A&O SHEARMAN 599 Lexington Avenue New York, NY 10022-6069 +1.212.848.4000

[email protected] 212.848.4424 Via CM/ECF October 6, 2025 Hon. Timothy M. Reif 1 Federal Plaza New York, New York 10278 Re: SS&C Tech. Holdings, Inc. et al. v. D. E. Shaw & Co., L.P., No. 1:23-cv-09158-TMR-OTW — Letter Motion to Seal Dear Judge Reif: SS&C Technologies Holdings, Inc. and Advent Software, Inc. (collectively, “SS&C”) respectfully submits this request to file under seal unredacted exhibits filed with SS&C’s memorandum of law in support of its motion to dismiss the counterclaims filed by D. E. Shaw & Co., L.P. (““DESCO”) and an unredacted version of its memorandum of law in support of its motion to dismiss. While a presumption of public access applies to judicial documents, e.g., documents relevant to the performance of the judicial function and useful in the judicial process, the weight of the presumption is “governed by the role of the material at issue” and the resulting value of such information to the public. Lugosch v. Pyramid Co. of Onondaga,

(2d Cir. 2006). Courts must also balance against the weight of the presumption of any countervailing factors such as “the privacy interests of those resisting disclosure,”

, including “the degree to which the subject matter is traditionally considered private rather than public” and the “nature and degree of injury” resulting from disclosure. United States v. Amodeo,

(2d Cir. 1995). The exhibits and portion of the memorandum of law SS&C seeks to redact consist of or reflect commercially sensitive and trade secret information relating to SS&C’s pricing of Geneva and related Geneva services. This type of information is regularly deemed protected because disclosure “might harm a litigant’s competitive standing.” Jn re Parmalat Sec. Litig.,

(S.D.N.Y. 2009) (quoting Nixon v. Warner Commce’ns, Inc.,

(1978)); Dodona I, LLC v. Goldman, Sachs & Co.,

(S.D.N.Y. 2015). This Court has granted similar sealing requests. E.g., ECF No. 60.

AOSHEARMAN.COM Allen Overy Shearman Sterling US LLP is a limited liability partnership organized under the laws of the State of Delaware. Allen Overy Shearman Sterling US LLP is affiliated with Allen Overy Shearman Sterling LLP, a limited liability partnership registered in England and Wales with registered number OC306763 and with its registered office at One Bishops Square, London E1 6AD. It is authorized and regulated by the Solicitors Regulation Authority of England and Wales (SRA number 401323). The term partner is used to refer to a member of Allen Overy Shearman Sterling LLP or an employee or consultant with equivalent standing and qualifications. A list of the members of Allen Overy Shearman Sterling

October 6, 2025

Accordingly, SS&C respectfully submits this request to file under seal unredacted exhibits filed with SS&C’s memorandum of law in support of its motion to dismiss the counterclaims and an unredacted version of its memorandum of law. Respectfully submitted, /s/ Stephen Fishbein Stephen Fishbein

ce: Counsel of record (via ECF)

SO ORDERED DATE October 22, 2025

TIMOTHY M. REIF, JUDGE, UNITED STATES COURT OF INTERNATIONAL TRADE SITTING BY DESIGNATION UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK