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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF PENNSYLVANIA
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`AMERANTH, INC.,
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` v.
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`DOORDASH, INC.,
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`Plaintiff,
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`Defendant.
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`C.A. No.: 2:22-cv-1776-WSH
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`DEFENDANT’S UNOPPOSED MOTION FOR LEAVE TO FILE UNDER SEAL
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`Defendant DoorDash, Inc. (“DoorDash”) respectfully requests leave of Court to file under
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`seal its Brief in Support of its Motion to Dismiss for Improper Venue and Failure to State a Claim
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`(“Brief”), supporting declaration, and any exhibits thereto. In support of the Motion, DoorDash
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`states as follows:
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`1.
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`The deadline for DoorDash to respond to Plaintiff’s First Amended Complaint is
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`June 29, 2023. (Dkt. 13). By June 29, DoorDash intends to file a Motion to Dismiss for Improper
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`Venue and Failure to State a Claim.
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`2.
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`DoorDash’s forthcoming motion will include a declaration from a DoorDash
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`corporate witness containing facts describing the relationship between DoorDash and its
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`employees, contractors, and subsidiaries, which includes confidential operational, financial, and
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`accounting information.
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`3.
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`DoorDash’s Brief will include confidential facts from its corporate witness
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`declaration and discussion thereof in support of its grounds for improper venue.
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`4.
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`Pursuant to LPR 2.2(a), the Automatic Protective Order of Appendix LPR 2.2
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`provides that parties can designate documents as “Protected Information” due to their confidential,
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`Case 2:22-cv-01776-WSH Document 16 Filed 06/22/23 Page 2 of 4
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`sensitive business nature.
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`5.
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`DoorDash intends to designate its corporate witness declaration as “Confidential
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`Attorney Eyes Only Information” under the Automatic Protective Order.
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`6.
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`Consequently, DoorDash requests leave to file its Brief and accompanying
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`corporate witness declaration under seal. (LCvR 5.2(H); J. Hardy Pr. and Proc. R. II(H)).
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`7.
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`To ensure that the public has meaningful access to DoorDash’s forthcoming Brief,
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`DoorDash simultaneously requests leave to redact confidential information from the Brief that
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`originates from DoorDash’s corporate witness declaration. A redacted version of the Brief will be
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`filed in unsealed form.
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`8.
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`Counsel for DoorDash has conferred with counsel for Plaintiff, and they do not
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`oppose the relief requested in this Motion.
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`WHEREFORE, DoorDash respectfully request that this Motion be granted, and that
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`DoorDash be permitted to file its Brief in Support of its Motion to Dismiss for Improper Venue
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`and Failure to State a Claim, along with its accompanying declaration and any exhibits thereto
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`under seal. DoorDash further requests leave to redact its Brief in Support of its Motion to Dismiss
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`for Improper Venue and Failure to State a Claim. A proposed Order is attached.
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`2
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`Case 2:22-cv-01776-WSH Document 16 Filed 06/22/23 Page 3 of 4
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`Dated: June 22, 2023
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`BENESCH, FRIEDLANDER, COPLAN &
` ARONOFF LLP
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`/s/ Richard D. Kalson
`Richard D. Kalson
`1330 Avenue of Americas, 23rd Floor
`New York, NY 10019
`Telephone: (614) 223-9380
`Facsimile: (412) 417-4209
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`Attorneys for Defendant
`DoorDash, Inc.
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`3
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`Case 2:22-cv-01776-WSH Document 16 Filed 06/22/23 Page 4 of 4
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`CERTIFICATE OF SERVICE
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`I hereby certify that on June 22, 2023, I electronically filed the foregoing with the Clerk of
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`the Court for the United States District Court for the Western District of Pennsylvania by using
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`the CM/ECF system. I certify that all participants in the case are registered CM/ECF users and that
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`service will be accomplished by the CM/ECF system.
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`/s/ Richard D. Kalson
`Richard D. Kalson
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`4
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