Jane Street Group, LLC v. Millennium Management LLC

quinn emantiel trial tawyers | new york Madison Avenue, 22nd Floor, New York, New York 1oo10-1601 | TEL (212) 849-7000 FAX (212) 849-7100 WRITER'S DirEcT DIAL No. (212) 849-7116 WRITER'S EMAIL ADDRESS [email protected] August 2, 2024 Via ECF Hon. Paul A. Engelmayer United States District Court, Southern District of New York Foley Square, Room 2201 New York, NY 10007 Re: Sealing Motion for Jane Street’s Motion for Extension, Jane Street Group, LLC v. Millennium Management LLC, et al., No. 1:24-cv-02783 Dear Judge Engelmayer: On behalf of Plaintiff Jane Street Group, LLC (“Jane Street”), and pursuant to Your Honor’s Individual Rule 4(B)(2) (Sealing/Redaction Requiring Court Approval), we write to re- quest permission to redact and seal certain materials that contain Jane Street’s proprietary, com- mercially sensitive, or trade secret information in Jane Street’s Letter Motion for Extension.

Within three business days, Jane Street will file a public redacted version of Jane Street’s motion.

Jane Street will also file a sealed version of Jane Street’s motion with highlighting to indicate the proposed redactions, and an explanation of why Jane Street seeks redaction of the highlighted materials.

In connection with Jane Street’s Letter Motion for Extension, Jane Street seeks to seal portions of the Letter Motion and its supporting Exhibits that contain competitively sensitive in- formation regarding Jane Street’s business operations and confidential, proprietary, and trade se- cret information, and intellectual property. This information should not be made public, as Jane Street maintains this information as confidential and its secrecy is a significant competitive asset to Jane Street. Jane Street has spent significant sums of money to develop, use, and protect this confidential information and making it public would place Jane Street at a competitive disad- vantage. See Playtex Prods., LLC v. Munchkin, Inc., 2016 WL 1276450, at *11 (S.D.N.Y. Mar.

29, 2016) (granting redaction request for qualitative market research because “[p|laintiffs would be competitively harmed if they were revealed.”). Additionally, Jane Street believes that quinn emanuel urquhart & sullivan, lip ABU DHABI | ATLANTA | AUSTIN | BEIJING | BERLIN | BOSTON | BRUSSELS | CHICAGO | DALLAS | DOHA| HAMBURG | HONG KONG | HOUSTON | LONDON Defendants may seek to seal some or all of the Letter Motion for Extension and the Exhibits. This Court has previously ordered similar information filed under seal. See, e.g., Dkts. 157, 169.

Jane Street will meet and confer with Defendants regarding sealing or redactions of the Letter Motion and Exhibits, and within three business days, Jane Street will submit proposed re- dactions to the sealed documents, providing the public with ample information to understand the dispute. See Dependable Sales & Serv., Inc. v. TrueCar, Inc., 311 F. Supp. 3d 653, 666 (S.D.N-Y.

2018) (permitting proposed redactions where a “member of the public reviewing the parties’ re- dacted submissions . . . would have information sufficient to understand the parties’ arguments and the Court’s adjudication”).

Respectfully submitted, /s/ Deborah K. Brown Deborah K. Brown Attorney for Plaintiff Jane Street Group, LLC ce: All Counsel of Record (Via ECF) GRANTED.

SO ORDERED.

PAUL A, ENGELMIAYER United States District Judge Dated: August 5, 2024 New York, New York