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Case 2:20-cv-07872-GW-PVC Document 359-1 Filed 05/04/24 Page 1 of 4 Page ID
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`#:40157
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`UNITED STATES DISTRICT COURT
`FOR THE CENTRAL DISTRICT OF CALIFORNIA
`Case No. 2:20-cv-07872-GW-PVC
`NANTWORKS, LLC, a Delaware
`limited liability company, and
`
`NANT HOLDINGS IP, LLC, a
`Hon. George H. Wu
`Delaware limited liability company,
`
`[PROPOSED] ORDER GRANTING
`
`DEFENDANTS’ APPLICATION TO
`Plaintiffs,
`FILE DOCUMENTS UNDER SEAL
`
`
`vs.
`
`BANK OF AMERICA
`CORPORATION, a Delaware
`corporation, and BANK OF
`AMERICA, N.A., a national banking
`association,
`
`
`
`
`Defendants.
`
`
`
`1
`
`[PROPOSED] ORDER GRANTING APPLICATION TO SEAL
`CASE NO. 2:20-CV-07872-GW-PVC
`
`

`

`Case 2:20-cv-07872-GW-PVC Document 359-1 Filed 05/04/24 Page 2 of 4 Page ID
`
`#:40158
`
`Upon consideration of the Defendants BANK OF AMERICA CORPORATION
`and BANK OF AMERICA, N.A.’s (collectively, “Defendants”) Application to File
`Under Seal, and for good cause shown, the Court hereby rules as follows:
`IT IS HEREBY ORDERED that Defendants’ Application to File Under Seal is
`GRANTED and the following documents and portions of documents may be filed
`under seal.
`
`Document Description
`Exhibit 1 to the Declaration of Danielle
`Williams in Support of the Defendants’
`Motion for Partial Summary Judgment
`of Non-infringement of the Asserted
`Claims of the Asserted Patents
`
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`Nature of Information to be Sealed
`Designated by Plaintiffs in its entirety as
`“HIGHLY CONFIDENTIAL –
`ATTORNEYS’ EYES ONLY” and
`“HIGHLY CONFIDENTIAL –
`SOURCE CODE,” and contains excerpts
`of documents designated by Bank of
`America and third-party Mitek as
`“Highly Confidential – Attorneys’ Eyes
`Only.” Plaintiffs and Mitek do not
`oppose sealing this exhibit in its entirety.
`Designated by Defendants as “HIGHLY
`CONFIDENTIAL – ATTORNEYS’
`EYES ONLY” under the parties’
`stipulated protective orders (Dkt. Nos.
`102, 210).
`Designated by Defendants as “HIGHLY
`CONFIDENTIAL – ATTORNEYS’
`EYES ONLY” under the parties’
`stipulated protective orders (Dkt. Nos.
`
`Exhibit 2 to the Declaration of Danielle
`Williams in Support of Defendants’
`Motion for Partial Summary Judgment
`of Non-infringement of the Asserted
`Claims of the Asserted Patents
`Exhibit 3 to the Declaration of Danielle
`Williams in Support of Defendants’
`Motion for Partial Summary Judgment
`of Non-infringement of the Asserted
`
`
`
`2
`
`[PROPOSED] ORDER GRANTING APPLICATION TO SEAL
`CASE NO. 2:20-CV-07872-GW-PVC
`
`

`

`Case 2:20-cv-07872-GW-PVC Document 359-1 Filed 05/04/24 Page 3 of 4 Page ID
`
`#:40159
`
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`Document Description
`Claims of the Asserted Patents
`Exhibit 4 to the Declaration of Danielle
`Williams in Support of Defendants’
`Motion for Partial Summary Judgment
`of Non-infringement of the Asserted
`Claims of the Asserted Patents
`
`Exhibit 5 to the Declaration of Danielle
`Williams in Support of Defendants’
`Motion for Partial Summary Judgment
`of Non-infringement of the Asserted
`Claims of the Asserted Patents
`Exhibit 6 to the Declaration of Danielle
`Williams in Support of Defendants’
`Motion for Partial Summary Judgment
`of Non-infringement of the Asserted
`Claims of the Asserted Patents
`Exhibit 7 to the Declaration of Danielle
`Williams in Support of Defendants’
`Motion for Partial Summary Judgment
`of Non-infringement of the Asserted
`Claims of the Asserted Patents
`
`Nature of Information to be Sealed
`102, 210).
`Designated by Defendants’ in its entirety
`as “HIGHLY CONFIDENTIAL –
`ATTORNEYS’ EYES ONLY” and
`“HIGHLY CONFIDENTIAL –
`SOURCE CODE,” and contains excerpts
`of documents designated by Bank of
`America and third-party Mitek as
`“Highly Confidential – Attorneys’ Eyes
`Only.” Plaintiffs and Mitek do not
`oppose sealing this exhibit in its entirety.
`Designated by Defendants as “HIGHLY
`CONFIDENTIAL – ATTORNEYS’
`EYES ONLY” under the parties’
`stipulated protective orders (Dkt. Nos.
`102, 210).
`Designated by Defendants as “HIGHLY
`CONFIDENTIAL – ATTORNEYS’
`EYES ONLY” under the parties’
`stipulated protective orders (Dkt. Nos.
`102, 210).
`Designated by third-party Mitek as
`“Highly Confidential – Attorneys’ Eyes
`Only.” Plaintiffs and Mitek do not
`oppose sealing this exhibit in its entirety.
`
`
`
`3
`
`[PROPOSED] ORDER GRANTING APPLICATION TO SEAL
`CASE NO. 2:20-CV-07872-GW-PVC
`
`

`

`Case 2:20-cv-07872-GW-PVC Document 359-1 Filed 05/04/24 Page 4 of 4 Page ID
`
`#:40160
`
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`Document Description
`Exhibit 8 to the Declaration of Danielle
`Williams in Support of Defendants’
`Motion for Partial Summary Judgment
`of Non-infringement of the Asserted
`Claims of the Asserted Patents
`Exhibit 9 to the Declaration of Danielle
`Williams in Support of Defendants’
`Motion for Partial Summary Judgment
`of Non-infringement of the Asserted
`Claims of the Asserted Patents
`
`Nature of Information to be Sealed
`Designated by Defendants in its entirety
`as “HIGHLY CONFIDENTIAL –
`ATTORNEYS’ EYES ONLY.”
`Plaintiffs do not oppose sealing this
`exhibit in its entirety.
`Designated by Defendants in its entirety
`as “HIGHLY CONFIDENTIAL –
`ATTORNEYS’ EYES ONLY.”
`Plaintiffs do not oppose sealing this
`exhibit in its entirety.
`
`
`
`IT IS SO ORDERED.
`
`
`DATED: ________________
`
`
`By
`
`
`Honorable George H. Wu
`United States District Judge
`
`
`
`
`
`4
`
`[PROPOSED] ORDER GRANTING APPLICATION TO SEAL
`CASE NO. 2:20-CV-07872-GW-PVC
`
`

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