ADRIENNE BENSON and MARY SIMONSON, individually and on behalf of all others similarly situated,

I went through my credit card statements (those that I still had; some I could not find) and came to a total of $52,540 spent playing DoubleDown Casino from 2015 to February 2020.

I’ve taken out loans with lower finance charges just to try to pay my monthly amount due.

1700 Seventh Avenue, Suite 2200 Seattle, Washington 98101-4416 Tel: 206.682.5600 • Fax: 206.682.2992 DocuS gn Enve ope ID: 80D76B67-C553-47B6-9ED7-888EF575938C started again.

1700 Seventh Avenue, Suite 2200 Seattle, Washington 98101-4416 Tel: 206.682.5600 • Fax: 206.682.2992

ADRIENNE BENSON and MARY SIMONSON, individually and on behalf of all others similarly situated,

1 2 3 4 5 6 7 8 9 Defendants International Game Technology and IGT (together, the “IGT Defendants”) respectfully submit this reply in support of their motion to seal Exhibits A through D to their Response to Plaintiffs’ Motion for Class Certification and Preliminary Injunction (“Response”) and portions of the Response discussing the Exhibits.

First, although plaintiffs argue that defendants have not given “compelling reasons” for sealing the documents at issue, plaintiffs fail to address, much less distinguish, cases that recognize “compelling reasons” in situations, like this one, where the disclosure of “business information ... might harm a litigant’s competitive standing.” See Ctr.

The only specific terms defendants wish to seal relate to licensing fee calculations, royalty formulas, and other similarly-sensitive commercial information.

Therefore, the IGT Defendants respectfully request that the Court grant them leave to file under seal Exhibits A through D to their Response to Plaintiffs’ Motion for Class Certification and Preliminary Injunction and portions of the Response discussing the Exhibits.

350 N LaSalle Street, 14th Floor, Chicago, IL 60654 Tel: 312.589.6370 • Fax: 312.589.6378 Pursuant to Civil Local Rule 5(g) and the protective order at Dkt. 123, Plaintiffs respectfully move for leave to file under seal the following materials in connection with their Reply in Support of Class Certification and Preliminary Injunction (the “Reply”): First, selectively-redacted transcripts of deposition testimony given by Plaintiffs and the Declarants,1 which contain extremely sensitive and/or personally-identifying information and were designated by Plaintiffs’ counsel as “Confidential.” While there exists a “strong presumption of access to judicial records,” the presumption is overcome by a showing of “compelling reasons” to seal documents attached to dispositive material.

Second, transcripts of deposition testimony given by Defendants’ employees and corporate witnesses pursuant to Rule 30(b)(6), including: (i) Alex Entrikin, (ii) Jude Cooper, (iii) Julie Frederick, (iv) Leslie Keddie, (v) and Joe Sigrist on behalf of DoubleDown Interactive, LLC, (vi) and Suzy Langham, and (vii) Jennifer Peters on behalf of IGT.

Catherine Witt, Sandra Logan, Deborah Raymond, Patrick Bailey, Jan Saari, and Olivia Werner.

For the foregoing reasons, Plaintiffs respectfully request leave to file under seal (1) limited portions of transcripts of oral testimony given by Plaintiffs and the Declarants, (2) transcripts of oral testimony given by Defendants’ employees and corporate witnesses, (3) documents bates-stamped DDI_77; DDI_213; DDI_374; DDI_966; DDI_1811; DDI_1942;

1700 Seventh Avenue, Suite 2200 Seattle, Washington 98101 Tel: 206.682.5600 *Admitted pro hac vice Attorneys for Plaintiffs and the Putative Class

920 Fifth Avenue, Suite 3300 Seattle, WA 98104-1610 206.622.3150 main · 206.757.7700 fax 1 2 3 4 5 6 7 8 9 recent settlements of other class actions, which captures the true scope of injunctive relief Plaintiffs could seek here.

That variance independently creates a controlling question of law the resolution of which would materially advance the litigation.1 Second, Plaintiffs’ threat to file dozens of single-state class actions in this district, Dkt. 269 at 6, is empty as well because it relies on the false premise that those litigations would have any merit.

As explained in Double Down’s Motion, substantial grounds for difference of opinion exist here regarding the issues presented for certification from the Court’s Order because they raise “novel and difficult questions of first impression,” upon which “reasonable jurists might disagree,” Reese v. BP Expl.

But in reaching its decision, the Court here relied on what it believed to be Thornell I’s expression of the exact opposite conclusion, and that it was “giv[ing] effect” to “the legislature’s intent regarding the range of a state law” on “the out-of-state facts.” Order at 9.

And what is missing from Plaintiffs’ retelling of the litigation history is Plaintiffs’ own requests for relief from deadlines, see Dkt. 161, 236, and their role in deluging the docket and sapping Double Down’s legal resources, including by belatedly demanding production of certain discovery and filing motions to compel on the same issues.

SIMONSON, individually and on behalf of all others similarly situated,

DOUBLE DOWN INTERACTIVE, LLC, a Washington limited liability company, and INTERNATIONAL GAME TECHNOLOGY, a Nevada Corporation,

On April 15, 2021, Defendants Double Down Interactive, LLC and International Game Technology filed a Motion for Certification Regarding Abstention Pursuant to 28 U.S.C. § 1292(b) and Motion to Stay (the “Motion”).

- 3 Duane Morris LLP Spear Tower One Market Plaza, Suite 2200 San Francisco, CA 94105 Telephone: +1 415 957 3000 Fax: +1 415 957 3001

I hereby certify that on this day I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system which will send notification of such filing to all counsel of record.