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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`Civil Action No. 2:19-cv-00209-JRG
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`THE HILLMAN GROUP, INC.
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`KEYME, INC.,
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`Plaintiff,
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`v.
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`Defendant.
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`UNOPPOSED MOTION FOR LEAVE TO FILE EXHIBITS D, E, AND F TO KEYME’S
`MOTION TO DISMISS FOR IMPROPER VENUE UNDER SEAL
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`Defendant KeyMe, LLC1 (“KeyMe”) respectfully requests leave to file Exhibits D, E, and
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`F to KeyMe’s Motion to Dismiss for Improper Venue or, in the Alternative, to Transfer to the
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`Southern District of New York under seal. In support of its unopposed Motion, KeyMe states as
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`follows:
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`1.
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`KeyMe intends to file a Motion to Dismiss for Improper Venue or, in the
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`Alternative, to Transfer to the Southern District of New York. In doing so and in accordance with
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`Local Rule CV-5, KeyMe believes sealing Exhibits D, E, and F is appropriate to protect highly
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`confidential proprietary and business information regarding contractual details between KeyMe
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`and third parties, referenced in these exhibits. See also Declaration of Greg Marsh, attached as
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`Exhibit A to KeyMe’s Motion to Dismiss for Improper Venue, ¶¶ 13-14.
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`1 Plaintiff originally filed suit against “KeyMe, Inc.”; however, that entity no longer exists.
`KeyMe, LLC is the successor-in-interest to KeyMe, Inc.
`1
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`Case 2:19-cv-00209-JRG Document 11 Filed 07/25/19 Page 2 of 3 PageID #: 243
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`2.
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`Counsel for KeyMe conferred with counsel for Plaintiff regarding the requested
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`relief. Counsel for Plaintiff does not oppose KeyMe’s request to file Exhibits D, E, and F to the
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`Motion to Dismiss for Improper Venue under seal.
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`Dated: July 25, 2019
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`Respectfully submitted,
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`/s/ Deron R. Dacus
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`Deron R. Dacus (Bar No. 00790553)
`The Dacus Firm, PC
`821 ESE Loop 323
`Suite 430
`Tyler, TX 75701
`Tel. 903.705.1177
`Fax 903.581.2543
`Email: ddacus@dacusfirm.com
`
`Michael G. Rhodes
`Cooley LLP
`101 California Street, 5th Floor
`San Francisco, CA 94111
`Tel: 415.693.2000
`Fax: 415.693.2222
`Email: rhodesmg@cooley.com
`
`Stephen R. Smith
`Cooley LLP
`1299 Pennsylvania Ave., NW, Suite 700
`Washington, DC 20004
`Tel: 202.842.7800
`Fax: 202.842.7899
`Email: stephen.smith@cooley.com
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`Attorneys for Defendant KeyMe, LLC
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`2
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`Case 2:19-cv-00209-JRG Document 11 Filed 07/25/19 Page 3 of 3 PageID #: 244
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`CERTIFICATE OF CONFERENCE
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`I hereby certify that counsel for KeyMe has complied with the meet and confer requirement
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`in Local Rule CV-7(h). The personal conference required by Local Rule CV-7(h) was conducted
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`on July 24, 2019 via telephonic conference with the following participants: Stephen Smith for
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`KeyMe and Ryan Quinn and Chris Isaac for Hillman. Plaintiff has indicated they are unopposed
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`to this motion.
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`/s/ Stephen Smith
` Stephen Smith
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`CERTIFICATE OF SERVICE
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`I hereby certify that all counsel of record, who are deemed to have consented to electronic
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`service, are being served this July 25, 2019, with a copy of this document via the Court’s CM/ECF
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`system.
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`/s/ Deron R. Dacus
`Deron R. Dacus
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`3
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