`ELI LILLY AND COMPANY,
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`v.
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`Defendant.
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`Case 1:18-cv-12029-ADB Document 98 Filed 02/18/21 Page 1 of 4
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF MASSACHUSETTS
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`TEVA PHARMACEUTICALS
`INTERNATIONAL GMBH and
`TEVA PHARMACEUTICALS
`USA, INC.,
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`Plaintiffs,
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`Civil Action No.
`1:18-cv-12029-ADB
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`TEVA’S [UNOPPOSED] MOTION FOR LEAVE TO FILE
`CONFIDENTIAL DOCUMENTS UNDER SEAL
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`Pursuant to Local Rule 7.2 of the United States District Court for the District of
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`Massachusetts and the Protective Order (Dkt. 58), Plaintiffs Teva Pharmaceuticals International
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`GmbH and Teva Pharmaceuticals USA, Inc. (collectively, “Teva”) hereby move this Court for an
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`Order to impound or otherwise seal the following documents, on the ground that these documents
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`contain or reveal Defendant Eli Lilly and Company’s (“Lilly”) designated confidential and/or
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`proprietary information. Where possible, Teva has publicly filed redacted versions of each of the
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`below documents on the public ECF system:
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`1. Teva’s Letter to the Court Regarding ESI Search Terms (the “Letter”, Dkt. 99);
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`2. A document produced by Lilly bearing Bates nos. LLY-GALCA-00113904-24 and
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`marked as CONFIDENTIAL under the Protective Order (attached as Exhibit B to the
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`Letter); and
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`1
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`Case 1:18-cv-12029-ADB Document 98 Filed 02/18/21 Page 2 of 4
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`3. A document produced by Lilly bearing Bates nos. LLY-GALCA-00018440-49, and
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`marked as CONFIDENTIAL under the Protective Order (attached as Exhibit C to the
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`Letter).
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`Teva proposes that the Order sealing the exhibits described above be lifted only in the instance of
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`a further order of the Court, and that the sealed documents be kept in the clerk’s nonpublic
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`information file during any post-impoundment period.
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`WHEREFORE, Teva respectfully requests that the Court allow this Motion.
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`Case 1:18-cv-12029-ADB Document 98 Filed 02/18/21 Page 3 of 4
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`Dated: February 18, 2021
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`Respectfully submitted,
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`/s/ Elaine Herrmann Blais
`Douglas J. Kline (BBO# 556680)
`Elaine Herrmann Blais (BBO# 656142)
`Robert Frederickson III (BBO# 670111)
`Joshua S. Weinger (BBO# 690814)
`Alexandra Lu (BBO# 691114)
`Eric T. Romeo (BBO# 691591)
`GOODWIN PROCTER LLP
`100 Northern Avenue
`Boston, MA 02210
`Tel.: (617) 570-1000
`Fax: (617) 523-1231
`dkline@goodwinlaw.com
`eblais@goodwinlaw.com
`rfrederickson@goodwinlaw.com
`jweinger@goodwinlaw.com
`alu@goodwinlaw.com
`eromeo@goodwinlaw.com
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`I. Neel Chatterjee (pro hac vice)
`GOODWIN PROCTER LLP
`601 Marshall St.
`Redwood City, CA 94063
`Tel.: (650) 752-3100
`Fax: (650) 853-1038
`nchatterjee@goodwinlaw.com
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`Natasha Daughtrey (pro hac vice)
`GOODWIN PROCTER LLP
`601 S. Figueroa St.
`Los Angeles, CA 90017
`Tel.: (213) 426-2500
`Fax: (213) 623-1673
`ndaughtrey@goodwinlaw.com
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`Attorneys for Plaintiffs
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`3
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`Case 1:18-cv-12029-ADB Document 98 Filed 02/18/21 Page 4 of 4
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`LOCAL RULE 7.1 CERTIFICATION
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`I certify that counsel for the Parties conferred in good faith regarding the relief sought in
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`this Motion. Defendant’s counsel does not oppose the relief sought in this motion.
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`/s/ Elaine Herrmann Blais
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`CERTIFICATE OF SERVICE
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`I certify that, on February 18, 2021, the foregoing document was filed with the Clerk of
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`the Court and served upon all counsel of record via the Court’s CM/ECF system.
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`/s/ Elaine Herrmann Blais
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`4
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