Lippes Math laS The motion to seal is granted, as Plaintiff's interest in maintaining the confidentiality of sensitive business information outweighs any presumption of public acces The Clerk of Court is respectfully directed to close Dkt. No. 22. March 31, 2025 SO ORDERED. 4 i Ay i Ces, VIA ECF Lo LEW#s J. LIMAN Honorable Lewis J. Liman United States District Judge United States District Court August 18, 2025 Southern District of New York 500 Pearl Street, Room 1620 New York, NY 10007 Re: Birdie Girl Golf, LLC v. Many Hats Enterprises, LLC Civil Action No. 1:24-cv-09425-LJL Dear Judge Liman: As you requested during our recent pre-trial conference, I am writing on behalf of Plaintiff Birdie Girl Golf, LLC (“Plaintiff”), in the above-referenced matter, to respectfully request leave to file the declaration of Lindzee Barrera and supporting Exhibits under seal containing confidential information in redacted form’, pursuant to Section 1(C) and Attachment A of Your Honor’s Individual Practice Rules and Section 6 of the Electronic Case Filing Rules and Instructions for this District. I regret the procedural oversight. The contemplated declaration is offered in support of Plaintiffs Opposition to Defendant’s Motion to Dismiss (D.I.11-14). Portions of the declaration and its attached exhibits disclose: (1) confidential information containing sensitive financial and company information associated with Plaintiff's business that is confidential and proprietary business information, the public release of which would be detrimental to Plaintiff's business or exploited by Plaintiffs competitors; and (2) personal identifying information of non-parties. The proposed redactions are narrowly tailored to exclude only a few financial dollar figures, personal identifying information of non-parties, and confidential and proprietary business information, leaving unsealed the substantive portions of the declaration that Plaintiff relies upon in support of Plaintiffs Opposition to Defendant’s Motion to Dismiss. The specific sensitive financial information and business information in the declaration is arguably confidential as that term is defined in New York Rule of Professional Conduct 1.6(a). The information is “likely to be embarrassing or detrimental to the client if exposed,” id., so we have an ethical obligation to “make reasonable efforts to prevent the . . . unauthorized disclosure or use of, or unauthorized access to” this information. Rule 1.6(c). Accordingly, to be able to provide the Court with a complete Opposition, we request leave to file the unredacted version of

' A public version and confidential version of the declaration of Lindzee Barrera with respective supporting Exhibits was filed concurrently with Plaintiff's Opposition to Defendant’s Motion to Dismiss on January 17, 2025. 420 Lexington Avenue, Suite 2005, New York, NY 10170 Phone: 332.345.4500 __lippes.com // //

the contemplated declaration under seal. Courts in this district have accepted such requests, going so far as to consider such motions on an in camera, ex parte basis. See, e.g., L.V. v. New York City Dep't of Educ., No. 19 Civ. 5451 (AT) (KHP),

, at *2 (S.D.N.Y. Nov. 17, 2020); Markowitz v. KBI Servs., Civil Action No. 21-mc-00397-LGS,

, at *2 (S.D.N.Y. Oct. 5, 2021) (collecting cases where sealing was appropriate because, among other reasons, “documents contained company's proprietary marketing strategies, product development, costs and budgeting information” (citation omitted)); Louis Vuitton Malletier S.A. v. Sunny Merch. Corp.,

(S.D.N.Y. 2015) (allowing filings in redacted form where “Plaintiffs’ proposed redactions are generally limited to 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.” (internal quotation marks omitted)). As per Your Honor’s Individual Practice Rules, this Letter Motion is filed in public view and explains the reasons for seeking to file certain information under seal. In support of this Letter Motion, Plaintiff contemporaneously files herewith a publicly redacted version of the contemplated declaration and exhibits with the proposed redactions. Additionally, Plaintiff contemporaneously files herewith under seal a copy of the unredacted declaration and exhibits with the redactions highlighted. We thank the Court for its consideration of this request.

Respectfully submitted, /s/ Matthew D. Asbell Matthew D. Asbell Chintan A. Desai Lippes Mathias LLP 420 Lexington Avenue Suite 2005 New York, NY 10170