`Wilshire Boulevard
`12th Floor
`Los Angeles
`California
`90025
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`Tel 310.826.7474
`Fax 310.826.6991
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`www.raklaw.com
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`Case 1:14-cv-02396-PGG-SN Document 284 Filed 10/28/22 Page 1 of 2
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`October 28, 2022
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`Filed Via ECF
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`Hon. Paul G. Gardephe
`United States District Court
`Southern District of New York
`40 Foley Square, Room 2204
`New York, New York 10007
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`Re: Network-1 Technologies, Inc. v. Google LLC, et al.,
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`Case Nos. 1:14-cv-2396-PGG-SN & 1:14-cv-9558-PGG-SN
`Dear Judge Gardephe:
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`I write on behalf of Plaintiff Network-1 Technologies, Inc. to request leave to file under
`seal Network-1’s objections to the Magistrate Judge’s order striking portions of Network-1’s
`supplemental expert report (Dkt. No. 283). Network-1’s objections contain material and
`information designated by Defendants Google LLC and YouTube LLC (collectively, “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 its objections to the Magistrate
`Judge’s order under seal. Google has indicated that, pursuant to the Court’s Individual Practices,
`Google will submit a letter explaining its position on sealing by October 31, 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.
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`Respectfully submitted,
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`s/ Amy E. Hayden
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`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)
`RUSS, AUGUST & KABAT
`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
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`Case 1:14-cv-02396-PGG-SN Document 284 Filed 10/28/22 Page 2 of 2
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`Hon. Paul G. Gardephe
`October 28, 2022
`Page 2
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`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
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`Attorneys for Network-1 Technologies, Inc.
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