Solid 21, Inc. v. Richemont North America, Inc.

HECHTPARTNERS David L. Hecht —— LLP Partner

P: (212) 851-6821 E: [email protected] VIA ECF October 7, 2021 Hon. Lorna G. Schofield

United States District Judge

United States District Court

40 Foley Square

New York, New York 10007

RE: Solid 21, Inc. v. Richemont North America, Inc. et al, Case No. 1:19-cv-01262-LGS Dear Judge Schofield,

We represent Plaintiff Solid 21, Inc. (“Solid 21”) in the above captioned matter. Solid 21’s opposition to Defendant’s Motion for Summary Judgment as well as Plaintiff’s Cross-Motion for Summary Judgment is due today, October 7, 2021. See ECF No. 134. We respectfully request that permission to file under seal Exhibit 1 and Exhibit 2 to the Hecht Declaration filed in support of Plaintiff's Opposition to Defendant’s Motion for Summary Judgment and Cross-Motion for Summary Judgment. Consistent with Section I(D)(i11) of this Court’s Individual Rules, these documents will be filed under seal on ECF and electronically related to this letter motion. Counsel for Plaintiff files these documents fully under seal in an abundance of caution, as Defendant has previously designated these documents as Attorney’s Eyes Only, Highly Confidential, or Confidential pursuant to the Protective Order.

Solid 21 thanks the Court for its consideration in this matter.

Respectfully Submitted, /s/ David L. Hecht

David L. Hecht

Hecht Partners LLP

125 Park Avenue, 25" Floor New York, NY 10017

Tel: 212-851-6821

Email: [email protected] Attorney for Plaintiff Solid 21, Inc. cc. Counsel of Record (via ECF)

125 Park Avenue, 25th Floor, New York, NY 10017

October 7, 2021

Page 2

Appendix identifying all parties and attorneys of record who should have access to the sealed documents

David L. Hecht, Counsel for Plaintiff

Yi Wen Wu, Counsel for Plaintiff

Andrew J. Lorin, Counsel for Plaintiff

John P. Margiotta, Counsel for Defendant

David Donahue, Counsel for Defendant

Laura E. Popp-Rosenberg, Counsel for Defendant

Daniel M. Nuzzaci, Counsel for Defendant

Emily S. Weiss, Counsel for Defendant

Sydney L. Kipen, Counsel for Defendant

Defendant shall file a response by October 15, 2021, stating whether they seek to seal Exhibits 1 and 2 to the Hecht Declaration. If Defendant seeks to seal those documents, Defendant shall provide the basis for sealing in accordance with the three-part test in Lugosch. See Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119-20 (2d Cir. 2006). If Defendants believe redactions are appropriate, they shall also submit proposed redactions. So Ordered.

Dated: October 8, 2021

New York, New York

LORNA G. SCHOFIEL

UNITED STATES DISTRICT JUDGE Park Avenue, 25th Floor, New York, NY 10017