Vinci Brands LLC v. Coach Services, Inc.

55 WEST MONROE STREET, SUITE 1200 CHICAGO, IL 60603-5127 DICKINSON/WRIGHT»riic hunt succu.auue http://www.dickinsonwright.com PAUL A. DEL AGUILA [email protected] 312-377-7862 May 6, 2025 VIA ECF The Honorable Valerie Figueredo Daniel Patrick Moynahan United States Courthouse Pearl Street New York, NY 10007 Re: — Vinci Brands, LLC v. Coach Servs. Inc., et al., Civil Action No. 1:23-cv-05138 Vinci’s Letter Motion to Seal Exhibit A to Letter Motion for Relief from Protective Order.

Dear Judge Figueredo: Pursuant to Your Honor’s Individual Rule I(g)(2), Vinei Brands LLC (“‘Vincv’) respectfully requests Your Honor’s approval to provisionally seal Exhibit A to Vinci’s Letter Motion for Relief from Protective Order.

In ruling on a motion to seal, Your Honor must consider “the privacy interests of those resisting disclosure.” Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 120 (2d Cir. 2006) (quoting United States v. Amodeo, 71 F.3d 1044, 1050 (2d Cir. 1995)). On February 7, 2024, this Court so ordered a stipulation and confidentiality agreement (“Protective Order”). Pursuant to the Protective Order, parties may mark documents produced in discovery and deposition transcripts as “Confidential” and “Highly Confidential — Attorney’s Eyes Only.”

On April 24, 2024, Vinci took the deposition of Case-Mate, Inc. employee, Kristen Roney.

Case-Mate has designated portions of Ms. Roney’s deposition transcript as Confidential. Exhibit A to Vinci’s Letter Motion for Relief from Protective Order contains two pages that have been designated as Confidential. Pursuant to the protections set forth in the Protective Order, Vinci requests that Exhibit A be provisionally sealed until Case-Mate has an opportunity to move to seal.

Accordingly, Vinci has filed an unredacted copy of Exhibit A under seal pending further Order from the Court.

ARIZONA CALIFORNIA COLORADO FLORIDA ILLINOIS KENTUCKY MICHIGAN NEVADA OHIO TENNESSEE TEXAS WASHINGTON DC TORONTO . . DICKINSON WRIGHT PLLC Hon. Valerie Figueredo May 6, 2025 Page 2 Respectfully submitted, /s/ Paul A. Del Aguila Paul A. Del Aguila Counsel for Vinci Brands LLC ce: All Counsel of Record \ | \ \ WIAA HON. VALERIE FIGUEREDO UNITED STATES MAGISTRATE JUDGE Dated: 5/7/25 The motion for a provisional seal is GRANTED. If Case- Mate, Inc. seeks to permanently seal the document referenced herein, Case-Mate, Inc. is directed to make a showing under Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) by May 17, 2025. The Clerk of Court is directed to maintain the viewing restrictions at ECF No. and terminate the motion at ECF No. 817.

ARIZONA CALIFORNIA COLORADO FLORIDA ILLINOIS KENTUCKY MICHIGAN NEVADA OHIO TENNESSEE TEXAS WASHINGTON DC TORONTO