Spectrum Dynamics Medical Limited v. General Electric Company

| S H oie 6 DOCUMENT FISH & RICHARDSON ELECTRONICALLY FILED nison PC Street, Suite 400 DOC #: ry, CA 94063 DATE FILED: 02/21/2023 ) main em fax VIA ECF February 17, 2023 Esha Bandyopadhyay [email protected] Hon. Katharine H. Parker +1650 859 5088 direct 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 Federal Rule of Civil Procedure 5.2(e), Your Honor’s Individual Rule of Practice III(d), and the parties’ Stipulated Protective Order (ECF No. 156), Spectrum respectfully requests (1) redaction and filing under seal of its Second Amended Complaint and Exhibits 20 and 25 thereto and (2) filing under seal of Exhibits 2-18 and 28-29.

Like its First Amended Complaint and Exhibits 20 and 25 thereto, Spectrum’s Second Amended Complaint and Exhibits 20 and 25 thereto (1) describe the trade secrets that Spectrum alleges GE misappropriated; (2) reference the GE patents, by number and other identifying information, that Spectrum alleges contain its misappropriated trade secrets; and (3) point to specific figures and text in those GE patents that Spectrum alleges disclose its misappropriated trade secrets. Judge Broderick previously granted Spectrum’s request to redact such information from its First Amended Complaint and Exhibits 20 and 25 thereto. ECF No. 32 at 1-2. Judge Broderick also granted Spectrum’s request to redact such information from its Motion for Leave to Amend Complaint. ECF No. 552.

Exhibits 2-18 and 28 to Spectrum’s Second Amended Complaint are copies of the GE patents that Spectrum alleges contain its misappropriated trade secrets. Judge Broderick previously granted Spectrum’s requests to file these patents under seal. ECF No. 32; ECF No. 552.

Finally, Exhibit 29 to Spectrum’s Second Amended Complaint is a copy of Spectrum’s Amended Second Supplemental Table of Trade Secrets (ECF No. 613-1). Your Honor previously granted Spectrum’s request to file that document under seal. ECF No. 614.

For these reasons, Spectrum respectfully requests that the Court grant its request to file its Second Amended Complaint and Exhibits 20 and 25 thereto under seal and in redacted form, and to file Exhibits 2-18 and 28-29 under seal.

Hon. Katharine H. Parker Page 2 Respectfully Submitted, Spectrum's proposed redactions are narrowly tailored protect trade secrets and other competitively sensitive /s/ Esha Bandyopadhyay information in accordance with Lugosch v. Pyramid C Esha Bandyopadhyay of Onandaga, 435 F.3d 110 (2d Cir. 2006) and its Fish & Richardson P.C. progeny. Accordingly, the motion is GRANTED and t Arguello Street, Suite 400 document filed at ECF No. 630 may remain under seé Redwood City, CA 94063 Tel: 650 839 5070 Fax: 650 839 5071 SO ORDERED: Email: [email protected] Michael F. Autuoro (MA 2932 Fish & Richardson P.C. eT laarcare JUDGE 2/21/2023 Times Square, 20" Floor New York, NY 10036 Tel: 212 765 5070 Fax: 212 258 2291 Email: [email protected] Roger A. Denning (Pro Hac Vice) Fish & Richardson P.C.

12860 El Camino Real, Suite 400 San Diego, CA 92130 Tel: 858 678 5070 Fax: 858 678 5099 Email: [email protected] Adam J. Kessel (Pro Hac Vice) Alexander M. Pechette (Pro Hac Vice) Philip K. Chen (Pro Hac Vice) Fish & Richardson P.C.

One Marina Park Drive Boston, MA 02210 Tel: 617 542 5070 Fax: 617 542 8906 Email: [email protected]; [email protected]; [email protected] Attorneys for Plaintiff Spectrum Dynamics Medical Limited cc: All counsel of record (via ECF)