444 West Lake Street | Suite 1650 |Chicago, IL 60606 Phone: (312) 776-2517 Fax: (312) 276-2601 Email: [email protected] April 11, 2025 VIA ECF The Honorable Phillip M. Halpern United States District Court for the Southern District of New York 300 Quarropas Street, Room 530 White Plains, New York 10601 Re: DB Home Designs, LLC v. Matthew Wilhelm et al. Case No. 7:23-cv-11307 We write on behalf of the Plaintiff in the above-captioned case, DB Home Designs, LLC (‘Plaintiff’), pursuant to Rules 1B and 5B of Your Honor’s Individual Practices order. Plaintiff respectfully requests that this Court maintain under seal the documents that Plaintiff has filed simultaneous to this letter-motion under seal, which are Exhibits D and G to Plaintiff’s contemporaneously filed Motion in Limine. To be approved, any redaction or sealing of a court filing must be narrowly tailored to serve whatever purpose justifies the redaction or sealing and must be otherwise consistent with the presumption in favor of public access to judicial documents. See, e.g., Lugosch v. Pyramid Co. of Onondaga,

(2d Cir. 2006). In general, the parties’ consent or the fact that information 1s subject to a confidentiality agreement between litigants is not, by itself, a valid basis to overcome the presumption in favor of public access to judicial documents. See, e.g., In re Gen. Motors LLC Ignition Switch Litig.,

, at *4 (S.D.N.Y. Aug. 11, 2015). This is a trade secret case that fundamentally involves the most sensitive of business denied without prejudice. Exhibits D and G are not entitled to a protective order that allows the sealing. Plaintiff's letter motion (Doc. 80) fails to set forth on a (ECF No. 43). Exhibits D and G basis both the justification for the sealing of such documents, -otected in these exhibits includes that such sealing would be sufficiently narrowly tailored to safeguard the ‘de of Plaintiff’s busi Such confidential information. Plaintiff is referred to Rule 5(B) of this ice 0 AIMEE S_OUSITIESS. SUC Individual Practices, which includes directives on the filing of stomer names, file names, and sealed documents under seal and/or redacted only to the extent requests that the Court maintain to safeguard information sought to be filed under seal. Counsel is referred to paragraph 10 of the Stipulated Confidentiality Agreement and Order (Doc. 43). Respectfully submitted, Clerk of Court is respectfully directed to terminate the letter motion /s/ Daniel R. Saeedi at Doc. 80. BLANK ROME LLP (ew M. Halpern States District Judge White Plains, New York April 17, 2025