UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK Scott H. Kaliko (SK 1163) YK Law LLP 32 E. 57TH Street 8th Floor New York, NY 10022 Tel: 201-739-5555 212-837-2600 Ext. 1019 Fax: 201-603-1142 Attorneys for Plaintiff _____________________________________ ) HEXIN HOLDING LIMITED ) Case No.: ) Plaintiff, ) ) v. ) ) ) PARTNERSHIPS AND ) UNINCORPORATED ASSOCIATIONS ) ) LISTED ON SCHEDULE A; ) ) ABC CORPS 1-100; ) ) ) JOHN/JANE DOES 1-100. ) Defendants. ) ) ) ) ) PLAINTIFF’S EX PARTE MOTION FOR LEAVE TO FILE UNDER SEAL Plaintiff Hexin Holding Limited (“Plaintiff”) hereby moves ex parte and files this Motion requesting leave to file the following documents under seal: (1) Schedule A attached to Plaintiff’s Complaint, which lists the fully interactive e-commerce stores operating under the seller aliases (the “Seller Aliases) and the e-commerce stores URLS under the Online Marketplaces; (2) Declaration of Juan Yang and exhibits, which includes a sample of screenshot printouts showing e-commerce stores operating under the Seller Aliases (3) Declaration of Scott H. Kaliko and exhibits. Good cause exists for this Court to grant the requested relief ex parte as the underlying action involves allegations of copyright infringement, and therefore sealing of the requested materials is necessary to prevent Defendants from learning of these proceedings prior to the execution of a temporary restraining order. If Defendants were to learn of these proceedings prematurely, the likely result would be the destruction of relevant documentary evidence and the hiding or transferring of assets to foreign jurisdictions, which would frustrate the purpose of the underlying action and would substantially interfere with the Court’s power to grant relief. Should the Court grant this motion and permit the sealing of the requested materials, Plaintiff will move to unseal the requested materials after service of the temporary restraining order has been effectuated upon Defendants.

Dated this 17th day of December 2021. Respectfully submitted, Endorsed: The application is granted in part. The of Scott H. Kaliko and exhibits contain no information By: s/ Scott H Kaliko / could alert Defendants to these proceedings. Accordingly, has not set forth any reasons to overcome the presumption Scott H. Kaliko (SK1163) f publi to those documents. See Lugosch v. Pyramid C cK haw lle public access to those documents. See Lugosch v. Pyramid Co. 633 Wyckoff Ave Onondaga,

(2d Cir. 2006). The Clerk of Wyckoff, NJ 07481 is directed to seal Dkt. Nos. 2-1, 2-2, 2-3, 9, 15, 15-1, and [email protected] 5-2, so that those documents are viewable only by the Court and Fel: OLSOR TLD Hexin Holding Limited. The Clerk of Court is further , (1) to remove the names of individual Defendants in the Attorneys for Plaintiff caption so that the caption in this matter appears as Hexin Limited v. The Partnerships and Unicorporated identified in Schedule A; and (2) to terminate the motion at Dkt. No. 1. SO ORDERED. oud & Hovdkppbe Paul G. Gardephe United States District Judge