1 Patrick J. Reilly Nevada Bar No. 6103 2 BROWNSTEIN HYATT FARBER SCHRECK, LLP 3 100 North City Parkway, 16th Floor Las Vegas, Nevada 89106 4 Telephone: 702.382.2101 Facsimile: 702.382.8135 5 [email protected] 6 Mark Oakes (pro hac vice) Zach McHenry (pro hac vice) 7 Ethan Glenn (pro hac vice) 8 NORTON ROSE FULBRIGHT US LLP 98 San Jacinto Boulevard, Suite 1100 9 Austin, Texas 78701-4255 Telephone: (512) 474-5201 10 Facsimile: (512) 536-4598 [email protected] 11 [email protected] 12 [email protected] 13 Attorneys for Defendants/Counterclaimants 14 15 UNITED STATES DISTRICT COURT 16 DISTRICT OF NEVADA 17 18 PARADISE ENTERTAINMENT LIMITED, a Bermuda corporation; and LT GAME INC., a 19 Nevada corporation; and LT GAME LIMITED, Case No. 2:24-cv-00428-JCM-BNW 20 a British Virgin Islands corporation,

21 Plaintiffs, UNOPPOSED MOTION FOR LEAVE TO v. REDACT LIMITED EXCERPTS OF 22 EMPIRE TECHNOLOGICAL GROUP DEFENDANT YI ZHAO’S REPLY IN 23 LIMITED, a Nevada corporation; GAMING SUPPORT OF MOTION TO DISMISS FOR SPECIALIZED LOGISTICS LLC, a Nevada LACK OF PERSONAL JURISDICTION 24 limited liability company; LINYI FENG, an AND SEAL 3 EXHIBITS TO THE SAME individual; ROY KELCEY ALLISON, an 25 individual; DARYN KIELY, an individual; and 26 YI ZHAO, an individual, 27 Defendants. 28 1 Pursuant to Rule 5.2 of the Federal Rules of Civil Procedure and Local Rule IA 10-5, 2 Defendant Yi Zhao (“Ms. Zhao”) hereby moves this Court for an order: (i) temporarily placing 3 under seal (the “Motion to Seal”) Exhibits A-3, A-4, and A-7 to Defendant Zhao’s Reply in Support 4 of Motion to Dismiss for Lack of Personal Jurisdiction and (ii) to temporarily redact limited 5 portions of Defendant Zhao’s Reply in Support of Motion to Dismiss for Lack of Personal 6 Jurisdiction that reference or quote those materials. Exhibits A-3, A-4, and A-7 contain Plaintiffs’ 7 and Defendants’ confidential business materials covered under the Court’s protective order. Ms. 8 Zhao asks the Court to set a date on which the parties could brief the Court as to whether the 9 materials should be permanently sealed and redacted. The motion is unopposed.1

10 DATED this 3rd day of June, 2025.

11 /s/ Patrick J. Reilly Patrick J. Reilly 12 BROWNSTEIN HYATT FARBER SCHRECK, LLP 13 100 North City Parkway, 16th Floor Las Vegas, Nevada 89106 14 Mark Oakes (pro hac vice) Zach McHenry (pro hac vice) 15 Ethan Glenn (pro hac vic) NORTON ROSE FULBRIGHT US LLP 16 98 San Jacinto Boulevard, Suite 1100 Austin, Texas 78701-4255 17 Attorneys for Defendants 18 MEMORANDUM OF POINTS AND AUTHORITIES 19 Pursuant to Federal Rule of Civil Procedure 5.2(d), “[t]he court may order that a filing be 20 made under seal without redaction.” “[A]lthough the common law right creates a strong 21 presumption in favor of access, the presumption can be overcome by sufficiently countervailing 22 interests.” San Jose Mercury News, Inc. v. District Ct.,

, 1102 (9th Cir. 1999). Parties 23 seeking to seal judicial records attached to dispositive motions must “articulate[ ] compelling 24 reasons supported by specific factual findings that outweigh the general history of access and the 25 public policies favoring disclosure.” Kamakana v. City & Cty. of Honolulu,

