`Wilshire Boulevard
`12th Floor
`Los Angeles
`California
`90025
`
`Tel 310.826.7474
`Fax 310.826.6991
`
`www.raklaw.com
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`Case 1:14-cv-02396-PGG-SN Document 286 Filed 11/01/22 Page 1 of 2
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`November 1, 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 in regard to Plaintiff Network-1 Technologies, Inc.’s October 28, 2022 under seal
`filing (Dkt. No. 285 in Case No. 1:14-cv-2396-PGG-SN; Dkt. No. 221 in Case No. 1:14-cv-9558-
`PGG-SN). In Network-1’s letter motion to seal preceding that filing (Dkt. No. 284 in Case No.
`1:14-cv-2396-PGG-SN; Dkt. No. 220 in Case No. 1:14-cv-9558-PGG-SN), I indicated that
`Network-1 believed that its filing contained material and information designated by Defendants
`Google LLC and YouTube LLC (collectively, “Google”) under the Protective Order. In that letter,
`I also noted that Google had indicated to Network-1 that it would 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. However, Google informed
`Network-1 that it does not wish for any portion of the October 28 filing to be redacted. Therefore,
`immediately following this letter, Network-1 will file a public version of the October 28 filing
`with only the confidentiality label redacted.
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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
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`Case 1:14-cv-02396-PGG-SN Document 286 Filed 11/01/22 Page 2 of 2
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`Hon. Paul G. Gardephe
`November 1, 2022
`Page 2
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`jbuczko@raklaw.com
`ahayden@raklaw.com
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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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