KIRKLAND & ELLIS LLP

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November 5, 2025 VIA CM/ECF Hon. Alvin K. Hellerstein United States District Court Southern District of New York United States Courthouse 500 Pearl Street, Room 1050 New York, NY 10007

Re: Comcast Cable Communications Management, LLC, et al. v. MaxLinear, Inc., Case No. 1:23-ev-04436-AKH Dear Judge Hellerstein: We represent Defendant-Counterclaim Plaintiff MaxLinear, Inc. (‘““MaxLinear”) in connection with the above-captioned action. We write pursuant to Your Honor’s Individual Rules and the Protective Order entered by the Court to respectfully request permission to file the following document under seal: * Patent Purchase Agreement between MaxLinear, Inc. and MaxLinear Communications LLC and Entropic Communications, LLC (“the PPA”). The right of public access to judicial documents is presumptive, “‘not absolute.” Mirlis v. Greer,

(2d Cir, 2020) (quoting Nixon v. Warner Comme’ns, Inc., 435 U.S, 589, 598 (1978)). “Courts in this Circuit regularly seal information that might disclose trade secrets or confidential business information.” Jacovacci v. Brevet Holdings, LLC,

, at *2 (S.D.N.Y. Jan. [1, 2022). Confidential business information includes information that, if public, could harm a party’s competitive standing and ability to effectively negotiate future agreements. The PPA between MaxLinear and Entropic is confidential business information. Placing the PPA in the public record could “harm [MaxLinear’s and Entropic’s] competitive standing,” which the Supreme Court has recognized as a basis “to defeat the common law presumption of access.” Standard Inv. Chartered, Inc. v, Nat’ Ass’n of Secs. Dealers, Inc.,

, at *8 (S.D.N.Y, Jan. 22, 2008) (quoting Nixon, 435 U.S. at 598), aff'd Standard Inv. Chartered, Inc. v. Fin. Indus. Regul. Auth., Ind.,

, 617 (Qd Cir, 2009), Disclosure of the PPA threatens MaxLinear’s and Entropic’s competitive standing by, for

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KIRKLAND & ELLIS LLP

The Honorable Alvin K. Hellerstein November 5, 2025 Page 2 example, enabling competitors to “deduce [their] negotiation tactics.” Standard Inv., 347 F. App’x at 617. Thus, disclosure “would likely result in competitive harm,” and sealing is warranted. News Corp. v. CB Nepiune Holdings, LLC,

, at *2 (S.D.N.Y. Aug. 4, 2021); see also Rubik’s Brand Ltd. v. Flambeau, Inc.,

, at *1 (S.D.N.Y. Mar. 22, 2021) (sealing documents whose disclosure “could harm the [company’s] and/or its business partners by disadvantaging them in future” negotiations). Moreover, sealing the PPA will not impair the public’s interest in transparent judicial proceedings. From the public’s perspective, the important information regarding the PPA is that MaxLinear sold patents to Entropic, who then sued Comcast for infringing those patents. That information has already been disclosed to the public, including in this case. See ECF 142, 20, 22 (Comcast alleging that MaxLinear “assigned [its] rights in certain U.S. patents ... to [Entropic]’ and that Entropic filed infringement suits against Comcast); ECF 148 {J 20, 22 (MaxLinear admitting that it “assigned [its] rights in certain U.S. patents ... to [Entropic]” and that Entropic subsequently sued Comcast for infringement), Beyond that, the specific commercial terms of the assignments are not relevant to the public and are not the gravamen of Comcast’s claims against MaxLinear in this action. SEC v. Ripple Labs, Inc.,

, at *6 (S.D.N.Y. May 16, 2023); see also Graczyk v. Verizon Comme'ns, Inc.,

, at *9 (S.D.N.Y. Mar. 24, 2020). So not only are MaxLinear’s and Entropic’s interests in keeping the information confidential high, but the need for public access is low. For these reasons, good cause exists to seal the PPA. MaxLinear respectfully requests permission to file the PPA under permanent seal. Comcast does not oppose MaxLinear’s motion to file the PPA under seal, Respectfully submitted, /s/ Atif Khawaja Atif Khawaja, P.C. Ce: All Counsel of Record (via ECF)

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