Mirrorlite Mirror, Inc. v. LiteMirror, GMM Inc.

LEASON One Barker Avenue rectum White Plains, New York 10607 ELLIS se. T 914.821.1686 [email protected] 17, 2024 eo Robert M. Isackson ECF PARTNER Honorable Philip M. Halpern States District Judge, Southern District of New York States Courthouse Quarropas Street Plains, New York 10601 Mirrorlite Mirror, Inc. v. Glassless Mirror Manufacturers Inc., No.: 7:23-cv-03437-PMH Judge Halpern: Pursuant to Rule 5.B of Your Honor’s Individual Rules of Practice, Defendant Glassless Mirror Inc. respectfully requests approval to redact and file under seal portions of Defendant’s Statement Material Facts Pursuant to Rule 56.1 and Plaintiff's Responses Thereto. The Statement of Material Facts confidential information designated as Highly Confidential — Attorneys’ Eyes Only by each Plaintiff and pursuant to the Stipulated Confidentiality Agreement and Protective Order (Dkt. 40).

The Court has discretion in determing Ae tiLe OF O00 4 e ex] OD OVeTCOomMEe eS Te mption o □□□□ Application granted with respect to Defendant's proposed redactions which it has tod ts filed. S 0 highlighted in yellow. With respect to that which Plaintiff designated, highlighted To Cocuments Mec. 9€@, €.§-> Defendant in green, the Court will provisionally seal such information subject to Plaintiff, by June 24, 2024 at 5:00 p.m., filing a letter explaining the reasons of access may be outweffppintaining that information under seal in accordance with Rule 5(B) of this Cou Individual Practices. information that could harm 4 The redacted document (Doc. 57) shall remain the publicly-filed version, and the & Co. Inc. 2020 WL 6781222. at *3 unredacted version (Doc. 56) shall remain under seal, as indicated herein.

The Clerk of Court is respectfully directed to terminate the letter motion pending as a countervailing factor |Doc¢._ 55.

Gusa S/A v. AMCI Holdings, Inc., 202/S0 ORDERED.

Defendant’s proposed redactio Philip M. Halpem . . United States District Judge strategy and marketing sp Dated: White Plains, New York June 18, 2024 LEASON ELLIS Hon. Philip M. Halpern June 17, 2024 Page 2 designated material (in green highlighting) on May 31, however, Plaintiff has not responded. Defendant has maintained the designations Plaintiff identified during discovery.

In accordance with the Court’s Individual Rules of Practice, Defendant will publicly file the Statement of Facts with proposed redactions and file under seal the Statement of facts with the redactions highlighted.

We appreciate the Court’s consideration.

Respectfully submitted, Robert M. Isackson cc: All counsel of record (via ECF)