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`October 30, 2023
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`VIA ELECTRONIC FILING
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`The Honorable Maryellen Noreika
`United States District Court
`844 N. King Street
`Wilmington, DE 19801
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`Re:
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`VB Assets, LLC v. Amazon.com, Inc., et al., C.A. No. 19-01410-MN
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`Dear Judge Noreika:
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`We received the Court’s Order regarding sealing of VB Assets’ motion for leave to
`amend its trial exhibit list, Amazon’s response to that motion, and the accompanying declaration
`of Melanie Gens (D.I. 254, 256, 257). Amazon is working to secure a declaration to support a
`request for modest redactions to the public versions of these filings. The declaration will likely
`be from Ms. Gens, the witness whose declaration was submitted in support of Amazon’s
`opposition, or other members of the Alexa team. Ms. Gens is located in Honolulu, Hawaii, and
`could not be reached as of the time of this letter given the 6-hour time difference. Other
`members of the Alexa team are likewise based in Seattle, Washington.
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`Accordingly, Amazon respectfully requests an extension until 5:00 p.m. ET to submit a
`motion to seal and accompanying declaration in support of a sealing request. In light of the
`Court’s Order, any request for sealing will be narrowly tailored to cover only highly confidential
`and competitively sensitive information, largely from paragraphs 3 and 4 to Ms. Gens’
`declaration, and the portions of the brief that quote from those sections.
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`cc: All Counsel of Record (via electronic mail)
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`Respectfully,
`/s/ Andrew C. Mayo
`Andrew C. Mayo (#5207)
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