`
`!
`
`
`
`12424
`Wilshire Boulevard
`12th Floor
`Los Angeles
`California
`90025
`
`Tel 310.826.7474
`Fax 310.826.6991
`www.raklaw.com
`
`
`
`
`
`
`September 23, 2022
`
`
`Filed Via ECF
`
`Hon. Paul G. Gardephe
`United States District Court
`Southern District of New York
`40 Foley Square, Room 2204
`New York, New York 10007
`
`Re: Network-1 Technologies, Inc. v. Google LLC, et al.,
`
`Case Nos. 1:14-cv-2396-PGG & 1:14-cv-9558-PGG
`
`
`Dear Judge Gardephe:
`
`I write on behalf of Plaintiff Network-1 Technologies, Inc. (“Network-1”) to request leave to
`file under seal several documents that will be submitted in connection with Network-1’s
`Supplemental Brief in Opposition to Google’s Motion for Summary Judgment. Specifically,
`Network-1 requests leave to file undredacted copies of Network-1’s Brief, and accompanying
`Exhibits 86, 87, and 88 under seal. Each of these documents contains material and information
`designated by Google under the Protective Order in these matters. Because the relevant
`information is Google’s information, Network-1 requests that the Court permit filing of these
`documents under seal. Google has indicated that, pursuant to the Court’s Individual Practices,
`Google will submit a letter explaining its position on sealing by September 26, and provide
`Network-1 with redactions for any portions of these materials Google requests to remain sealed by
`that time as well. Network-1 will then file a public, redacted version of its submission.
`
`
`
`Case 1:14-cv-02396-PGG-SN Document 273 Filed 09/23/22 Page 2 of 2
`
`!
`
`Hon. Paul G. Gardephe
`September 23, 2022
`Page 2
`
`
`
`
`Dated: September 23, 2022
`
`Respectfully submitted,
`
`RUSS, AUGUST & KABAT
`BY: s/ Brian D. Ledahl
`
`Marc A. Fenster (pro hac vice)
`Brian D. Ledahl (pro hac vice)
`Adam S. Hoffman (pro hac vice)
`Paul A. Kroeger (pro hac vice)
`Jacob R. Buczko (pro hac vice)
`Amy E. Hayden (pro hac vice)
`12424 Wilshire Blvd. 12th Floor
`Los Angeles, CA 90025
`Phone: (310) 826-7474
`Fax: (310) 826-6991
`mfenster@raklaw.com
`bledahl@raklaw.com
`ahoffman@raklaw.com
`pkroeger@raklaw.com
`jbuczko@raklaw.com
`ahayden@raklaw.com
`
`Charles R. Macedo
`AMSTER, ROTHSTEIN &
`EBENSTEIN LLP
`90 Park Avenue
`New York, NY 10016
`Phone: (212) 336-8074
`Fax: (212) 336-8001
`cmacedo@arelaw.com
`
`
`Attorneys for Network-1
`Technologies, Inc.
`
`
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