Sportvision, Inc v. MLB Advanced Media L.P.

BOLIMAN MEMO ENVUROLU ISMAIL Sav Ml 9 TOMASELL \) SAR BRENNAN & Alan Littmann BAUM LLP UNITED STATES Te [email protected] Dated: 12/30/24 Exhibit B to MLBAM's Objection will be provisionally sealed, but sealing based only on the designation in the protective order is not appropriate.

SENT VIA ECF The party interested in permanently sealing Exhibit B is directed to make a showing under Lugosch v. December 24, 2024) amid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) by January 27, 2025.

Honorable Valerie Figueredo Magistrate Judge United States District Court for the Southern District of New York Daniel Patrick Moynihan United States Courthouse Pearl Street, Courtroom 17A New York, NY 10007-1312 Re: Sportvision, Inc. et al. v. MLB Advanced Media, L.P., No. 18-cv-03025-PGG-DCF Dear Judge Figueredo: Defendant MLB Advanced Media, L.P. (“MLBAM”) submits this letter-motion to respectfully request the Court’s approval to seal Exhibit B to MLBAM’s Objection to Magistrate Judge’s Memo Endorsement Order of Plaintiffs’ Letter Seeking a Partial Lift of the Stay for the reasons detailed in its contemporaneously-filed declaration. Exhibit B is a true and correct copy of the Export Report of Plaintiffs’ Expert Mr. Philip Green, dated March 17, 2023 (“Green Report’).

Portions of the Green Report have either been designated or describe in detail materials that have been designated “Confidential,” “Highly Confidential — Limited,” or “Highly Confidential — Attorneys’ Eyes Only” by Plaintiffs pursuant to the Stipulated Amended Confidentiality Agreement and Protective Order (Dkt. No. 222).

For these reasons, MLBAM respectfully requests that the Court grant its letter-motion to seal.

Sincerely, Alan Littmann Chicago 200 South Wacker, 22nd Floor, Chicago, IL 60606 Dallas 7557 Rambler Road, Suite 1450, Dallas, TX 75231 Santa Monica 100 Wilshire Boulevard, Suite 1760, Santa Monica, CA 90401 goldmanismail.com