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September 16, 2025 [x aS i gr yn | ¢ AP pete ob ln Via ECF < fe 4 The Honorable Colleen McMahon 4w United States District Court spt te Southern District of New York { Kv 500 Pearl Street, Courtroom 24A Aw? cf New York, NY 10007 halal i WW, □□

Re: Hoar v. Launch Pad Payment Services Corporation et al. we I □ te Case No. 1:24-cv-06195 (S.D.N.Y.) ye Ww a Dear Judge McMahon: i) Pursuant to your Honor’s September 9, 2025 Order (Dkt. 67) Defendants Launch Pad Payment Services Corp. and Hotmart BV respectfully identify the following information as lL confidential and request that it be maintained under seal. HOTMART_0000778, an image of which appears in Plaintiffs’ August 14, 2025 Letter □ Motion (Dkt. 65 at 3), contains confidential financial information, namely, the Defendants’ account number and Tax ID. Defendants request that the unredacted version of this letter remain under seal, and that the account number and Tax ID remain redacted in the public version of the filing. Defendants have carefully considered the information filed under seal, currently redacted in the public version of this letter (Dkt. 63), and have proposed only these two limited, targeted redactions of confidential financial information. While the original redactions included three A images in their entirety along with two additional sentences (Dkt. 63 at 3, 8. 9), Defendants propose □□ continued redaction of only two numbers: their account number and Tax ID. □□ This comports with the Lugosch factors, which govern a motion to seal. Lugosch v. Pyramid Co. of Onondaga,

(2d Cir. 2006) (cleaned up and internal quotation □ marks and citations omitted), In determining whether a “common law presumption of access” i □□ a” ‘ quinn emanuel urquhart & sullivan, tp pe □□ ABU DHABI | ATLANTA | AUSTIN | BEIJING | BERLIN | BOSTON | BRUSSELS | CHICAGO| DALLAS | DOHA HAMBURG | HONG KO Pe UST) □□□ LONDON | LOS ANGELES | MANNHEIM | MIAMI| MUNICH | NEUTLLY-LA DEFENSE | NEW YORK PARIS| PERTH RIVADH SALT cing □□ SAN FRANCISCO | SEATTLE | SHANGHAI ! SILICON VALLEY | STUTTGART | SYDNEY | TCKYO! WASHINGTON. DC wiuwuddton 7URKH 7, =

a “ee a court must first conclude that the documents at issue are indeed judicial documents.” - “In order to be designated a judicial document, the item filed must be relevant to the performance of the judicial function and useful in the judicial process.” Jd. “Once the court h determined that the documents are judicial documents..., it must denmine the weight of a presumption,” which is “governed by the role of the material at issue in the exercise of Article II] oe power and the resultant value of such information to those monitoring the federal courts,” aie ae the weight of the presumption of access, the court must balance B° rations against it.

Such countervailing factors include but are not limited (0... the privacy Interests of those resisting disclosure.” Jd While the letter motion is a judicial document, its importance to the judicial function and process is less than that of a dispositive motion. See In re New York City Policing During Summer 2020 Demonstrations,

, 253 (S.D.N.Y. 2022) (“where the document is submitted in connection with a discovery motion, rather than a dispositive motion, the presumption of access is entitled to only ‘modest’ weight”). There is no “value” in revealing a financial account number and Tax ID to the public, and the countervailing considerations are more than sufficient to warrant redacting this information. See Zou v. Han,

, at *7 (E.D.N.Y. Apr. 19, 2024) (permitting redaction of Tax ID and bank account number from exhibits to discovery motion even where first Lugosch factor weighed in favor of public access). Accordingly, Defendants respectfully request that the foregoing information remain under seal. Plaintiffs, per their August 14, 2025 motion to file under seal (Dkt. 64), do not object to this request. Plaintiffs did not warn Defendants of their filing, nor seek Defendants’ consent to file any documents publicly, which Defendants would have given subject to the request above.

Respectfully submitted, /s/ Mario O. Gazzola Mario O. Gazzola Counsel for Defendants Launch Pad Payment Services Corporation and Hotmart BV cc: All Counsel of Record via ECF