Comcast Cable Communications Management, LLC, et al. v. MaxLinear, Inc.

2020 K Street NW Attorneys at Law in Suite 406 Chicago Washington, D.C. 20006 Denver Tei: 202-372-6300 Indianapolis Fax: 202-372-9599 Madison www.quarles.com Milwaukee Minneapolis Naples Phoenix San Diego St. Louis Fampa Tiicson Washington, D.C. October 2, 2025 PF VIA ECF ; YW The Honorable Alvin K. Hellerstein iv United States District Court for the Southern District of New York Daniel Patrick Moynihan United States Courthouse Pearl Street New York, NY 10007 Re: Comcast Cable Communications Management, LLC, et al. v. MaxLinear, Inc., No. 23-cv-04436-AKH Dear Judge Hellerstein: This firm represents subpoenaed nonparty Broadcom Corporation (“Broadcom”) in the above-referenced matter. I write pursuant to the Amended Stipulated Protective Order (ECF No. 118) and Rule 4(B)(i) of this Court’s Individual Rules to respectfully request that certain exhibits to the Letter Motion for Discovery filed on September 29, 2025 (ECF No. 210) (“Joint Letter”) remain permanently sealed.

Comcast Exhibit C to the Joint Letter consists of excerpts of the deposition transcript of Broadcom employee Niki Pantelias, who testified as a corporate representative on behalf of Broadcom in response to the parties’ subpoenas to Broadcom. Ms. Pantelias’s testimony set forth in Exhibit C contains confidential information concerning Broadcom’s internal design and business processes.

MaxLinear Exhibit 8 consists of additional excerpts from Ms. Pantelias’s deposition transcript. The excerpts beginning on page 10 of the document likewise contain confidential information concerning Broadcom’s internal design processes.

A party may file documents under seal where “closure is essential to preserve higher values and is narrowly tailored to service that interest.” Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 120 (2d Cir. 2006) (citation omitted). “The interest in protecting ‘business information that might harm a litigant’s competitive standing’ has, at a minimum, been The Honorable Alvin K. Hellerstein Page 2 recognized by the Supreme Court as potentially sufficient to defeat the common law presumption” of access. Standard Inv. Chartered, Inc. v. Nat'l Ass’n of Sec. Dealers, Ine., No. 07-CV-2014 (SWK), 2008 WL 199537, at *8 (S.D.N.Y. Jan. 22, 2008) (quoting Nixon vy. Warner Commic’ns, Inc., 435 U.S, 589, 598 (1978)).

Here, Broadcom seeks to maintain the confidentiality of testimony reflecting Broadcom’s sensitive internal business and design practices regarding its products. In particular, Ms. Pantelias’s testimony reflects aspects of the decision-making process during the design of the Broadcom products at issue in this case, as well as certain technical innovations and development milestones that are internal and confidential to Broadcom. Broadcom would suffer competitive harm if this information were to be made public, as it would provide visibility to Broadcom’s competitors as to how Broadcom designs its products. Thus, maintaining the documents under seal is warranted.

Further, Broadcom is submitting with this letter redacted versions of the exhibits to ensure that only those portions requiring confidentiality remain sealed. Broadcom’s requested closure is thus narrowly tailored.

For the foregoing reasons, Broadcom respectfully requests that the Court accept the narrowly tailored redacted versions of Exhibits C and 8, and maintain the unredacted versions of Exhibits C and 8 under seal permanently.

Respectfully submitted, /s/ Lauren Bolear Lauren Bolcar Enclosures ce: All Counsel of Record (via ECF)