`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`SHERMAN DIVISION
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`
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`Civil Action No. 4:23-cv-01147-ALM
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`Jury Trial Demanded
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`
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`R2 Solutions LLC,
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` Plaintiff,
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`v.
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`Databricks, Inc.,
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` Defendant.
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`
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`PLAINTIFF’S UNOPPOSED MOTION FOR LEAVE TO FILE UNDER SEAL
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`Plaintiff R2 Solutions LLC (“R2”) files this Unopposed Motion for Leave to File Under
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`Seal its Sur-Reply in Opposition to Defendant Databricks, Inc.’s (“Databricks”) Motion to
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`Transfer (ECF 20) (the “Sur-Reply”).
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`Basis for Motion
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`Plaintiff seeks to seal the Sur-Reply because it contains, incorporates, and/or refers to
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`information that has been identified as confidential business-related information to Databricks.
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`Counsel for Plaintiff has conferred with counsel for Defendant and confirmed that Defendant
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`does not oppose this request. Pursuant to Amended Local Rule CV-5(a)(7)(E), redacted, public
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`versions of this Response and its attachments will be filed within 7 business days.
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`Prayer
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`WHEREFORE, Plaintiff respectfully requests that the Court grant this motion for leave
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`to file under seal and allow the Sur-Reply to be filed and remain under seal until further order of
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`the Court.
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`
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`Case 4:23-cv-01147-ALM Document 37 Filed 06/28/24 Page 2 of 3 PageID #: 1454
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`Dated: June 28, 2024
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`
`Respectfully submitted,
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`
`/s/ Edward R. Nelson III
`EDWARD R. NELSON III
`State Bar No. 00797142
`ed@nelbum.com
`BRENT N. BUMGARDNER
`State Bar No. 00795272
`brent@nelbum.com
`CHRISTOPHER G. GRANAGHAN
`State Bar No. 24078585
`chris@nelbum.com
`JOHN P. MURPHY
`State Bar No. 24056024
`murphy@nelbum.com
`CARDER W. BROOKS
`State Bar No. 24105536
`carder@nelbum.com
`NELSON BUMGARDNER CONROY PC
`3131 West 7th Street, Suite 300
`Fort Worth, Texas 76107
`817.377.9111
`
`COUNSEL FOR PLAINTIFF
`R2 SOLUTIONS LLC
`
`
`
`
`
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`
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`CERTIFICATE OF SERVICE
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`Pursuant to Local Rule CV-5, I hereby certify that the foregoing document was
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`electronically filed with the Clerk of Court using the CM/ECF filing system, which will generate
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`and send an e-mail notification of the filing to all counsel of record on this the 28th day of June,
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`2024.
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`
`
`
`
`
`/s/ Edward R. Nelson III
`
`
`
`2
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`
`
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`Case 4:23-cv-01147-ALM Document 37 Filed 06/28/24 Page 3 of 3 PageID #: 1455
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`CERTIFICATE OF CONFERENCE
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`I hereby certify that counsel for Plaintiff and counsel for Defendant conferred
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`regarding the relief sought by this motion and that this motion is unopposed.
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`
`
`/s/ Edward R. Nelson III
`
`3
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