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

KIRKLAND & ELLIS LLP 2049 Century Park East Los Angeles, CA 90067 Sharre Lotfoltahi, P.C, United States To Cail Writer Directly: Facsimile: +1 213 680 8673 +1 310 552 4200 +1 310 552 5900 [email protected] www. kirkland.com November 20, 2025 pos f □ VIA CM/ECF Cc i yh 1 4 Hon. Alvin K, Hellerstein !

United States District Court Southern District of New York ° I United States Courthouse Pear! Street, Room 1050 New York, NY 10007 Re: Comcast Cable Communications Management, LLC, et al. v. MaxLinear, inc., Case No. 1:23-cv-04436-AKH Dear Judge Hellerstein: We represent Defendant-Counterclaim Plaintiff MaxLinear, Inc. (“MaxLinear”’) in connection with the above-captioned action. We write regarding the November 17, 2025 letter-motion filed by Plaintiffs-Counterclaim Defendants Comcast Cable Communications Management and Comcast Cable Communications, LLC (collectively, “Comecast”). See ECF 226. In that letter-motion, Comcast requested permission to file Comeast’s Reply to MaxLinear’s Responses to the Court’s October 17, 2025 Order Regulating Proceedings (“Comcast’s Reply”) with temporary redactions of information that MaxLinear and Entropic have designated confidential under the Protective Order entered by this Court. /d.; see also ECF (Comeast’s Reply). The Court granted Comcast’s letter-motion. See ECF 229.

MaxLinear now respectfully requests that the Court order that certain information redacted from Comcast’s Reply remain under permanent seal and has attached a proposed redacted version of Comcast’s Reply for the public docket as Exhibit 1. Comcast does not oppose the relief sought in this letter motion. Specifically, MaxLinear requests that the following redacted statements remain sealed, which are of the same substance and content for which the Court has already granted sealing for Comcast’s opening brief (see ECF 229): e The redacted statement on page 1 of Comcast’s Reply. e The redacted statement on page 2 of Comcast’s Reply, Austin Gay Area Beijing Boston Brissets Ghicage Dallas Frankfurt Hong Kong Houston Londen Miami Munich New York Paris Philadelphia Riyadh Salt Lake City Shanghe? Washington, D.C. KIRKLAND & ELLIS LLP The Honorable Alvin K. Hellerstein November 18, 2025 Page 2 * The redacted statement on page 4 of Comcast’s Reply. * The second redacted statement on page 10 of Comcast’s Reply.

Although Comcast did not attach the document to its Responses, each of the identified statements arises from the Patent Purchase Agreement (“PPA”) entered between MaxLinear and Entropic. Permanent sealing of the statements in Comeast’s Reply disclosing the substance of that document is proper.

The right of public access to judicial documents is presumptive, “not absolute.” Mirlis v. Greer, 952 F.3d 51, 59 (2d Cir. 2020) (quoting Nixon vy. 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, 2022 WL 101907, at *2 (S.D.N.Y. Jan. 11, 2022). There is no prejudice to the public here, “as, given the limited scope of the redactions,” nearly all of Comcast’s Reply will “be available to the public.” Thomas v. City of New York, 2025 WL 2671597, at *3 (E.D.N.Y. Sept. 18, 2025) (citing TufAmerica, Inc. v. Songs of Universal, Inc., 2025 WL 1225210, at *2 (S.D.N.Y. Apr. 24, 2025)).

This Court has already permitted the permanent sealing of the Patent Purchase Agreement between MaxLinear and Entropic following MaxLinear’s explanation that the PPA contained competitively sensitive information affecting both MaxLinear’s and non-party Entropic’s ability to effectively negotiate future transactions. See ECF 223. This Court also granted MaxLinear’s motion to permanently seal statements regarding the PPA contained in Comcast’s Responses to the Court’s October 17, 2025 Order Regulating Proceedings (“Comcast’s Responses”). See ECF 229. For the same reasons underlying this Court’s order permanently sealing the PPA and certain statements in Comcast’s Responses concerning the substance of the PPA, MaxLinear requests the permanent redaction of the statements in Comeast’s Reply that disclose the substance of the terms of the PPA.

For these reasons, MaxLinear respectfully requests that the redactions in Comcast’s Reply identified in this letter motion remain permanently sealed.! ! MaxLinear does not seck permanent sealing of the following temporary redactions in Comcast’s Responses: the redacted statement in footnote 4 on page 3; the redacted statement on page 9; and the first redacted statement on page 10.

KIRKLAND & ELLIS LLP The Honorable Alvin K. Hellerstein November 18, 2025 Page 3 Respectfully submitted, /s/ Sharre Lotfollahi, P.C.

Sharre Lotfollahi, P.C.

Cc: All Counsel of Record (via ECF)