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90 Park Avenue New York, NY 10016 212-210-9400 | Fax: 212-210-9444 Andrew J. Ligotti Direct Dial: +1 212 210 1286 Email: [email protected]

VIA ECF

December 13, 2024 Confirmation Email to: [email protected] Hon. Andrew L. Carter, Jr., U.S.D.J. United States District Court Southern District of New York 40 Foley Square, Room 435 New York, NY 10007 Re: Skechers U.S.A., Inc. et al. v. Marc Fisher Holdings LLC et al. 24-cv-06708 — Request to File Under Seal Dear Judge Carter: My firm represents Plaintiffs Skechers U.S.A., Inc. and Skechers U.S.A., Inc. Il (Skechers) in the above-referenced action. Pursuant to Rule 6 of the Court’s Individual Practices, Skechers respectfully submits this letter to request that the following documents be filed under seal, redacted copies of which are being filed via ECF contemporaneously with this request along with the proposed sealed document with the proposed redactions highlighted: ® Skechers’ Amended Complaint; and, e Exhibit 2: A copy of an agreement entitled “Summary of Commercial Terms” (the “Commercial Terms Agreement”) involving Defendants, provided to Skechers by Defendants’ counsel on the condition that Skechers treat the document as “HIGHLY CONFIDENTIAL — OUTSIDE COUNSEL’S EYES ONLY.” The foregoing documents contain material that Defendants provided to Skechers’ counsel pursuant to agreement that Skechers treat the material as “HIGHLY CONFIDENTIAL — OUTSIDE COUNSEL’S EYES ONLY.” According to Defendants’ counsel, the Commercial Terms Agreement contains Defendants’ highly sensitive business information. Skechers currently has no reason to dispute these representations. Skechers’ Amended Complaint references and quotes the Alston & Bird LLP www.alston.com Atlanta | Brussels | Century City | Charlotte | Chicago | Dallas | London | Los Angeles | New York | Raleigh | San Francisco | Silicon Valley | Washington, D.C.

Hon. Andrew J. Carter, Jr., U.S.D.J. December 13, 2024 Page 2

Commercial Terms Agreement extensively and attaches the Commercial Terms Agreement as a supporting exhibit. The proposed sealed document, comprising Skechers’ Amended Complaint and Exhibit 2 thereto, will be filed and electronically related to this letter in accordance with the Court’s rules. See Individual Practices, Rule 6.C.ii. Courts in this district routinely permit parties to seal or redact confidential business materials. See, e.g., Louis Vuitton Malletier S.A. v. Sunny Merch. Corp.,

(§.D.N.Y. 2015) (granting motion to seal “specific business information and strategies, which, if revealed, ‘may provide valuable insights into a company’s current business practices that a competitor would seek to exploit.’”); GoSmile, Inc. v. Levine,

(S.D.N.Y. 2011) (granting motion to seal documents containing defendants’ “highly proprietary material”). Accordingly, Skechers respectfully requests that the Court grant its request to file the above documents under seal.

Respectfully submitted,

80 ORDERED: La / los Andrew J. Ligotti HON ANDTEM i CARTE Ih Sere Counsel for Plaintiffs UMITED STATE nieraier Hine

December 20, 2024 New York, NY