, 1178- 26

27 1 Plaintiffs stated they do not oppose the filing under seal in the first instance of materials previously designated to be confidential but, if needed, will file a supplemental submission on these materials 28 1 79 (9th Cir. 2006) (alteration in original) (internal quotation marks and citations omitted). A party 2 may establish compelling reasons by demonstrating that the materials could gratify spite, see 3 Primus Grp., Inc. v. Inst. for Environmental Health, Inc.,

, 1267 (N.D. Cali. 4 2019), or where the materials contain sensitive business information that might harm a litigant’s 5 competitive standing (including financial terms, details on confidential negotiations, and business 6 strategies). See TML Recovery, LLC v. Cigna Corp.,

, 1218 (C.D. Cali. 2024). 7 Here, Ms. Zhao seeks to seal Plaintiffs’ employees’ deposition excerpt and two confidential 8 internal documents contained in Exhibits A-3, A-4, and A-7. These materials have been designated 9 confidential by the parties per the Stipulated Confidentiality Agreement and Protective Order the 10 Court issued on August 5, 2024 (the “Protective Order”). ECF No. 41. Accordingly, these 11 materials should be presumed confidential pending a date to be set by this Court on which the 12 parties will brief the Court on whether the materials should be permanently sealed and redacted. 13 Accordingly, Ms. Zhao moves to place these documents under seal and to redact 14 limited portions of the Reply in Support of Motion to Dismiss for Lack of Personal Jurisdiction 15 which reference or quote those materials.

16 DATED this 3rd day of June, 2025.

17 /s/ Patrick J. Reilly Patrick J. Reilly 18 BROWNSTEIN HYATT FARBER SCHRECK, LLP 19 100 North City Parkway, 16th Floor Las Vegas, Nevada 89106 20 Mark Oakes (pro hac vice) Zach McHenry (pro hac vice) 21 Ethan Glenn (pro hac vic) NORTON ROSE FULBRIGHT US LLP 22 98 San Jacinto Boulevard, Suite 1100 Austin, Texas 78701-4255 23 Attorneys for Defendants 24 ORDER 25 The Court, having reviewed the above motion, and finding good cause therein, hereby 26 GRANTS the above motion, ORDERS that Exhibits A-3, A-4, and A-7 be SEALED in their 27 entirety, and ORDERS that the redactions found in Defendant Zhao’s Reply in Support of Motion 28 1 || to Dismiss for Lack of Personal Jurisdiction shall remain. 2 IT IS SO ORDERED. 3 □□ gn La 4 UNITED STATES Magistrate Judge 5 DATED:_ October 24, 2025 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

1 CERTIFICATE OF SERVICE 2 Pursuant to Fed. R. Civ. P. 5(b), and Section IV of District of Nevada Electronic Filing 3 Procedures, I certify that the foregoing Unopposed Motion for Leave to Redact Limited Excerpts of 4 Defendant Yi Zhao’s Reply in Support of Motion to Dismiss for Lack of Personal Jurisdiction and 5 Seal 3 Exhibits to the Same and Memorandum of Points and Authorities in Support was served via 6 electronic service on the 3rd day of June 2025, to all parties on the CM/ECF service list. 7 /s/ Patrick J. Reilly 8 Patrick J. Reilly 9 10 CERTIFICATE OF CONFERENCE 11 I certify that counsel for the parties conferred regarding the relief requested in Unopposed 12 Motion for Leave to Redact Limited Excerpts of Defendant Yi Zhao’s Reply in Support of Motion 13 to Dismiss for Lack of Personal Jurisdiction and Seal 3 Exhibits to the Same and Memorandum of 14 Points and Authorities in Support; counsel for Plaintiffs stated that Plaintiffs are unopposed to the 15 relief requested. 16 /s/ Patrick J. Reilly 17 Patrick J. Reilly 18 19 20 21 22 23 24 25 26 27 28