Spectrum Dynamics Medical Limited v. General Electric Company

| S H USDC SDNY FisHaricusacso {| DOCUMENT Kish & Richardson PC ELECTRONICALLY FILED 500 Arguello Street, Suite 400 DOC #: Redwood City, CA 94063 ED: 650 839 5070 main DATE FILED: 12/01/2022 680 839 3071 fax VIA ECF November 30, 2022 Esha Bandyopadhyay Principal : [email protected] Hon. Katharine H. Parker 430 One cle United States District Judge Southern District of New York Daniel Patrick Moynihan United States Courthouse Pearl Street New York, NY 10007 Re: Spectrum Dynamics Medical Limited (Plaintiff) v. GE et al. (Defendants); Case No.: 18-cv-11386 (VSB) Dear Judge Parker: Pursuant to Rule III(d) of your Honor’s Individual Practices in Civil Cases and Your Honor’s direction during the January 8, 2021 telephonic hearing (D.I. 176 at 37:18-20), Plaintiff Spectrum Dynamics Medical Limited, by and through counsel, respectfully requests permission to file under seal its Second Supplemental Table of Trade Secrets being filed herewith today, November 30, 2022.

Your Honor previously granted Spectrum’s motions to file its original and First Supplemental Tables of Spectrum Trade Secrets under seal. (D.J. 188; D.I. 558.) Spectrum’s Second Supplemental Table of Spectrum Trade Secrets, like the original and First Supplemental Tables of Spectrum Trade Secrets, contains Spectrum’s highly confidential information and describes Spectrum’s trade secrets.

For these reasons, Spectrum respectfully requests that the Court grant its request to file its Second Supplemental Table of Spectrum Trade Secrets under seal.

APPLICATION GRANTED.

Respectfully Submitted, Plaintiff's motion to seal is narrowly tailored to protect potentially competitively sensitive information, /s/ Esha Bandyopadhyay consistent with Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006), and its progeny.

Esha Bandyopadhyay Accordingly, Plaintiff's motion is granted and the document filed at ECF No. 601 may remain under seal. cc: All counsel of record (via ECF) SO ORDERED: Vetiver Ht Faber UNIVED STATES MAGISTRATE JUDGE 12/()1/2022