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`NORTHSTAR SYSTEMS LLC,
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`v.
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`VOLKSWAGEN AG,
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`Plaintiff,
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`Defendant.
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`Case No. 2:22-cv-00486-JRG
`(LEAD CASE)
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`JURY TRIAL DEMANDED
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`
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`§
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`PLAINTIFF NORTHSTAR SYSTEMS LLC’S
`UNOPPOSED MOTION TO FILE UNDER SEAL
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`Pursuant to Eastern District of Texas Local Rule 5(a)(7)(C), NorthStar Systems LLC
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`(“NorthStar”) moves to file under seal its Sur-Reply Brief in Opposition to Volkswagen AG’s
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`Motion to Dismiss for Failure to State a Claim Pursuant to Rule 12(B)(6) or, in the Alternative, to
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`Transfer Venue Pursuant to 28 U.S.C. § 1404(A) (Dkt. 11) (the “Motion”).
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`NorthStar’s Sur-Reply discusses highly confidential business information related to the
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`operation of a third-party to this litigation. NorthStar’s Sur-Reply also cites confidential
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`information contained in Dkt. 32-2, which was previously filed under seal. There is currently no
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`Protective Order entered in this matter. Accordingly, to preserve the confidentiality of that
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`information, NorthStar respectfully requests that the Sur-Reply be filed under seal.
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`NorthStar has conferred with Defendant Volkswagen AG (“VWAG”) in advance of the
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`filing of this Motion, and VWAG has stated that it does not oppose NorthStar’s request to seal the
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`Sur-Reply. Pursuant to Local Rule CV-5(a)(7)(E), a redacted version of the Sur-Reply will be
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`filed within seven (7) days.
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`Case 2:22-cv-00486-JRG Document 45 Filed 07/19/23 Page 2 of 3 PageID #: 611
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`Dated: July 19, 2023
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`Respectfully submitted,
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`
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`/s/ Vincent J. Rubino, III
`Alfred R. Fabricant
`NY Bar No. 2219392
`Email: ffabricant@fabricantllp.com
`Peter Lambrianakos
`NY Bar No. 2894392
`Email: plambrianakos@fabricantllp.com
`Vincent J. Rubino, III
`NY Bar No. 4557435
`Email: vrubino@fabricantllp.com
`FABRICANT LLP
`411 Theodore Fremd Road, Suite 206 South
`Rye, NY 10580
`Telephone: (212) 257-5797
`Facsimile: (212) 257-5796
`
`John Andrew Rubino
`NY Bar No. 5020797
`Email: jarubino@rubinoip.com
`Michael Mondelli III
`NY Bar No. 5805114
`Email: mmondelli@rubinoip.com
`RUBINO IP
`51 J.F.K. Parkway
`Short Hills, NJ, 07079
`Telephone: (201) 341-9445
`Facsimile: (973) 535-0921
`
`Justin Kurt Truelove
`Texas Bar No. 24013653
`Email: kurt@truelovelawfirm.com
`TRUELOVE LAW FIRM, PLLC
`100 West Houston
`Marshall, Texas 75670
`Telephone: (903) 938-8321
`Facsimile: (903) 215-8510
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`ATTORNEYS FOR PLAINTIFF,
`NORTHSTAR SYSTEMS LLC
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`2
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`Case 2:22-cv-00486-JRG Document 45 Filed 07/19/23 Page 3 of 3 PageID #: 612
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`CERTIFICATE OF SERVICE
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`I hereby certify that on July 19, 2023, a true and correct copy of the above and foregoing
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`document has been served by email on all counsel of record.
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`/s/ Vincent J. Rubino, III
` Vincent J. Rubino, III
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`CERTIFICATE OF COMPLIANCE
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`I hereby certify pursuant to Local Rule CV-5(a)(7) that a motion to seal the document has
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`been filed. I hereby certify that an unredacted version of the above and foregoing document has
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`been served by email on all counsel of record.
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`
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`/s/ Vincent J. Rubino, III
` Vincent J. Rubino, III
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`3
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