`
`IN THE UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`GENTEX CORPORATION and INDIGO
`TECHNOLOGIES, LLC,
`
`
`Plaintiffs,
`
`THALES VISIONIX, INC.,
`
`
`Involuntary Plaintiff,
`
`
`v.
`
`
`META PLATFORMS, INC. and META
`PLATFORMS TECHNOLOGIES, LLC,
`
`
`Case No. 6:21-cv-00755-ADA
`
`JURY TRIAL DEMANDED
`
`
`
`Defendants.
`
`
`
`
`
`
`DEFENDANTS’ UNOPPOSED MOTION TO SEAL DKT. 79
`
`Meta Platforms, Inc. and Meta Platforms Technologies, LLC (collectively, “Meta” or
`
`“Defendants”) respectfully request that the Court seal Dkt. 79 (the “Public Order”).
`
`The Public Order is a fully public version of the Court’s Order on Meta’s motion to transfer,
`
`originally filed under seal at Dkt. 76 (“Sealed Transfer Order”). Although the Sealed Transfer
`
`Order was signed on June 30, the public docket indicates that the Sealed Transfer Order was not
`
`entered until July 1, as shown in this highlighted screenshot of the public docket:
`
`This July 1 “entered” date is also confirmed by the automated ECF notice attached hereto as
`
`Exhibit 1, which states that the Sealed Transferred Order was “entered on 7/1/2022 at 7:44 AM
`
`CDT.” The Court’s Amended Standing Order Regarding Filing Documents Under Seal and
`
`Redacted Public Versions states: “The movant shall email a redacted version of the Court’s sealed
`
`
`
`
`
`
`
`
`Case 6:21-cv-00755-ADA Document 80 Filed 07/08/22 Page 2 of 4
`
`order for publication within seven days after the Court enters the sealed order.”1 Meta (the moving
`
`party) emailed a redacted version of the Sealed Transfer Order to the Court’s law clerk on July 8,
`
`which is within seven days after the Court entered the Sealed Transfer Order, such that the
`
`redactions were timely provided to the Court.
`
`
`
`In view of Meta’s timely compliance with the Court’s Amended Standing Order, Meta
`
`believes that the redacted version that it emailed is the version that should be made public, not the
`
`fully unredacted version that was filed by the Court at Dkt. 79. The Public Order at Dkt. 79
`
`contains information that Meta believes is confidential to it and its employees. Accordingly, to
`
`preserve the confidentiality of that information, Meta requests that the Court grant this motion to
`
`seal the Public Order at Dkt. 79.
`
`Plaintiffs Gentex Corporation and Indigo Technologies, LLC do not oppose this motion.
`
`
`
`Dated: July 8, 2022
`
`
`
`
`/s/ Joshua Glucoft
`Jeanne M. Heffernan
`Texas State Bar No. 24128395
`KIRKLAND & ELLIS LLP
`401 Congress Avenue
`Austin, TX 78701
`Tel: (512) 678-9100
`Fax: (512) 678-9101
`jheffernan@kirkland.com
`
`Ellisen Shelton Turner (pro hac vice)
`Joshua Glucoft (admitted)
`KIRKLAND & ELLIS LLP
`2049 Century Park East, Suite 3700
`Los Angeles, CA 90067
`Tel: (310) 552-4200
`Fax: (310) 552-5900
`
`
`1 Available at https://www.txwd.uscourts.gov/wp-
`content/uploads/Standing%20Orders/Waco/Albright/Amended%20Standing%20Order%20Regar
`ding%20Filing%20Documents%20Under%20Seal%20and%20Redacted%20Public%20Versions
`%20030722.pdf (emphasis added).
`
`- 2 -
`
`
`
`Case 6:21-cv-00755-ADA Document 80 Filed 07/08/22 Page 3 of 4
`
`ellisen.turner@kirkland.com
`josh.glucoft@kirkland.com
`
`Akshay S. Deoras (pro hac vice)
`KIRKLAND & ELLIS LLP
`555 California Street
`San Francisco, CA 94104
`Tel: (415) 439-1400
`Fax: (415) 439-1500
`akshay.deoras@kirkland.com
`
`Paige Arnette Amstutz
`Texas State Bar No. 00796136
`SCOTT, DOUGLASS & MCCONNICO, LLP
`303 Colorado Street, Suite 2400
`Austin, TX 78701
`Tel: (512) 495-6300
`Fax: (512) 495-6399
`pamstutz@scottdoug.com
`
`Counsel for Defendants Meta Platforms, Inc. and
`Meta Platforms Technologies, LLC
`
`
`
`
`
`
`
`- 3 -
`
`
`
`Case 6:21-cv-00755-ADA Document 80 Filed 07/08/22 Page 4 of 4
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that, on July 8, 2022 all counsel of record who are deemed to have
`
`consented to electronic service are being served with a copy of the foregoing via the Court’s
`
`CM/ECF system.
`
`/s/ Joshua Glucoft
`Joshua Glucoft
`
`
`
`
`
`- 4 -
`
`