`
`
`
`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
`
`WRITER'S DIRECT DIAL NO.
`(212) 849-7412
`
`WRITER'S EMAIL ADDRESS
`raynimrod@quinnemanuel.com
`
`August 1, 2023
`
`VIA ECF
`
`Hon. Mary Kay Vyskocil
`United States District Court
`Southern District of New York
`500 Pearl Street, Room 2230
`New York, NY 10007
`
`
`
`Re:
`
`Acuitas Therapeutics Inc. v. Genevant Sciences GmbH et al.,
`Case No. 1:22-cv-02229-MKV
`
`
`Dear Judge Vyskocil:
`
`Pursuant to Rule 9.B of Your Honor’s Individual Rules of Practice in Civil Cases,
`Defendants Genevant Sciences GmbH and Arbutus Biopharma Corporation (collectively,
`“Defendants”) hereby jointly move to seal and/or redact confidential material in their letter to Your
`Honor of today’s date, which is filed concurrently under seal with highlights that denote redactions
`in conformity with the Court’s Standing Order 19-mc-00583 and Section 6 of the Court’s
`Electronic Case Filing Rules & Instructions.
`
`In particular, Defendants’ letter quotes from sealed portions of Plaintiff’s Opposition to
`Defendants’ Motion to Dismiss for Lack of Subject Matter Jurisdiction, which was previously filed
`in redacted form (DI 48) and under seal (DI 50) by the Plaintiff pursuant to its sealing and redaction
`application (DI 47). Defendants’ proposed sealing and redactions are consistent with those of
`Plaintiff, 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 grant their application to seal.
`
`
`Respectfully submitted,
` /s/ Raymond N. Nimrod
`Raymond N. Nimrod
`
`cc:
`
`All Counsel of Record (via ECF)
`
`
`
`quinn emanuel urquhart & sullivan, llp
`ATLANTA | AUSTIN | 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
`
`
`
`
`
`
`
`
`