`
`
`
`quinn emanuel trial lawyers | new york
`51 Madison Avenue, 22nd Floor, New York, New York 10010-1601 | TEL (212) 849-7000 FAX (212) 849-7100
`
`November 16, 2022
`
`VIA ECF
`
`The Honorable Mary Kay Vyskocil
`United States District Judge
`Southern District of New York
`Daniel Patrick Moynihan U.S. Courthouse
`500 Pearl Street
`New York, NY 10007-1312
`
`
`
`Re: Acuitas Therapeutics Inc. v. Genevant Sciences GmbH and Arbutus Biopharma Corp.,
`Case No. 22-cv-02229-MKV
`
`
`Your Honor:
`
`Pursuant to Rule 9.B of Your Honor’s Individual Rules of Practice in Civil Cases,
`Defendant Genevant Sciences GmbH and Defendant Arbutus Biopharma Corp. (collectively
`“Defendants”), hereby jointly move to seal and/or redact confidential material in their Reply in
`Further Support of Defendants’ Motion to Dismiss the Amended Complaint (“Reply”), which is
`filed concurrently under seal with highlights denoting redactions pursuant to the Court’s
`Standing Order 21-mc-00013 and Section 6 of the Court’s Electronic Case Filing Rules &
`Instructions.
`
`
` Defendants reply brief quotes from sealed portions of Exhibit A of the Declaration of
`Allison Penfield, dated November 1, 2022, which was previously filed in redacted form (Dkt.
`No. 49-1) and under seal (Dkt. No. 51-1) by the Plaintiff pursuant to their sealing and redaction
`application (Dkt. No. 47). Defendants’ proposed sealing and redactions are consistent with those
`of Plaintiff’s, and are narrowly tailored to keep any alleged highly sensitive and proprietary
`information from being disclosed to the public.
`
`Accordingly, Defendants’ respectfully request that the Court grants their application to
`
`seal.
`
`
`
`
`
`quinn emanuel urquhart & sullivan, llp
`
`
`
`ATLANTA | AUSTIN | BERLIN | BOSTON | BRUSSELS | CHICAGO | DOHA | HAMBURG | HONG KONG | HOUSTON | LONDON | LOS ANGELES |
`MANNHEIM | MIAMI | MUNICH | NEUILLY-LA DEFENSE | NEW YORK | PARIS | PERTH | RIYADH | SALT LAKE CITY | SAN FRANCISCO | SEATTLE |
`SHANGHAI | SILICON VALLEY | STUTTGART | SYDNEY | TOKYO | WASHINGTON, DC | ZURICH
`
`
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`Case 1:22-cv-02229-MKV Document 53 Filed 11/16/22 Page 2 of 2
`
`
`Respectfully submitted,
`
`/s/ Raymond N. Nimrod
`
`Raymond N. Nimrod
`
`
`cc:
`
`
`All Counsel of Record (via ECF)
`
`
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`2
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`
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