SS&C Techs. Holdings, Inc. v. D. E. Shaw & Co.

ENDORSED. VPESMARAIS.u+ www.desmaraisllp.com NEW YORK Justin P.D. Wilcox SAN FRANCISCO Washington, D.C. Direct: 202-451-4905 WASHINGTON, DC [email protected] July 17, 2025 VIA ECE The Honorable Ona T. Wang United States District Court Pearl Street New York, NY 10007 Re: SS&C Techs. Holdings, Inc. v. D. E. Shaw & Co., No. 1:23-cv-09158-TMR-OTW Letter Motion to File Under Seal DESCO’s Answer and Counterclaims to Plaintiffs” Amended Complaint Dear Judge Wang: Defendant D. E. Shaw & Co., L.P. (““DESCO”) respectfully requests permission to file a redacted version of its Answer and Counterclaims to Plaintiffs’ Amended Complaint (“Answer”), with an unredacted version to be filed under seal.

While a presumption of public access applies to judicial documents, “[t]he weight to be given the presumption of access must be governed by the role of the material at issue in the exercise of Article III judicial power and the resultant value of such information to those monitoring the federal courts.” Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119 (2d Cir. 2006) (quoting United States v. Amodeo, 71 F.3d 1044, 1049 (2d Cir. 1995)). Courts must balance against the weight of the presumption countervailing factors such as “the privacy interests of those resisting disclosure.” /d. at 120 (quoting Amodeo, 71 F.3d at 1050).

The material that DESCO seeks to redact from its Answer is material that Plaintiffs allege are their trade secrets; namely, information relating to the pricing of Plaintiffs’ Geneva product.

Although DESCO does not agree that this information is trade secret, it seeks to file its Answer with minimal redactions out of an abundance of caution. These redactions are narrowly tailored only to material that presents a privacy concern.

Accordingly, DESCO respectfully submits this request to redact the public version of the Answer and file an unredacted copy of the Answer under seal.

Respectfully submitted, /s/ Justin P.D. Wilcox Justin P.D. Wilcox Application GRANTED. ce: Counsel of record (via ECF) SO ORDERED.