Ever Victory Technology Limited v. SAS Group, Inc.

CLOFFMANN & BARON, LLP Ris ATTOANEVS AT LAW 6900 Jericho Turnpike, Syosset, New York 11791-4407 | phone: 516.822.3550 | fax: 516.822.3582 | www. hbiplaw.com Oaniel A. Scol. □□□ October 18, 2023 □□□ Steven T. Zusc VIA ECF Michel 1 Chak □□□□□ □□□□□□□ Hon. Timothy M. Reif □□□□ United States Court of International Trade □□□□ Federal Plaza Susan A. S New York, New York 10278 □□□ □□□ Re: Ever Victory Technology Limited v. SAS Group, inc. me tae.

19-cv-00486 (TMR) Mark €, B Patent A Dear Judge Reif: Christine E. Dietzel, F Founding Senior Cot Hoffman & Baron, LLP (“Hoffmann & Baron”) represents defendant SAS Group, □ □□ Inc. (“SAS”) in the above-referenced action. To prevent possible waiver of attorney- □□ client privilege, avoid public disclosure of client confidences, and minimize potential □□□□ □□□□□ prejudice to SAS, Hoffmann & Baron respectfully submits this letter-motion requesting {Senior Atta that the Court approve for filing under seal with an ex parte viewing level designation, Hoffmann & Baron’s memorandum in support of its motion to withdraw as counsel and the Declaration of Daniel A. Scola, Jr. in support of that motion. In connection with its motion to withdraw, Hoffmann & Baron is not asserting a retaining or charging lien.

The reason for Hoffmann & Baron’s request is that it is the preferred practice to file the above-identified pleadings in support of a motion to withdraw as counsel under seal. See, e.g., Brown v. Montefiore Med. Ctr., 19 Civ. 11474 (ALC) (JLC), 2022 US.

Dist. LEXIS 128965, at *1 (S.D.N.Y. July 20, 2022); Team Obsolete Ltd. v. A.H.R.M.A.

Ltd., 464 F. Supp. 2d 164, 164-65 (E.D.N. Y. 2006).

SAS has indicated that it will not oppose Hoffmann & Baron’s motion to withdraw as counsel.

Counsel for the parties have met and conferred, and plaintiff Ever Victory Technology Limited will not oppose Hoffmann & Baron’s request to seal or its motion to withdraw as counsel.

Respectfully, cc: Counsel of Record (via ECF) Ss.

Mr. Scott Sobo: President & CEO, defendant SA' -Greup; Inc. (via John ea GRANTED. The court grants the letter-motion of Hoffmann & $9 ORDERED DATE October 24, 2023 Baron, LLP to file under seal with an ex parte viewing level EX, = designation Hoffmann & Baron, LLP’s memorandum in Ene oan OF support of its motion to withdraw as counsel and the STG CSTOR TION declaration in support of that motion. The Clerk of the Court is FOR THe SOUTHERN DISTRICT OF