5:17-cv-00220-LHK

DECLARATION OF TIMOTHY 

SYRETT ON BEHALF OF NONPARTY INTEL CORPORATION IN 

SUPPORT OF ITS ADMINISTRATIVE 

MOTION SEAL CONFIDENTIAL 

INFORMATION PURSUANT TO L.R. 

7-11 & 79-5

Courtroom: 8, 4th Floor 

The Honorable Lucy H. Koh 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN JOSE DIVISION 

Case 5:17-cv-00220-LHK Document 1175-2 Filed 01/07/19 Page 1 of 4
Case No. 5:17-CV-00220-LHK 1 Syrett Declaration ISO Non-Party Intel’s 

Administrative Motion to Seal Confidential 

Information Pursuant to L.R. 7-11 & 79-5

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I, Timothy Syrett, declare as follows: 

1. I am a partner at the law firm of Wilmer Cutler Pickering Hale and Dorr LLP, counsel for 

non-party Intel Corporation (“Intel”) in the above-captioned litigation. I am licensed to 

practice law in the Commonwealth of Massachusetts and am admitted to practice pro hac 

vice before the U.S. District Court for the Northern District of California. I am familiar 

with the facts set forth herein and, if called as a witness, I could and would testify 

competently to those facts under oath.

2. I respectfully submit this declaration in support of non-party Intel’s Administrative Motion 

to Seal Confidential Information Pursuant to Local Rules 7-11 and 79-5. 

3. On January 6, 2019, pursuant to the Court’s December 13, 2018 Order (ECF No. 1003)

and instructions given at the Pretrial Conference, defendant Qualcomm Incorporated 

(“Qualcomm”) and plaintiff Federal Trade Commission (“FTC”) informed Intel of the trial 

exhibits produced by Intel that they anticipate presenting at trial on January 8, 2019.

4. I have reviewed the Intel trial exhibits that Qualcomm and the FTC may present at trial on 

January 8, 2019. Intel seeks to seal portions of seven of the twelve Intel exhibits that 

Qualcomm and the FTC have identified as ones they may offer at trial on January 8, 2019. 

5. Attached hereto as Exhibits 1-7 are the seven exhibits that Qualcomm and the FTC have

identified and of which Intel seeks to seal portions. Intel has marked for redaction portions 

of Exhibits 1-7 containing highly sensitive information, including concerning Intel’s 

business strategies, product plans or roadmaps, margins, pricing, cost structure, and 

specific financial targets. In the versions filed under seal, the portions Intel seeks to seal 

are marked with red boxes (or in the case of QX0092, which already contains red boxes, 

Intel has added orange boxes). The accompanying Proposed Order lists each page of each 

exhibit on which Intel has marked information that it seeks to seal.

Case 5:17-cv-00220-LHK Document 1175-2 Filed 01/07/19 Page 2 of 4
Case No. 5:17-CV-00220-LHK 2 Syrett Declaration ISO Non-Party Intel’s 

Administrative Motion to Seal Confidential 

Information Pursuant to L.R. 7-11 & 79-5

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6. Attached hereto with proposed redactions as Exhibit 1 is proposed trial exhibit JX0104

(INTEL-QCOMM008124586 – INTEL-QCOM0081246561), containing a June 2015 

PowerPoint presentation entitled “5G CSD MCM Review.” This exhibit is designated 

“Intel Highly Confidential – Outside Attorneys’ Eyes Only” under the protective order in 

this litigation.

7. Attached hereto with proposed redactions as Exhibit 2 is proposed trial exhibit JX0117

(INTEL-QCOM002458604 - INTEL-QCOM002458670), containing a 2016 PowerPoint 

presentation entitled “ICDG PGBP Strategy Update.” This exhibit is designated “Intel 

Highly Confidential – Outside Attorneys’ Eyes Only” under the protective order in this 

litigation.

8. Attached hereto with proposed redactions as Exhibit 3 is proposed trial exhibit QX0089

(INTEL-QCOM000354039 - INTEL-QCOM000354044), contains a document entitled 

“Mobile Best in Class/14 nm Whitepaper.” This exbibit is designated “Intel Highly 

Confidential – Outside Attorneys’ Eyes Only” under the protective order in this litigation.

9. Attached hereto with proposed redactions as Exhibit 4 is proposed trial exhibit QX0092

(INTEL-QCOM007957504 - INTEL-QCOM007957535), containing a July 2015 

PowerPoint presentation entitled “Mobile R&D Benchmarking.” This exhibit is 

designated “Intel Highly Confidential – Outside Attorneys’ Eyes Only” under the

protective order in this litigation.

10. Attached hereto with proposed redactions as Exhibit 5 is proposed trial exhibit QX0094

(INTEL-QCOM000487295 - INTEL-QCOM000487302), a September 2016 email 

 1 The Bates range for JX0104 provided by counsel for Qualcomm is INTEL-QCOM008124586 - INTELQCOM008124663. The pages for bates range INTEL-QCOM008124657 - INTEL-QCOM008124663 consist of 

images from within the PowerPoint presentation that appear to have been generated as separate files during production 

by Intel. Those pages are not included herein because they are duplicative of images within the PowerPoint found at 

INTEL-QCOM008124587 - INTEL-QCOM008124656.

Case 5:17-cv-00220-LHK Document 1175-2 Filed 01/07/19 Page 3 of 4
Case No. 5:17-CV-00220-LHK 3 Syrett Declaration ISO Non-Party Intel’s 

Administrative Motion to Seal Confidential 

Information Pursuant to L.R. 7-11 & 79-5

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memorandum with the subject “7360 1$ [sic] Cost Challenge – Response.” This exhibit is 

designated “Intel Highly Confidential – Outside Attorneys’ Eyes Only” under the 

protective order in this litigation.

11. Attached hereto with proposed redactions as Exhibit 6 is proposed trial exhibit QX0095

(INTEL-QCOM002236311 - INTEL-QCOM002236327), containing a May 2017 

PowerPoint entitled “ICE Multi-generational LTE Pricing Proposal.” This exhibit is 

designated “Intel Highly Confidential – Outside Attorneys’ Eyes Only” under the 

protective order in this litigation.

12. Attached hereto with proposed redactions as Exhibit 7 is proposed trial exhibit CX1598 

(INTEL-QCOM000420594 - INTEL-QCOM000420607), containing an email and a July

2015 Executive Office Review detailing the acquisition and integration of Via 

Technologies. This exhibit is designated “Intel Highly Confidential – Outside Attorneys’ 

Eyes Only” under the protective order in this litigation.

I declare under the penalty of perjury under the laws of the United States that the foregoing is true 

and correct to the best of my knowledge. 

Dated: January 7, 2019

By: /s/ Timothy Syrett

 Timothy Syrett

Case 5:17-cv-00220-LHK Document 1175-2 Filed 01/07/19 Page 4 of 4