POLLOCK | COHEN Lup 60 BROAD STREET, 24TH FLOOR NEw YORK, NEW YORK 10004 (212) 337-5361 Raphael Janove [email protected] (215) 667-8607 June 30, 2022 VIA ECF Judge Paul A. Engelmayer United States District Court 40 Foley Square, Room 2201 New York, NY 10007

Re: Gill v. National Football League, et al., No. 21 Civ. 1032 Request for Sealing Dear Judge Engelmayer: The Parties respectfully request that the unredacted version of Exhibit A to the Declaration of Karl Kronenberger, be sealed, as the document contains proprietary and trade information of the National Football League, its affiliates and licensees. Plaintiff has filed a redacted version of Exhibit A as ECF No. 89-1. Rule 4(B)(1) of Your Honor’s Individual Rules and Practices permits a party to redact financial information, proprietary or trade secret information. The contract, with redactions, has been publicly filed at ECF No. 89-1. Plaintiff is filing the unredacted version under seal, concurrently with this letter. The document to be sealed has been designated “Highly Confidential.” And this Court has already ordered that similar contracts between the NFL and third-parties can be filed with redactions. See ECF No. 80. Moreover, this Court has permitted narrowly tailored redactions of filings in order to prevent the disclosure of confidential proprietary information damaging to competitive interests. See Leonard v John Hancock Life Ins. Co., No. 18-cv-4994-AKH,

, at **12-13 (S.D.N.Y. May 26, 2021); Sellick v. Consol. Edison Co. of NY, Inc., No. 15-ev- 9082 (RJS),

, at *24-25 (S.D.N_Y. Mar. 23, 2017). Disclosure of this information could be detrimental to the National Football League and provide competitors proprietary information. Accordingly, the Parties request that the Court seal the unredacted version of ECF No. 89-1.

Hon. Judge Paul A. Engelmayer June 30, 2022 Page 2 of 2

Respectfully submitted, /s/ Raphael Janove Raphael Janove Pollock Cohen LLP 111 Broadway, Ste. 1804 New York, NY 10006 Telephone: (212) 337-5361 [email protected] Counsel for Plaintiff Sietel Singh Gill and the Proposed Class /s/ Jason M. Myers Jason M. Myers London Fischer LLP 59 Maiden Ln, FL 41 New York, NY 10038 Telephone: (212) 331-9555 [email protected] Attorneys for Defendants National Football League and NFL Enterprises LLC ec: All counsel of record (via ECF) Enclosures

Granted. SO ORDERED.

PAUL A. G yer) United States District Judge 7/1/22