* SCHNEIDER WALLACE Selendy|Gay COTTRELL KONECKY up

January 22, 2025

Via ECF and E-mail MEMO ENDORSED Hon. Katherine Polk Failla United States District Court Southern District of New York 40 Foley Square, Room 2103 New York, NY 10007 Re: In re Tether and Bitfinex Crypto Asset Litigation, 19-CV-09236 (KPF) — Letter Motion to File Letter with Amended Class Certification Filings Under Seal Dear Judge Failla, We represent Plaintiffs in the above-referenced action. Pursuant to Rule 9 of this Court’s Individual Rules of Practice in Civil Cases, we write to request permission to file Plaintiffs’ January 22, 2025 Letter with Amended Class Certification Filings (“Letter”) and the exhibits attached thereto, under temporary seal, to give Defendants an opportunity to request appropriate redactions. Plaintiffs’ Letter and the accompanying exhibits have been designated as Confidential or Attorneys’ Eyes Only by Defendants pursuant to the operative Stipulation and Order for the Production and Exchange of Confidential Materials. See Dkt. 151. Plaintiffs take no position as to Defendants’ characterization of that information as Confidential or Attorneys’ Eyes Only for the limited purposes of this filing. Plaintiffs recognize that confidential business interests must be weighed against the strong presumption of public access to the Courts. Video Software Dealers Ass’n v. Orion Pictures Corp. (In re Orion Pictures Corp.),

, 26 (2d Cir. 1994). Consistent with the Court’s prior orders, see Dkt. 590, Plaintiffs request permission to file unsealed copies of Plaintiffs’ Letter and accompanying exhibits on January 31, 2025, subject to redactions proposed by Defendants and redactions to comply with this Court’s prior orders.

hon. Katherine Polk Falla January 22, 2025

Respectfully submitted, /s/ Andrew R. Dunlap /s/ Todd M. Schneider Philippe Z. Selendy Todd M. Schneider (pro hac vice) Andrew R. Dunlap Matthew S. Weiler (pro hac vice) Oscar Shine Schneider Wallace Cottrell Konecky LLP Laura M. King 2000 Powell Street, Suite 1400 SELENDY GAY PLLC Emeryville, CA 94608 1290 Sixth Avenue [email protected] New York, NY 10104 [email protected] [email protected] [email protected] [email protected] [email protected] Interim Lead Counsel and Attorneys for Plaintiffs and the Proposed Class

cc: All Counsel of Record (via ECF)

Application GRANTED. The Clerk of Court is directed to maintain docket entry 592 under seal, viewable to the Court and the parties only. The Clerk of Court is further directed to terminate the pending motion at docket entry 591. Dated: January 24, 2025 SO ORDERED. New York, New York Kipthirn Palle (filo HON. KATHERINE POLK FAILLA UNITED STATES DISTRICT JUDGE