Timothy Hoar, on behalf of himself and all others similarly situated v. Launch...

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK TIMOTHY HOAR, on behalf of himself and all others similarly situated, Case No. 1:24-cv-06195-CM Plaintiffs, v. MOTION TO-FILE UNDER SEAL- LAUNCH PAD PAYMENT SERVICES ae i!

CORPORATION and HOTMART BV, ec ay i| Defendant. | pov libas | Plaintiffs hereby move to file under seal the unredacted version of the August 14, 2025 letter- motion filed with Court in redacted form earlier today (ECF No. 63).

Plaintiffs respectfully request permission to file under seal the August 14, 2025 letter-motion because it contains information produced by defendant during discovery that defendant has marked as confidential In ruling on a motion to seal, the Court must balance the competing interests at stake, which include the public’s interest in access to judicial documents, and the privacy interest of the party resisting disclosure. Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119-20 (2d Cir. 2006).

Dated: August 14, 2025 Respectfully submitted, REESE LLP fe Rem /s/ Michael R. Reese eo pied Michael R. Reese bit f, 100 West 93 Street, 16" Floor Uo } New York, New York 10025 /T flor Telephone: (212) 643-0500 IN ety mreese(@reesellp.com fink f Co-Counsel for Plaintiffs and the Proposed Class cf mobo lA Fidteidi LLL,